571 



The seabed concept is thus quite unlike sea dumping and 

 should be thought of as a variant of isolation of radio- 

 active waste within stable geological formations on land, 

 the difference being that the coordinates are at sea. Also, 

 because of the potentially higher costs of this technique, 

 it would almost certainly be reserved for solidified, 

 encapsulated high-level waste which could not be sea 

 dumped under the London Convention. 



Hearings , supra n. 1(4), at 554-555. This logic could be 

 read to mean that as IAEA and the international community 

 move toward a regime of ocean dumping that stresses the 

 need for isolation and containment of wastes, that a 

 single , conceptual model is being developed that should apply 

 to sub-seabed emplacement as well. However, although IAEA 

 has begun to stress the containment of wastes, containment 

 of wastes that are not embedded in the sea floor will never 

 achieve complete isolation. The IAEA containment strategy 

 is therefore not a complete isolation strategy, unlike 

 sub-seabed emplacement. It may thus be argued that sub- 

 seabed emplacement remains a unique method of disposal that 

 does not fall under the terms of the Convention. 



18. IAEA Doc. GOV/1622 (Sept. 13, 1973). 



19. Id.. 



20. The Radiological Basis of the IAEA Revised Definition and 

 Recommendations Concerning High-Level Radioactive Waste 

 Unsuitable for Diimping at Sea: Report of the Consultants 

 Meeting to Review the Radiological Basis of the Provisional 

 Definition and Recommendations for the Convention on the 

 Prevention of Marine Pollution by Dumping of Wastes and Other 

 Matter Organized by the International Atomic Energy Agency, 

 IAEA - 211 (1978) . 



21. The Convention, Appendix IV. 



22. See Deese, Nuclear Power and Radioactive Waste (1978), at 82. 



23. See Deese, "Seabed Emplacement and Political Reality," 20 

 Oceanus 47, 52 (1977). 



24. Hearings, supra n. 1(4). 



25. Id . , at 798-799. 



26. Memorandum from Daniel Finn, Staff Attorney, to Sam Bleicher, 

 Deputy Assistant Administrator, NOAA, "Sub-Seabed Disposal 



of High-Level Radioactive Wastes" (Nov. 10, 1978). 



69-848 - 81 - 



