The release of the 52 American hostages in Tehran was held up yesterday by a dispute over one provision in an 11-page appendix to the financial arrangements governing the transfer of billions of dollars of Iranian frozen assets.

American officials said it was just a technical disagreement.

But the top official of Iran's central bank, Ali Reza Nobari, in a telephone interview early night from Tehran, said the provision was written to limit the amount of frozen Iranian bank deposits that the American banks would have to return to the Tehran government.

Later last night, top U.S. government officials said they had accepted the criticism, and had suggested several language changes to satisfy Nobari. But the Iranian side had yet to accept any of them.

"We believe they are just afraid to take the final step," one American official said.

Nobari said the document was part of a complex formula for handling the transfer of more than $4 billion of now-frozen Iranian bank deposits held by the European branches of American banks. It listed, he said, the deposits and interest that each of the American banks was to provide.

The provision to which he objected, Nobari said, concluded with language saying that if Iran accepted the amounts the American banks listed, it could not then challenge the amounts and seek more at a later date.

Nobari said he did not sign the document because the American bank totals were less than the amounts on record with the central bank.

"I disagree with their figures," Nobari said, adding that he wanted to have the right to "challenge" them after the actual transfer had taken place.

Nobari did not think the language problem was insoluble and said he was in the process of drafting orders to the American banks that would direct the frozen funds to be sent to the London account.

Nevertheless, as a result of this complication, the Iranians last night had not yet opened an escrow account in the Bank of England as required in the overall agreement.

A more ominous statement on the delay came from Iran's chief hostage negotiator, Behzad Nabavi, who was quoted by the official Pars News Agency as saying that Algeria had given Iran a surprise appendix that he called "an underhanded maneuver for delaying the final solution to the problem."

According to one U.S source, the appendix spelled out the mechanics for the transfer of funds among the central banks of Algeria, England and the United States and their handling of an escrow account that would hold several billion dollars destined for use in repaying American bank loans to Iran.

The Iranian central bank, which had not been part of the group negotiating this part of the financial agreement, was reported to have first seen it Sunday, at which time Nobari requested it be redrafted to include his bank as one of the participants.

When he got his first look at the redrafted document, sent him by the Algerian intermediaries in the negotiations, he balked at signing it.

A spokesman for Citibank said that the banks had nothing to do with the appendix. American officials maintained yesterday that the document affected only actions by the central banks, not the private banks with Iranian loans outstanding.

Lacking Iran's signature on this document, U.S. officials held back throughout the day on instructing the American banks to begin transferring the frozen deposits to an escrow account in the Bank of England.

According to banking sources, once an order was given to send the billions of dollars, it would "just take minutes" to accomplish.

State Department spokesman John Trattner told reporters that the United States had not sent any surprise appendix to Tehran, only a number of messages.

Secretary of State Edmund S. Muskie said the "hangup" was in the implementing of documents in the agreement that have not yet been made public.

Under the agreement, the American banks were to transfer to an escrow account in the Bank of England $4 billion in Iranian funds that they held in their European branches. The escrow account was to be controlled by the government of Algeria. The Federal Reserve Bank of New York is ready to put another $1.3 billion in cash and 1.6 million ounces of gold (worth about $1 billion) in that same account.

These three sums -- just over $6 billion altogether -- make up all the money Iran would receive prior to the takeoff of the hostages from Iran.

Iran has roughly $6 billion in additional frozen assets -- bank deposits in this country, accounts payable for oil, and spare parts and military equipment that Iran owns here. These would not pass to the Tehran government until an international claims commission was established and myriad lawsuits in American courts were nullified.

American banking sources said yesterday Nobari's action could represent just a misunderstanding or "more than that."

Nobari has been a close political ally of Iran's president, Abol Hassan Bani-Sadr. As part of the internal political conflict between Bani-sadr and Iran's minister, Mohammed Ali Rajai, Nobari's role in the hostage negotiations has been sharply limited over the last few weeks.

The problem-causing document is related to the final part of the financial agreement -- a last-minute arrangement worked out over the weekend to settle the outstanding loans to Iran from American commercial banks.

Without a settlement of the issues involving the American banks, Carter administration officials had made it clear they would not deliver to Iran any of its frozen bank deposits.

For weeks, the banks and representatives of Iran's central bank have attempted to reestablish relationships that existed prior to Nov. 14, 1979, the day President Carter froze all Iran's assets held by American banks and companies both inside and outside the United States.

The regulations under the freeze had given the American banks the right to use frozen Iranian deposits to pay off any loans they had made to Iranian entities that went into default. One day after tha freeze went into effect, banks declared Iran's loans in default and the banks dipped into the deposits to pay themselves off.

The problem in restoring the prefreeze situation proved impossible.

Suddenly, however, Iran proposed that the banks accept a new idea and liquidate all the pre-freeze loans rather than restore them. This involved repayment of all the outstanding loans using the unfrozen bank deposits on a two-stage schedule.

The plan, accepted in principle by representatives of 12 major U.S. banks late Friday in Washington, calls for Iran to repay immediately $3.6 billion in loans made by syndicates of American and European banks to the government of the late shah. The funds would come from the unfrozen deposits in European branches of the banks.

In addition, the Iranians were reported to have agreed to set up a separate escrow fund of $1.5 billion from which other loans to Iranian institutional borrowers, such as development banks, would be paid as the legality of these loans was validated.

The net result of the transfers and subsequent repayment of the old loan obligations was that Iran would wind up with only about $2 billion in cash left over, at the time the hostages were released.

The appendix that caused yesterday's impasse relates to implementation of this bank settlement agreement. And the account that Nobari failed to open in the Bank of England yesterday, sources said, is the one that would have received money earmarked for paying off these bank loans.