535 



detrimental to the environment than littoral drift or fluvial deposits. Areas which 

 are to be dredged sometimes have been polluted by indiscriminate sewage and 

 sludge outfalls which, for the lack of proper treatment and disposal, deposit pol- 

 luted material on nearby harbor bottoms. In such eases, dredged spoils are the 

 victim, rather than cause of pollution. It would be gro.ssly unfair in view of these 

 facts to place an economic burden on navigation improvements in the form of 

 excessive transportation costs ^^•ith what, in effect, is a form of interim pollu- 

 tion abatement. Just as pollution control facilities are funded specially for this 

 purpose, any extra costs for disposal of polluted dredgetl spoils should not be 

 borne by navigation improvements, but by pollution abatement programs. We 

 respectfully submit that these factors must be carefully considered in this 

 legislation. 



Sincerely, 



Hayden B. Johnson, 

 Coordinator, Office for Environmental Programs. 



Statement of the Manufacturing Chemists Association 



The vital importance of the ocean environment to our total ecological well be- 

 ing is an undisputed scientific fact. It is important to recognize, however, that 

 the oceans are the ultimate sink in the hydrologic cycle. An inquisitive child 

 might ask the question. "Why are the oceans salty?" The answer is not so 

 apparent. The oceans receive, concentrate, and to a degree provide natural treat- 

 ment to water-borne substances. Natural and man-made water-borne substances 

 eventually find their way to the oceans where the water evaporates. Rains then 

 fall over the land and fresh water resources are replenished. 



We are faced with a dichotomy. On the one hand, oceans are the source of life, 

 vital to ecological well being, and a significant economic factor in many parts of 

 the world. On the other hand, oceans are the natural and ultimate depository 

 for water-borne residues of man and nature. 



Decisive action must be taken to regulate and control the practice of dumping 

 deleterious wastes into oceans and coastal waters. In some instances serious 

 problems have arisen from irresponsible dumping practices — ^primarily dredging 

 spoils and municipal sewage shidges in coastal waters where the contaminating 

 materials have washed shoreward or affected commercial and sport fishing. Such 

 practices should be prohibited or strictly controlled. We submit, however, that 

 there are instances where ocean disposal, if resix»nsibly and conscientiously per- 

 formed is justified and that this disposal method should not be categorically 

 prohibited. 



We would like to put forth for consideration some basic regulatory concepts 

 and then comment specifically on the proposed "Marine Protection Act of 1971". 



The hydrologic cycle is an element in a complex ecological system which must 

 be balanced to serve mankind's needs. How we go about maintaining this balance 

 is the central issue. It is our view that control of ocean disposal practices should 

 not be totally divorced from protection of coastal and estuarine waters or inland 

 fresh water lakes, streams, and ground waters. The interplay between all aspects 

 of water pollution control dictates that a flexible grant of authority be given to 

 the regulatory agency. The agency should have latitude to determine within rea- 

 sonable bounds the control strategy and alternatives most appropriate in a partic- 

 ular instance. 



It should be recognized that there are technical limitations on what can be 

 accomplished in wastewater treatment and control. It is not always possible, 

 with today's state of the art, to adequately treat and control all wastewaters to a 

 degree which would allow the safe discharge to surface waters. Some waste- 

 waters are presently untreatable; others may be treatable, but where treatment 

 does not result in complete destruction, residuals may have adverse environ- 

 mental consequences. 



The diversity and scope of the chemical industry present a wide range of waste 

 residuals that must be disposed of. The industry has been forced to seek various 

 disiwsal alternatives when such wastes cannot l>e safely or economically recycled. 

 These alternatives are deep well injection, land application, incineration, and 

 ocean dumping. Each has its place if properly selected and conscientiously i>er- 

 formed. The central question is which disposal alternative poses the least risk 



