98 
of known or suspected carcinogens, mutagens, and teratogens with- 
out any consideration of the concentrations of such materials and 
wastes. 
For example, all materials contain some level of radioactive sub- 
stances in at least trace quantities, as naturally occurring radionu- 
clides. Now, these radioactive substances are recognized carcino- 
gens. Under this definition, all materials would be banned from 
ocean disposal. A complete prohibition of ocean disposal of radionu- 
clides or other carcinogens could foreclose ocean disposal options 
without an adequate scientific basis in that it would not relate to 
the concentration and the possiblity of harm from those sub- 
stances. That was another concern which we had. 
We would suggest that section 102(a)(1)(d) should be shifted to 
section 102(a)(1)(e) where trace amounts of known and suspected 
carcinogens could be allowed. 
Mr. D’Amours. That is a good recommendation and it is already 
our intention. 
Mr. ScHatzow. I see. Thank you, Mr. Chairman. 
Another provision of the staff draft was section 102(a)(1)() which 
provided for a phaseout of dumping in New York Bight Apex. We 
believe this position is premature. The Agency has a rulemaking 
package now going through the final stages of Agency review 
which will propose the designation of the 106-mile site for munici- 
pal wastes and which will seek comment on a petition by New 
York City and a number of New Jersey municipalities to redesig- 
nate the 12-mile site. It will also be seeking comments on the 60- 
mile site which was designated as an alternate site back in 1977. 
We believe that going through that process of public debate and 
consideration and hearings both from the public and the scientists 
on the relative merits and demerits of those three sites is an appro- 
priate way to go. 
Mr. D’Amours. While you are on the question of the New York 
Bight, it has been referred to as one of the most polluted areas of 
ocean anywhere in the world. 
Do you have any objection to moving to the 106-mile site to some 
other place? The only difference would be cost, I suppose. We were 
told just a minute ago that cost wasn’t terribly relevant. 
Would there be any reticence about moving to another site, if it 
would help the Bight Apex to restore itself? 
Mr. ScHatzow. I think that is the controversial issue in terms of 
the Bight Apex. NOAA has testified on this issue a number of 
times. The critical question is what is the contribution of sewage 
sludge to the total contamination of the New York Bight Apex? 
NOAA’s testimony has been that the Bight Apex is in a steady 
state, that sewage sludge accounts for approximately 3 to 7 percent 
of phe degradation at that site, and that removing the sewage 
sludge—— 
Mr. D’Amours. What was the percentage figure? I missed that. 
Mr. ScHatzow. I believe it is 3 to 7 percent. Removing the 
sludge, stopping the sludge dumping at the 12-mile site, is not 
likely to have any significant impact on the degradation at that 
site. 
Mr. D’Amours. All right. This is not a debate. It is testimony. 
We don’t share your view on that, but go ahead. 
