509 
ing to bear the responsibility for any subsequent cleanup that 
might occur as the state of the art proves that we learn a lot more 
about the damage that we do. I would like the position of the con- 
ference on that. I wouldn’t ask you today because I know you prob- 
ably have not discussed it. 
Mr. White. We have not. 
[The information follows:] 
CONFERENCE OF COASTAL AGENCIES POSITION ON AMENDMENT 
The Conference of Coastal Agencies opposes the concept of absolute liability, with- 
out regard to the state of the art, without regard to any negligence or other wrong- 
doing on the part of the agency, without regard to the cost that might be involved, 
and without regard to any responsibility on the part of others. Members of CCA 
who either presently deposit sludge in the ocean or who may do so in the future 
recognize their obligation to do so in a manner that is acceptable to the public. Fur- 
thermore they recognize their duty to comply with all pertinent laws and to take 
appropriate measures to minimize any detriments that might result from their ac- 
tions. But there is no demonstrated basis for or rationale for a requirement of abso- 
lute liability. 
Mr. HuGues. Thank you very much for your testimony. 
Mr. Waite. Thank you, Mr. Chairman. 
[The following was received for the record:] 
QUESTIONS SUBMITTED BY Hon. GLENN M. ANDERSON AND ANSWERED BY CONFERENCE 
oF COASTAL AGENCIES 
1. What type of monitoring and evaluation did you have in mind for municipal 
agencies to perform? 
Municipal Ocean Dischargers should be willing and capable of collecting oceano- 
graphic, biological and chemical data on the discharge site and surrounding area. 
Ocean currents, water quality analyses, chemistry of the bottom muds, physical 
characteristics of the biota, and chemical body burdens of the biota are the types of 
things that should be evaluated on a regular basis. 
By regular basis, I mean, the investigative sampling should be done frequently 
enough to enable evaluation over the long term. 
For example, the Agency I represent, Orange County, has collected data on the 
effects of our treated effluent on the marine environment for many years. The re- 
sults of our investigations are annually reported to the State Regulatory Agencies. 
By reviewing this data over a span of years, the long term effect of the discharge 
can be evaluated. 
ee Insofar as Orange County is concerned, what disposal options do you presently 
use? 
The digested sludges are mechanically dewatered to approximately 20 percent 
solids by centrifuges. The material is then trucked 15 miles to a county landfill 
where we are required to air dry the material to 50 percent solids before burial in 
the landfill. 
This operation is costly (labor and energy intensive) and does tend to create an 
odor nuisance at the treatment plant as well as at the landfall. 
We are currently conducting engineering studies on an expanded land composting 
project at a remote site. However, we have encountered public opposition to this 
project. 
We are also considering on site (at the treatment plants) mechanical composting. 
The drawback to this method is that we will wind up with more sludge to dispose of 
since carbonaceous material (sawdust, shredded paper, wood chips) must be added to 
the digested sludge to generate the heat necessary for composting. 
3. If the research project with NOAA is implemented, what percentage of your 
sludge would go into the ocean? 
The daily volume of solids removed during our treatment process is reduced by 50 
percent through the anerobic digestion process by producing 3,000,000 cu ft. of meth- 
ane gas each day to provide half of our energy needs. The resulting residues, 100 
percent from the digestion process which is represented by a 25 ft. x 25 ft. x 6 ft. 
sgh volume, would be discharged approximately 8.5 miles offshore in 1,000 ft. of 
water. 
