510 
4. What changes in Federal or state law or regulations are necessary to permit 
the NOAA-Orange County project to proceed? 
Currently the 1981 Amendments to the Federal Clean Water Act prohibit the dis- 
charge of sludge thru an ocean outfall. 
We suggest that Federal legislation be enacted under section 405 to permit this 
research project to gain the knowledge required to scientifically evaluate the assimi- 
lative capacity of the ocean. 
At the present time the California State Water Resources Control Board prohibits 
by regulation in its California Ocean Plan the discharge of sludge to the ocean. 
In recent conversations with state personnel pertaining to our project, they are 
only concerned with state waters which is defined as out to the three mile limit. It 
may not be necessary to change any state requirements for this research project to 
go forward. 
5. How would monitoring of any sludge disposal be evaluated and who would do 
it? 
Presently, a planning study is underway at the California Institute of Technology, 
Pasadena, California under the direction of Dr. Norman Brooks, Director of their 
Environmental Quality Laboratory. 
This independent group including representatives of EPA, NOAA, Woods Hole 
Oceanographic Institute, Scripps Institute of Oceanography, California Fish and 
Game and many nationally recognized scientists will develop a procedure by which 
the recommended monitoring program will be evaluated. We believe the evaluation 
will be done by a peer group of individuals from agencies and institutions represent- 
ed in this planning group. 
6. If the results of more focused monitoring and evaluation demonstrate that 
ocean disposal simply poses too many environmental problems, what would the 
Coastal Agencies then do about handling sludge? 
The coastal communities would proceed with the most desirable alternative. The 
decision to go to composting, combustion, direct burial in landfills, land spreading or 
any other disposal method would be made on a case-by-case basis. 
QUESTIONS SUBMITTED BY Hon. EDWIN B. ForsyTHE AND ANSWERED BY CONFERENCE 
oF COASTAL AGENCIES 
1. If costs are borne by municipalities to cover monitoring of ocean disposal, 
should these costs be included in an economic balance? 
Economies should only be considered after Human Health and Environmental 
Factors, and monitoring costs should be a part of the economic analysis. 
2. Do you feel there will continue to be the incentive to find cost-effective ways to 
reuse or recycle our wastes when one of the ocean dumping criterion is to consider 
the need for such dumping in terms of economics? 
Yes, we have a continuing responsibility to our ratepayers to find the most cost- 
effective and environmentally sound program for waste disposal. 
3. Is incineration a cost-effective alternative to using other media for disposal? 
The costs of incineration are high but in certain circumstances it is the most envi- 
ronmentally sound basis of disposal. 
4, With regard to the NOAA report presented at Woods Hole last year which com- 
pared the effects of the 12-mile site versus other ocean dumpsites off the northeast 
coast, were there any significant findings which would lead us to conclude the New 
York Bight Apex should be barred from consideration for waste disposal? 
In our judgment, the findings and conclusions would not compel barring consider- 
ation of the New York Bight Apex for waste disposal. But, perhaps more to the 
point, we believe legitimate and serious questions have been raised regarding those 
findings and conclusions. Should certain types of materials be banned from disposal 
at this site or any other ocean site? 
Absolutely yes—there are certain materials that should not be disposed of in the 
ocean. 
5. Do the examples in the testimony (page 5) regarding cadmium problems also 
relate to a land disposal option where the sludge could be contained? 
If perpetual containment could be assured, then there would be no human food 
chain problem. The nature and volume is such that we do not believe containment 
is possible. 
6. Why do you feel the new language will result in barring the oceans from con- 
sideration as an alternative for waste disposal of sludge? 
There are a number of provisions in the staff draft which would have this effect; 
the principal one among which is the absolute ban on all carcinogins. 
