oll 
7. If a fee system for ocean dumping were imposed, should it apply across the 
board to all dumpers, or should it distinguish between different types of materials 
and permits? . : 
We do not support a fee system for ocean disposal. If a fee were imposed it should 
be limited to the actual costs incurred by the Government in administering the 
permit system. 
8. To what extent to the existing environmental criteria for evaluating ocean 
dumping permit applications, by themselves, preclude ocean dumping of sewage 
sludge? What percentage of sewage sludge currently ocean dumped would fail these 
evironmental tests? 
The section 102A criteria by themselves do not preclude the dumping of sewage 
sludge. It is not possible to identify what percentage of sewage sludge would fail the 
environmental tests since suitable bioaccumulation tests havae never been devel- 
oped. 
Mr. HuGues. Our next panel consists of Dr. Edward Goldberg, 
Scripps Institution of Oceanography and Mr. Rocco Ricci, chief en- 
gineer of Passaic Valley Sewage Commission. bok 
We are delighted to have both of you. Rocco Ricci is no stranger 
to those of us from New Jersey. Mr. Ricci served as Commissioner 
in our Department of Environmental Protection. Also served at the 
Environmental Protection Agency. Dr. Edward Goldberg is a 
renown scientist, oceanographer, and a teacher of my own legisla- 
tive staff. 
We are delighted to have both of you here today. Why don’t we 
start with Dr. Goldberg. We have your statement which, without 
objection, will be made a part of the record and we hope that you 
can summarize it. 
STATEMENT OF DR. EDWARD GOLDBERG, SCRIPPS INSTITUTION 
OF OCEANOGRAPHY, AND ROCCO RICCI, CHIEF ENGINEER, 
PASSAIC VALLEY SEWAGE COMMISSION 
Mr. GoLpBErG. Thank you, sir. 
Mr. Chairman, Congressmen, I am Edward D. Goldberg, a profes- 
sor of chemistry at the Scripps Institution of Oceanography, the 
University of California at San Diego. For the past 25 years I have 
been involved in marine pollution problems in my research, teach- 
ing and public affairs. I have written a book on the problem of 
marine pollution. I have convened a number of workshops for na- 
tional and international agencies. Most recently I have convened 
two workshops for NOAA which have attempted to identify the 
spectrum of marine pollutants and to formulate the assimilative 
capacity concept. 
I have managed during 3 years for EPA the only national moni- 
toring program for marine pollutants, the “Mussel Watch.” During 
this period we were able to identify a serious marine pollution 
problem at New Bedford Harbor, Mass. Polychlorinated biphenyls, 
the PCBs were high in the mussels. As a consequence the fishery 
there was closed, when unacceptable PCB levels were measured in 
commercial species. 
Also in a somewhat different sense we were able to establish that 
the dumping of radioactive waste containers off the Farralon Is- 
lands near San Francisco were contributing no problems to either 
human health or the health of organisms as a result of leakage. 
Today, I would like to address my remarks to the general prob- 
lem of modifications to the Marine Protection, Research, and Sanc- 
tuaries Act that concerns you 
