32 



I want to reiterate, because I think it is important to understand 

 in terms of the structure of the act and the implementing EPA reg- 

 ulations that a decision to designate a particular site is not a deci- 

 sion to allow anyone specifically to use that site. 



For instance, if the agency were to designate the 106-mile site, 

 that is not a decision that the site is appropriate for either the ex- 

 isting dumpers at the 12-mile site or any other dumpers to use that 

 site. 



That decision has to be made in the permit context, based on an 

 analysis of that specific waste and on an analysis of the land-based 

 alternatives. 



On pages 12 and 13, we discuss the general criteria for site desig- 

 nation. On the bottom of page 13, we compare the characteristics of 

 the 12-mile site and the 106-mile site in terms of what we believe to 

 be some major criteria. 



In the interest of saving time, I am going to skip that, Mr. Chair- 

 man, because it is in front of the committee members. 



We conclude, after having gone through many of those character- 

 istics on the bottom of page 16, that our preliminary findings, 

 which I might add is supported by NO A A, is that the 106-mile site 

 is environmentally acceptable for the disposal of sewage sludges 

 and that it has a variety of characteristics that make it much more 

 environmentally acceptable than the 12-mile site. 



I also note on the bottom of the page that participating munici- 

 palities contend that the use of the 106-mile site would increase 

 their current disposal cost by three to four times. 



Beginning on page 17, we talk about the history in terms of what 

 is going on now, the fact that the New Jersey and New York dump- 

 ers are dumping under court order; what the requirements of that 

 court order are in terms of EPA; and we go through some of the 

 things we are doing now, specifically responding to a petition from 

 the municipal dumpers to redesignate the 12-mile site, and through 

 some of the specifics of our solicitation of comments, the fact we 

 have received additional materials from the dumpers. 



We note on page 18 that EPA proposed in December 1982 the 

 designation of the 106-mile site for the continuing disposal of aque- 

 ous industrial waste and for municipal sewage sludges. 



The EPA had a public hearing on May 10 in Rehobeth, Del. I 

 know Congressman Carper was there, and along with a number of 

 other people, to receive comments on the designation of the 106- 

 mile site. As a result of the concerns expressed at the public hear- 

 ings there and our evaluation of the public comments, there are a 

 number of specific things that we are not thinking about in terms 

 of the 106-mile site. 



On page 18 I mentioned briefly a few of the comments that are 

 mentioned. One is that we will not complete any site-designation 

 until we have what we believe to be an adequate and complete 

 long-term monitoring program. 



We have the outlines for such a program that has been devel- 

 oped by EPA and NOAA. We will work as I commented at the 

 public hearing with the coastal States to assure that this monitor- 

 ing plan adequately reflects their concerns and needs. 



We also mentioned that we are considering excluding the use of 

 those areas of the site which lie on the Continental Shelf. This 



