77 



Now, compare for me if you will the prospective deregulation 

 that will take place at the 106-mile site with that which has al- 

 ready taken place at the 12-mile site. Using that as a standard, is 

 the 12-mile site unreasonable? 



Mr. ScHATZOW. Well, I would — we have tried to refer the Con- 

 gressman to our testimony where we tried 



Mr. Hughes. Don't waltz around the maypole on me. I am asking 

 a very direct question. You know, you hesitate to classify anything 

 as reasonable or unreasonable. We argue about whether or not we 

 are going to factor in economic circumstances. I am asking you 

 from a — maybe Mr. Anderson has to answer the question. 



Mr. ScHATZOW. Maybe I can answer it somewhat differently or 

 try to. 



Mr. Hughes. Try to be direct, if you will. I don't have a lot of 

 time. 



Mr. ScHATZOW. I will try to be direct. I believe if we were ap- 

 proaching this issue fresh, in other words, if there had not been 

 dumping at the 12-mile site in the past, if there were not the other 

 contaminants' contribution to that area, and we were looking at 

 the question of does the 12-mile site meet our criteria in terms of 

 an appropriate site for the ocean dumping of municipal residues 

 and sewage sludge, the answer would be it does not. 



Mr. Hughes. That is fair enough. 



Now, does the 106-mile site represents less direct risk to the pop- 

 ulation centers alone the coast or more than the 12-mile site? 



Mr. ScHATzow. I think because of the distance from shore and 

 because of the fact that there is not a commercial fishery in the 

 area, for a variety of reasons, it represents less risk. 



Mr. Hughes. That wasn't too painful, was it? 



Thank you, Mr. Chairman. 



Mr. D' Amours. Mr. Dyson, do you have further questions? 



Mr. Dyson. My first questions, Mr. Chairman. 



How can you say less risk at the 106-mile site when you admitted 

 this morning yourself you have not even had that much opportuni- 

 ty to monitor it and I believe you did indicate to Congressman 

 Carper that is what you would do if this permit process is success- 

 ful? I understand it would mean final release in March 1984. 



Mr. ScHATZow. Well, I 



Mr. Dyson. I share the concern of my colleague from New Jersey 

 about the New York Bight, but 



Mr. ScHATZOW. We went over in some fairly great detail at 

 public hearings in Rehoboth the testimony from a number of differ- 

 ent scientists reporting both on the monitoring that had been done 

 at the 106-mile site in terms of the industrial waste dumping, as 

 well as a substantial amount of information dealing with oceano- 

 graphic processes 



Mr. Dyson. That is a case by case basis. Dumping is approved on 

 a case-by-case basis. 



Mr. ScHATZOW. That is correct. 



Mr. Dyson. Whereas the rule EPA proposed would open that to, 

 I assume, the same fashion the way the New York Bight is open? 



Mr. ScHATZOW. I am sorry you missed my testimony. Congress- 

 man, because I think it was made very clear that there are two 

 separate decisionmaking processes and any designation of the 106- 



