167 



a relatively simple variable fee system without having to incorpo- 

 rate a number of different parameters. 



Mr. Hughes. Thank you. 



Mr. Kamlet, thank you for your testimony and your support of a 

 number of the features of the staff draft. One of the things that 

 you recommended is that any deep water site be separate and 

 apart from any chemical dump site. 



Mr. Kamlet. Right. 



Mr. Hughes. My question is, Did you have some area in mind 

 that you recommended? Your concern, I presume, is that you 

 would not want to mix the sludge and the chemicals at one dump 

 site. You would have no opposition I presume to having another 

 106-mile site or 104-mile site, it is just that you don't want to mix 

 the two? 



Mr. Kamlet. Yes, that is basically correct. I wouldn't say that I 

 would have no concern. It obviously goes against the grain for me 

 to support any sort of ocean dumping site for harmful sludges. We 

 don't have a particular alternative site in mind but I might point 

 out that there happens to be an historical explosives dumping site 

 which is what the 106-mile site at one time was, located in rather 

 similar deep water approximately the same distance from shore 

 that is somewhat closer to New York and New Jersey, and main- 

 tains the geographic relationships of the 12-mile site and is some- 

 what further removed from Maryland and Delaware. 



It might be a way to meld the concerns of the members of the 

 committee from Maryland and Delaware with those of the New 

 Jersey members. I think the key considerations ought to be poten- 

 tial for impacts on fisheries resources and the extent to which the 

 separation between any new site and the existing sites are suffi- 

 cient to avoid interaction of wastes from one site with waste at an- 

 other site. 



Mr. Hughes. So it is the separation you are concerned about. 



Mr. Kamlet. That is correct. 



Mr. Hughes. On the subject of the concern of Maryland and 

 Delaware in particular, do either one of you want to comment on 

 the potential risk that is faced by Delaware or Maryland if we con- 

 tinue with the 12-mile site as opposed to a deep water dump site? 

 There is concern obviously in both those states that they face more 

 of a threat from moving to a deep water site. 



Do you have any views on that? 



Mr. Lahey. Mr. Chairman, my concern is that in designating the 

 deep water site for dumping we are impliedly assuming that the 

 site is suitable for extensive, long term-dumping. Such a designa- 

 tion would not create any built-in incentives for cities to search for 

 alternative disposal areas. I think Mr. Kamlet and I agree that safe 

 and feasible land-based alternatives are available or can be made 

 available through research and development. Allowing the 106 site 

 to be used without incentives to look for these land-based alterna- 

 tives seems to be unwise. 



Mr. Hughes. How about where incentive is provided by a fee 

 system or some other system which suggests that we are talking 

 about an interim dump site until we are able to develop land-based 

 alternatives. 



Do you have the same feeling with that? 



