168 



Mr. Lahey. About the feasibility 



Mr. Hughes. In other words, in your testimony you suggest that 

 there is no fee schedule for the deep water site. That is essentially 

 correct. However, there is a built-in mechanism through EPA to 

 recommend to the Congress a fee schedule for the deep water site. 



Mr. Lahey. I endorse doing so. I don't mean to say it has been 

 entirely overlooked, I just mean to suggest that developing a fee 

 system for the 106 site deserves serious consideration. 



Mr. Kamlet. Let me attempt to respond to your questions, Mr. 

 Hughes. It seems to me that the risks connected with use of the 

 106-mile site increase with time as the 106-mile site continued to be 

 used. 



The short-term risks, it seems to me, whether it is residents of 

 Maryland and Delaware or residents of New York or New Jersey 

 would be less in my judgment at the 106 site than the 12-mile site. 

 The longer dumping continued at the 106-mile site the greater the 

 possiblity of risks to seafood eaters up and down the coast, in my 

 judgment, would be. 



So I endorse what Mr. Lahey says in terms of the desirability of 

 incentives to get ultimate and hopefully land-based alternatives 

 considered as expeditiously as possible. 



Mr. Hughes. Thank you. 



The gentleman from New Jersey. 



Mr. Forsythe. Thank you, Mr. Chairman. 



Thank you both for your testimony. 



Mr. Kamlet, you talked about separation of sites. The 106-mile 

 site is, I understand 636 square miles. If you were to use opposite 

 corners of the site for dumping different materials, you could get a 

 10-mile or better separation between materials there. Do you be- 

 lieve that would be adequate? 



Mr. Kamlet. I have not done the calculations. What would be re- 

 quired if you look at a conservative pollutant like PCB's to get an 

 acceptable degree of dilution so that interaction could be mini- 

 mized, would be on the order of a million-fold dilution, a million- 

 fold initial mixing of the material that was dumped. 



Whether or not one could get that at the 106 site at locations 

 that are separated by 10 miles is not clear. But there certainly are 

 numerous other sites much further separated that would be possi- 

 ble at the edge of the shelf or near the edge of the shelf within that 

 general area. 



Mr. Forsythe. I fully agree that there may be more attractive 

 sites in terms of shorter distance and so on. However, one of my 

 concerns is the question of again starting a new site designation 

 process again. That has been a very long, drawn out process to 

 date. If we want to move with dispatch, we would be probably de- 

 laying our ability to make any move toward eventual cleanup if we 

 attempt to designate new sites. 



So again we can say that even though the 106-mile site is treated 

 as interim rather than final, I don't think anything we come up 

 with will be the final solution. There are all the other ramifica- 

 tions that we have talked about. If we think that what we are able 

 to do today is going to be final, I think we are going to be kidding 

 ourselves. There are just so many things coming out in terms of 

 new data. 



