136 



It is not known what the ultimate fate is of the lost 300.000 cubic yards. 



This finding confirms that of the 1987 field study :t \ that a combination of 

 poor disposal practices and transport off-site caused by high energy currents 

 results in substantial amounts of dredged material not being deposited within the 

 boundaries of the Mud Dump Site. 



e. Summary 



The results of limited monitoring efforts indicate that the Mud Dump Site 

 is more contaminated compared to the rest of the New York Bight Apex. 

 Although biomonitoring of higher trophic species is extremely limited, it does 

 signal that the Mud Dump Site needs to be carefully studied to understand the 

 extent to which it is responsible for contributing towards elevated levels of 

 contaminants in fish and shellfish species. Additionally, biomonitoring needs to 

 be stepped up to help evaluate and understand the degree to which toxic 

 pollutants are impairing marine species and potentially causing a threat to public 

 health. 



It seems apparent that the management of the Mud Dump Site has not 

 been successful. The combination of poor disposal practices and transport of 

 dredged material appear to have resulted in rendering the Mud Dump Site 

 boundaries meaningless. Capping cannot withstand storm events that can easily 

 breach the cap or carry cap material away. This is especially true as the United 

 States is entering into a new 25-year cycle of super-hurricanes and emerging from 

 a "quiet" 25-year hurricane cycle. The impact of storms needs to be reevaluted 

 in light of their potential to disturb sites and spread contaminated sediments, thus 

 rendering caps ineffective in isolating material. Capping appears to be less 

 effective in isolating PCBs than metals: what does this say about its ability to 

 contain dioxin?. And. the physical monitoring of the EMD cap, and the Mud 

 Dump Site altogether, do not appear to have directly affected management 

 decisions. 



The combination of all of these factors and pieces of information has led 

 the Environmental Defense Fund, and possibly others, to petition the EPA to re- 

 evaluate the impact of disposal of dredged material at the Mud Dump Site and to 

 place the site in Impact Category I. This would require EPA to place certain 

 limitations on dumping activities to reduce the impacts to acceptable levels. 

 These factors also confirm skepticism that this permit should be reinstated. 



See footnote 17 



12 



