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because of the lack of a suitable dumping site. After one failed attempt to 

 designate a site first in the Bay and then a few miles off shore, the process of 

 selecting a site has now focused upon open ocean waters just outside the newly 

 designated Monterey Bay Sanctuary. In the meantime, another dredging project at 

 two navy sites near Oakland has been proposed and an application to use an old 

 military dump site within the boundaries of the proposed new dump site is being 

 considered. Despite the fact that the Navy bases in question are proposed for 

 closure, the project is being portrayed as urgently needed as a matter of national 

 security, and as a basis to justify dumping at the site before the formal 

 designation is approved. 



iii. Thames River and Long Island Sound 



The Navy plans to dredge 2.7 million cubic yards of sediment from an X- 

 mile stretch of the Thames River in order to accomodate the needs of the 

 SEA WOLF submarine. The material is proposed to be dumped 2.5 miles due 

 south of the mouth of the Thames River in Long Island Sound. The project is 

 adjacent to several hazardous waste sites of the Groton Naval Base, all of which 

 are Superfund sites. This project is still in the evaluative stages as a 

 Supplemental EIS is being prepared by the Navy. 



2. Port Authority of New York-New Jersey permit 



There are a host of problems with the Port Authority's permit to dredge 

 and ocean dispose sediments from Newark Bay that are of grave concern. First, 

 it is a precedent-setting permit because it will be the first time that 2,3,7,8- 

 TCDD (dioxin) will be expressly regulated in dredged materials. Secondly, 

 serious procedural mistakes were made in processing the permit through public 

 review. Thirdly, the existing dioxin contamination condition of the Mud Dump 

 Site and the New York-New Jersey Harbor were never factored into the decision 

 about the appropriateness of dumping additional dioxin-contaminated sediments at 

 the Mud Dump Site. Fourth, we disagree with a variety of decisions made by 

 the Corps and EPA that impact this permit. Fifth, the entire decision-making 

 process was made in a void left by the U.S. EPA's failure to establish yet a 

 national dioxin policy. Lastly, the recent bathymetric surveys show that a 

 substantial amount of dredged material was lost due to the December Northeaster, 

 indicating that the Mud Dump Site should be evaluated by EPA to determine if it 

 fits "Category I" criteria for impacted site and that "containing" dioxin- 

 contaminated sediments at an open ocean site has a good chance of not being 

 successful and cannot be guaranteed. For these reasons and reasons stated below. 

 we have objected to this permit as presently issued. 



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