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To summarize the Report's number one choice for deep ocean dumping: 



A barge would sail from a major metropolitan area, loaded with 55 million tons 

 of waste. It would sail anywhere from 276 to 2300 miles offshore. It would 

 dump 50 bags containing a total of 55 million pounds of waste into the ocean. 

 The bags would sink through more than 3 1/2 miles of water. The dumpsite area 

 on the ocean floor would be the size of nearly 100 football fields. If only 

 dredged sediments are dumped ~ as opposed to sewage sludge and incinerator 

 ash, as also proposed by the report - 44 trillion pounds ofsedimems would be 

 dumped in the ocean annually. 



The top ten reasons why this proposal is fiill of flaws are: 



1. It would be illegal under U.S. and international law to dump the wastes 

 proposed by the Report. 



2. It would be illegal under U.S. law to transport the wastes through U.S. waters 

 for the purposes of dumping. Therefore, you could neither transport nor dump 

 the wastes discussed by the Report. 



3. Transportation hazards would be enormous. Distances of hundreds or 

 thousands of miles would be covered by a ship loaded with 55 million pounds of 

 waste. What happens in the event of a storm, or leak, or spill? 



4. The deep ocean is extraordinarily vibrant and filled with life, much of it with 

 great commercial potential. In addition, the ocean is traversed by marine 

 mammals, all of which are endangered or threatened species. Vitally important 

 fisheries use the ocean and depend on clean water for survival. It would be 

 extremely difficult to monitor the impact on migratory marine mammals and 

 fisheries from exposure to the wastes. However, common sense dictates that 

 dumping 44 trillion pounds of waste in the ocean would make an impact on its 

 biological integrity. 



5. A dumpsite on the ocean floor the size of 100 football fields is the equivalent 

 of firebombing the ocean floor. 



6. U.S. waste policy has developed more of an emphasis on monitoring disposal 

 facilities to ensure that wastes are not moving offsite. Monitoring the movement 

 of hundreds of bags on the ocean floor 3 1/2 miles below the water surface would 

 be extremely difficult if not impossible. 



7. Ocean floor dumping would make waste retrieval for treatment nearly 

 impossible, dooming the ocean floor to be a landfill forever. 



8. If the bags decayed or split open, cleaning up the resulting hazardous waste 

 area would be impossible. In addition, the bags of waste would be dumped 

 through extremely deep water. The only experience to date with dumping 

 geotextile bags filled with waste has been in water less than 300 feet deep. This 

 Report proposes dumping in water 20,000 feet deep. 



9. There is no practical experience with the bags proposed to hold 1 million 



