81 



on average, but their distance from shore prevents their having an effect on coastal 

 water quality. 



NOAA's recommendation to use the 106-mile site, rather than the current 12-mile 

 site, is based solely on improving environmental conditions in the New York Bight 

 Apex. Although sludge dumped at the 12-mile site could theoretically affect areas 

 off southern New Jersey and further south, no evidence exists that it has. The prob- 

 ability of effects on these areas resulting from use of the 106-mile site is even more 

 remote. 



Question 2. Assuming it is desirable to require any sewage sludge which is ocean- 

 dumped to be dumped in deepwater, at a site further offshore than the current 12- 

 mile site, would you agree — as EPA noted in a December 20, 1982 Federal Register 

 notice — that such a shift in dumping location should occur under conditions that 

 permit "further studies of the site and careful monitoring of the impacts of disposal 

 at the site"? 



Answer. We agree that dumping of sewage sludge at the 106-mile site should 

 occur under conditions that permit appropriate monitoring. The monitoring pro- 

 gram being developed by NOAA and EPA — as provided in response to a similar 

 question from Congressman Carper — includes the following: 



The monitoring program to assess the effects of dumping sewage sludge at the 

 106-mile site will measure: (1) changes in water quality downstream of the site; (2) 

 the increased flux of settling material onto the seafloor; (3) possible effects on plank- 

 tonic organisms in the upper water column; and (4) possible effects upon benthic or- 

 ganisms on the seafloor. The program wv\\ include chemical analyses of seawater 

 samples to detect the presence of sludge and the area extent of its detectability. 

 Planktonic organisms will be collected within and outside of the affected area to de- 

 termine whether chemical changes induced by sludge result in any measurable re- 

 sponse. An array of sediment traps will be deployed to measure the rate and a real 

 extent of sludge particles falling to the seafloor. Benthic organisms will be collected 

 within and beyond the seafloor area influenced by dumping to determine whether 

 dumping alters the community structure of the area. 



NOAA's responsibilities include the design and implementation of the oceano- 

 graphic activities described above. EPA will require short-term compliance monitor- 

 ing including periodic analysis of the quantity and quality of the sludges dumped 

 and the physical fate of the sludge up to four hours of its disposal. 



A first estimate of annual costs for the oceanographic monitoring described above, 

 based on roughly 30 days of ship time throughout the year and support for senior 

 investigators and their staffs for water chemistry, planktonic biology, fish tissue 

 analysis, sediment trap work, and benthic biology, is about $750,000. 



Regional fisheries resource surveys carried out under the Marine Resources Moni- 

 toring, Assessment, and Prediction (MARMAP) program of the National Marine 

 Fisheries Service (NMFS) and regional environmental quality monitoring programs, 

 such as the Northeast Monitoring Program (NEMP) of NMFS and the National 

 Ocean Service, could provide information useful for assessing the large-scale, long- 

 term effects on fisheries productivity in the Northwest Atlantic from ocean dump- 

 ing at the 106-mile site. These existing programs could be modified to include addi- 

 tional work at the 106-mile site. However, ocean dumping even 7 million tons of 

 sewage sludge at the 106-mile site is a small-scale event relative to the dynamics of 

 fish populations. The effects of ocean dumping would be more apparent in the types 

 of measurements detailed above, rather than from large-scale monitoring and as- 

 sessment programs like MARMAP and NEMP. 



Question 3. Would you also agree that some important conditions upon which the 

 ability to meet study and monitoring objectives may depend is the distance separat- 

 ing sewage sludge and industrial waste dumping activities, the opportunities for ini- 

 tial mixing with seawater before commingling of the affected water masses occurs, 

 and generally the potential for interaction of the different wastes? 



Answer. Given the relative volumes of industrial and sewage wastes and their dif- 

 ferent chemical characteristics, the sewage sludge monitoring program should be 

 unaffected by simultaneous industrial and sewage sludge dumping at the 106-mile 

 site. 



Question 4- The National Wildlife Federation, at the May 25th hearing, stated 

 that, to get an acceptable degree of dilution of a conservative sewage sludge con- 

 taminant like PCBs so that interaction could be minimized would require an initial 

 dilution on the order of a million-fold. This is sludge at the part-per-million level, 

 and on an assumed acceptable water quality requirement of ambient marine water 

 column PCB levels in the part-per-trillion range. Do you agree with NWF's estimate 

 of the degree of initial dilution required to ensure sufficient separation of nearby 



