85 



the 106-mile side do not reach the bottom, there would be no interference between 

 the two wastes in terms of bottom effect. 



The issue of sludge dilution and its influence on monitoring industrial waste has 

 so far been addressed without reference to PCBs. However, to argue that a million- 

 fold dilution of sewage sludge is needed to decrease PCB concentrations below the 

 former EPA water quality limit of one part per trillion (now 30 parts per trillion), 

 requires that the undiluted sludge contain about 20 parts per million PCB on a dry 

 weight basis. Published concentrations are in the 3 to 9 parts per million (dry 

 weight) range as indicated by the National Wildlife Federation during the May 

 hearing on sludge dumping. At that hearing, NOAA cited that recent sludge analy- 

 sis for New York City yielded dry weight concentrations in the 0.5 to 2.5 parts per 

 million range. Since sludge is 95 to 97 percent water the solids within it are essen- 

 tially diluted by a factor of 20 before entering the sea. If a value of 5 ppm (dry) is 

 assumed, this equates to .25 ppm (wet) which would require a dilution of 250,000-fold 

 to reduce the concentration to one part per trillion, or about 8,300-fold to get to 30 

 parts per trillion. 



If sludge was dumped at the i06-mile site, it would be the sole direct source of 

 PCBs. Industrial wastes result from processes which do not use or produce PCBs 

 (new uses or production of that compound are prohibited). Monitoring in the context 

 of sludge dumping would include determination of its large-scale (not just small- 

 scale) plume distribution, and PCBs are considered one possible chemical indicator 

 of sludge. Others include the elements iron, zinc, lead, and organic compounds, such 

 as steroids or high molecular weight polyaromatic compounds. None of these chemi- 

 cals are characteristic of the one industrial waste now routinely dumped at the site. 

 The chemical signature of this waste is due to organic solvents which are not in 

 sewage sludge. Other industrial wastes which have been dumped in the past did con- 

 tain elements which are common to sludge. However, given the projected large vol- 

 umes of sludge, an industrial waste would either have to be very concentrated or 

 dumped in exceedingly large volumes to alter the chemical content of seawater 

 beyond that due to sludge dumping. 



The EPA-NOAA monitoring program previously outlined omits the consideration 

 of industrial wastes; there is simply insufficient industrial waste dumped, and it is 

 not chemically similar enough, to affect the detection of sludge. Biological responses 

 to sludge will almost certainly not be altered by the presence of industrial waste. 

 Conceivably industrial wastes could become somewhat less toxic when dumped into 

 water containing sludge. This would occur for a waste whose toxicity is due to its 

 heavy metal content and if those metals form complexes with common organic com- 

 pounds provided by the sludge. As discussed above, small-scale monitoring of indus- 

 trial waste could proceed as in the past even if sewage sludge were dumped at the 

 106-mile site. 



Questions of Mr. Carper and Answers by NOAA 



Question. What type of monitoring program would be needed to assess the effects 

 of dumping at the 106-mile site (details, please)? 



What will be NOAA's and EPA's responsibilities under this program? 



What costs are to be anticipated in conjunction with the program described 

 above? (If an expanded MARMAP program is envisioned, what will be the addition- 

 al costs incurred to adequately monitor the 106-mile site over existing expendi- 

 tures?) 



Answer. A monitoring program to assess the effects of dumping sewage sludge at 

 the 106-mile site would be designed to measure: (1) changes in water quality down- 

 stream of the site; (2) the increased flux of settling material onto the seafloor; (3) 

 possible effects on planktonic organisms in the upper water column; and (4) possible 

 effects upon benthic organisms on the seafloor. The program will include chemical 

 analyses of seawater samples to detect the presence of sludge and the areal extent 

 of its detectability. Planktonic organisms will be collected within and outside of the 

 affected area to determine whether chemical changes induced by sludge result in 

 any measurable response. An array of sediment traps will be deployed to measure 

 the rate and areal extent of sludge particles falling to the seafloor. Benthic orga- 

 nisms will be collected within and beyond the seafloor area influenced by dumping 

 to determine whether dumping alters the community structure of the area. 



NOAA and the U.S. Environmental Protection Agency are working closely on the 

 design of a monitoring program for sludge dumping at the 106-mile site. NOAA's 

 responsibilities include the design and implementation of the oceanographic activi- 

 ties described above. EPA will perform short-term, compliance monitoring including 



