154 



PP:ee 



10-9A92 



c) The City's statement that the sludge diuap site is 

 not a ''dead sea" is correct. I disagree, however, with the ■ 

 implication that there is a normal population in the area. As 

 Dr. Swanson pointed out, the benthic community is far from 

 normal. (£x. A, p. 8-10). Dr. Swanson stated that studies have 

 "found an extremely depauperate macrobenthic community in muddy 



sediments near the sewage sludge and dredged material disposal 



2 

 sites. This most impacted zone typically exists in a 10-15 km 



area just west of the sewage sludge disposal site on the margin 



of the [ Chris tiaensen] basin. The area supports few 



macrobenthic species and is characterized by dense populations 



of the otherwise rare polychaete, Capitella canitata . Most of 



the Chris tiaensen Basin beyond this zone is populated by a very 



dense but atypical community of animals characteristic of muddy 



fine sands and 'enriched' sediments... Coupled with this is the 



absence of several important macrobenthic species, particularly 



amphipods , which normally occur in topographic lows of the 



middle Atlantic continental shelf." (Id., p. 8). 



d) Vith respect to fecal coliform counts in the 

 water column, up to 1,300 MF/lOOml have been measured by EPA 

 near the dump site. FDA is reported to have measured 2. A 

 million MPN/lOOml behind a discharging barge. Both of these 

 values exceed the marine water quality criterion, when evaluated 

 individually. Moreover, the City's statement only applies to 

 fecal coliform in the water column. Fecal coliforms are also 

 found in bottom sediments associated with sewage sludge. These 

 sediments provide nutrients for bacteria to grow on. Fecal 

 coliform counts in sediments at and near the site have been 

 measured as as high as 7,900 MF/lOOg. It should also be 

 pointed out that fecal coliforms are used as an indicator 

 organism to determine the safety of water for swimming and 



