155 



iO-9A92 



shellfish har\'esting. In the case of the New York Bight Apex, 

 NOAA has identified a pathogenic amoeba and EPA several viral 

 strains, as discussed above, that may be associated with sewage 

 sludge. Therefore, even if fecal coliform counts in the water 

 column on occasion do comply with the criteria, this does not 

 indicate the absence of pathogens. The presence of pathogens 

 has been confirmed independently. 



e) Commissioner McArdle also notes that dissolved 

 mercury and cadsiium concentrations in the water column are below 

 the -levels set in EPA's marine water quality criteria. While 

 true, the City does not discuss the levels of other toxic 

 pollutants nor the elevated levels of mercury, cadmium or other 

 toxic pollutants in the suspended particulate phase of its 

 sewage sludges v^ich, when dumped, result in elevated levels in 

 the sediment. Recent NOAA studies indicate that dissolved 

 cadmium levels (0.1-7.0 micrograms/1) in the Bight Apex are 

 considerably higher than in non- contaminated areas (4-7 

 nanograms/1), and that levels in sediments in and adjacent to the 

 sludge dumpsite range from 5-25 mg/kg (dry wgt.). Once in the 

 sediments , elevated levels of toxic pollutants are available for 

 bioaccumulation, bioconcentration, and biomagnifi cation in the 

 food chain of marine organisms and man. Marine water quality 

 criteria set levels for pollutants only in the water column, not 

 in bottom sediments. As noted above, NOAA studies show elevated 

 concentrations of cadmium in fish and shellfish, with some 

 already exceeding the 0.5 mg/kg level considered safe for human 

 consumption and marine health. 



(f) With respect to evidence suggesting the con- 

 tribution of sewage sludge dumping tc fin-rot and other 

 sub- lethal effects, Dr. Swanson's testimony (E;c. A, pp. lA-17) 



