173 



though partial) action immediately (to be implemented within 3 years). The history 

 of ocean dumping in the Bight is largely one of foot-dragging and delay and of con- 

 fused and changing signals being given to the dumpers. A firm and unambiguous 

 directive is much to be desired. 



(2) Preparation of a Multi-Media Assessment: We have no objection in principle to 

 requiring the preparation of a multi-media assessment of the sort New Jersey DEP 

 proposes. However, for the exercise to be useful and not simply a delaying tactic or 

 a means of perpetuating cheap but unsound current practices, two important quali- 

 fications must be incorporated into any assessment plan. First, completion of the 

 assessment must not be a pre-requisite to the taking of at least initial remedial 

 measures. The 3-year phase-out of the 12-Mile Site should occur simultaneous and in 

 parallel with conduct of the assessment. Although, ideally, the assessment should be 

 carried out on a clean slate and consider the full-range of options, this must be 

 weighed against the countervailing need to minimize the damage caused by continu- 

 ation of the status quo (and the benefits of rehabilitating the Bight Apex). Second, 

 the multi-media assessment should be confined to an assessment of the comparative 

 environmental and health implications of the various sludge use and disposal op- 

 tions. It should not attempt to weigh economic costs against environmental benefits. 

 This seems consistent with New Jersey's proposal of an assessment "to determine 

 the most environmentally acceptable disposal method." 



(3) Imposition of User-Fees: We basically support this proposal, which is quite simi- 

 lar to the corresponding provision of the Hughes-Fors3i;he approach, except that we 

 do not agree that the fee should be based on merely "a portion" of the cost differen- 

 tial between use of the 12-Mile and 106-Mile Sites. By the end of the 3-year period 

 specified in the Hughes-Forsjrthe proposal, the fee should at least equal the full cost 

 differential. 



(4) Promulgation of Interim Sludge Quality Standards: We agree that sludge qual- 

 ity standards should be established, but do not believe that aggressive pursuit of in- 

 dustrial pretreatment and other opportunities to improve sludge quality should be 

 delayed until such standards have been established. 



(5) Development of Categorical Industrial Pretreatment Standards: We agree that 

 this process should be completed as expeditiously as possible, but do not believe that 

 aggressive industrial pretreatment can or should await finalization of these stand- 

 ards — especially where lack of pretreatment results in contamination of sewage 

 sludge and interferes with the ability to appropriately use or dispose of the sludge 

 in an environmentally sound fashion. 



(6) Development of Ambient Air Quality Standards for Heavy Metals and Toxic Or- 

 ganics: We agree with this objective, but do not believe that aggressive industrial 

 pretreatment, or approval of state-of-the-art thermal reduction technologies, should 

 await finalization of such standards. 



Mr. FoRSYTHE. Thank you, Mr. Chairman. 



Mr. Hughes. Thank you. 



Just one additional question. What in your judgment would be 

 the impact on the water quality in the New York Bight Apex if we 

 discontinued dumping in the 12-mile site? 



Mr. Kamlet. Without any restoration plan covering the bight 

 apex as a whole? If we just removed the sludge? 



Mr. Hughes. Just remove the sludge. 



Mr. Kamlet. I think the most dramatic effect would be on 

 making it possible to reopen shellfish beds, in a portion of the apex 

 at least, most proximate to the 12-mile site. 



The closure of the shellfish areas is related primarily to micro- 

 biological contamination for which sewage sludge is the principal 

 source in that part of the apex. I think one would also expect to see 

 measurable and probably significant reductions in other contami- 

 nants that are associated with sludge but obviously it requires for 

 most of those others a bight apex-wide restoration plan to really re- 

 habilitate the area and clean it up. 



Mr. Hughes. Mr. Lahey, do you have any comments? 



Mr. Lahey. I am not in a position to comment. I don't have tech- 

 nical expertise on that matter. 



