196 



data, the mercury and cadmium loadings to the Bight apex from sewagt 

 sludge have been reduced in 1981 by 65 percent and 44 percent, 

 respectively. 



. Numerous federal, state, and academic research studies have 

 shown that sewage sludge did not cause the 1976 anoxic event nor any of 

 the beach pollution episodes. 



. Sewage sludge does not build-up on the seafloor and no sludge 

 monster is moving towards Long Island. In fact, both NOAA and EPA have 

 concluded that continued use of the 12-Mile Site is not a threat either 

 to public health or water quality along the Long Island and New Jersey 

 beaches. 



The NOAA Microconstituents Program data indicate that 

 concentrations of metals in fish and shellfish from the Bight apex 

 are generally not higher than concentrations in biota from other North 

 Atlantic areas. The most recent data indicate that PCB contamination 

 is predominantly from the Hudson River and the Hudson-Raritan Estuary, 

 not from the ocean disposal of sewage sludge. 



The contamination of beach waters is not caused by sewage 

 sludge disposal. Discharges located at the shoreline release 500 times 

 more coliform bacteria than does sewage sludge which is disposed 10 miles 

 from any beach area. 



Sludge vessels are not a navigational hazard. In fact the 



Captain of the Port of New York recently stated that disposal activities 

 could double without causing traffic problems. 



Based on the overall technical assessment, the 12-, 60-, and 106-Mile 

 Sites comply with EPA' s site designation criteria and should be desig- 

 nated for the disposal of those sludges that qualify to receive special 

 permits. However, we feel strongly that any sludges that are transferred 

 to the 60- or 106-Mile Sites should be phased in slowly to allow for ade- 

 quate monitoring of environmental effects. We also support the U.S. 



