197 



EPA's 1980 Environmental Impact Statement (EIS) conclusion that "sludge 

 disposal should be allowed at the [106-Mile] Site only under the 

 following conditions: Provided the existing sewage sludge site cannot 

 safely accomodate more sludge disposal without endangering public health; 

 severely degrading the marine environment, or degrading coastal water 

 quality." We also support similar conclusions made by EPA in their 1978 

 EIS concerning use of the 60-Mile Site. 



Effect of a Ban on Disposal in the Bight Apex 



I would like to briefly discuss the probable results of banning sewage 

 sludge from the New York. Bight apex. First, since contaminant loadings 

 to the Bight are dominated by other sources which would continue even if 

 sewage sludge disposal were stopped, the benefits of removing sludge, if 

 any, would be very minor. Recurrent beach pollution episodes would not 

 be reduced in number and the potential for anoxic events would not mea- 

 surably decrease. Because sludge disposal does not affect beach water 

 quality, banning sludge disposal in the Bight apex would not improve Long 

 Island or New Jersey beach conditions. Further, it is highly unlikely 

 that the New York Bight shellfish closure would be rescinded since sewage 

 sludge contributes only two-tenths of one percent of the Bight Apex 

 coliform bacterial load and dredged material would continue to be a large 

 source of coliform bacteria to the same offshore area. Finally, the 

 sludges currently disposed at the 12-Mile Site would have to be disposed 

 in some other location or media, each of which would present its own 

 potential for environmental and human health effects. The recognition 

 of these general findings led NCAA scientists to recently recommend 

 "continued use of the existing 12-Mile dumpsite until a regional waste 

 disposal inanagement strategy can be developed." Our extensive review 

 of the technical literature fully supports this statement. 



Special Permit Application 



I would like to briefly describe several key findings of New York City's 

 comprehensive Special Permit Application, which should be completed for 

 submission to EPA this summer. I also want to point out that the 



