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2.10 CESSATION OF DUMPING 



The foregoing summary of information concerning the effects of dumping 

 sewage sludge at the 12-Mile Site leads to two basic conclusions: 



. The impacts of sewage sludge dumping at the 12-Mile Site ars 

 minimal. Further, those changes or anomalies, which have been 

 observed in the New York Bight apex and which are interpreted as 

 indications of "degradation", are all either natural occurrences 

 or are known with a high degree of scientific certainty to be 

 caused predominantly by contaminant inputs other than from sewage 

 sludge. Sewage sludge is at most only a very minor contributor to 

 some of the observed or hypothesized problems. 



If sewage sludge dumping were halted at the 12-Mile Site, there 

 would be no significant, and probably no measurable, improvement 

 in either the environment of the New York Bight or the degree of 

 protection from health risks afforded the human population. This 

 conclusion has been reached by EPA in the 1978 FEIS and by the 

 National Oceanic and Atmospheric Administration (NOAA) in various 

 publications, including testimony at Congressional hearings. 



These conclusions would require reexamination if the quantity of sludge 

 that was disposed at the 12-Mile Site were to be substantially increased. 

 It is noteworthy that, in the 1978 FEIS (EPA 1978), EPA estimated that 

 the volumes of sewage sludge dumped annually at the 12-Mile Site would 

 rise from 4.12 million cubic meters in 1973 to an estimated 9.90 million 

 cubic meters in 1981, an increase of about 140 percent of the 1973 vol- 

 ume. The actual 1981 volume dumped was 6.07 million cubic meters, an 

 increase of less than 50 percent of the 1973 volume, or only one third 

 of the increase projected by EPA (Chapter 5). Even this 50 percent 

 increase in volume was apparently related to wastewater treatment 

 improvements such as the implementation of secondary treatment. 



The weight of "total sewage sludge solids" dumped annually increased 

 only about 5 percent between 1973 and 1981 (Section 6.7). Since "total 

 solids" as measured contain all the contaminants, then corrected for the 

 increase in water dumped, there has been only a 5 percent increase in 

 sewage sludge dumping between 1973 and 1981 (Section 6.7). In terms of 

 the annual quantity of specific contaminants contained in ocean dumped 

 sewage sludge, only "oil and grease" and copper appear to have increased 

 between 1973 and 1981. In contrast, for a number of other contaminants, 

 including cadmium, chromium and mercury, the total quantity dumped 

 annually in sewage sludge decreased over this period (Section 6.8). 



Virtually all secondary treatment facilities of the sewage sludge ocean 

 dumping permittees, with the exception of the North River and Red Hook 

 plants of New York City, are now in operation, and the population and 

 industry of the New York region are stable and not increasing rapidly. 

 Therefore, no major further increases in sludge quantities are antici- 

 pated until these two plants come cn-line. Under a 30 December 1982 

 consent decree between New York City and the U.S. EPA, advanced prelim- 

 inary treatment will begin at the North River plant by August 1986 and 

 at the Red Hook plant by August 1987, and secondary treatment will be 



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