221 



Since it has been demonstrated that there is no significant microbial 

 contamination of beach waters due to sewage sludge dumping at the 12-Mile 

 Site, and since the 60-Mile Site is much further offshore, use of the 

 latter site would neither increase nor decrease human health risk via 

 this mode of impact. However, there is a possibility that shellfish 

 within the 60-Mile Site would become contaminated with microbial patho- 

 gens from sewage sludge. The 1978 FEIS concluded that: 



"The FDA will probably close areas in and near a new dump site to 

 shellfish harvesting, based on the potential for bacterial 

 contamination. Nevertheless, use of a new dump site will 

 increase the risks of human consumption of illegally harvested 

 contaminated shellfish" (EPA 1973, p. 205). 



The Agency also notes however (EPA 1978, p. 204), that even if the 

 existing 12-mile Site was abandoned, areas now closed to shell fishing 

 would not be reopened in the near future due to the predominance of other 

 sources of microbial contamination in the apex. 



Economics 



Cost estimates for ocean dumping New York City's sewage sludge at each of 

 the three proposed New York Bight dumpsites were computed using constant 

 1982 dollars. The estimated annual operating costs for dumping at the 

 12-, 60-, and 106-Mile Sites were $4.09 mill ion, $18.05 million, and 

 $26.71 million, respectively. These estimates were based upon use of the 

 City's present sludge fleet (with additional capacity required for the 

 more distant sites supplied by leased barges) and include the costs for 

 fuel, crew salaries, and the need for additional sludge storage 

 facilities. The estimates are reasonably consistent with the 1980 FEIS 

 predictions that the cost of using the 60-Mile Site would be 3-5 times 

 the cost of the 12-Mile Site. 



Both the New York City and 1980 FEIS cost estimates fail to include the 

 significant costs of monitoring and surveillance. Since the costs of 

 monitoring and surveillance at the 60-Mile Site would be expected to be 

 large compared to the 12-Mile Site, the economic impact of transferring 

 sewage sludge dumping to the 60-Mile Site would be larger than reflected 

 by estimated escalations in operating costs alone. Thus, one of the 

 major impacts of any decision to transfer dumping from the 12-Mile Site 

 to a more remote location, such as the 60-Mile Site, would most likely be 

 these cost increases associated with the dumping operations, monitoring, 

 and surveillance. 



2.7 SURVEILLANCE AND MONITORING 



Monitoring and surveillance of dumping activities at the 60-Mile Site are 

 feasible, although much more difficult than at the existing 12-Mile Site. 

 Monitoring for short- and long-term environmental effects would be diffi- 

 cult and costly given the increased distance from shore, the types of 

 vessels required, and the lack of adequate baseline data. Furthermore, 

 no adequate site-specific and seasonal database exists against which any 

 effects of dumping could be assessed. 



B-7 



