230 



Because of its distance from coastlines, sewage sludge dumping at the 

 106-Mile Site would not be expected to affect Federal or state recrea- 

 tional areas, beaches or any other public amenity areas (Section 2.3). 

 It is highly unlikely that any sewage sludge constituents discharged at 

 the 106-Mile Site will reach New Jersey or Long Island bathing beaches 

 (Chapter 10). Researchers also note that since sludge dumping contri- 

 butes a negligible quantity of floatables to the Bight, the relocation 

 of sewage sludge to the 106-Mile Site would not be expected to prevent 

 or lessen the severity of future beach pollution incidents (Chapter 10). 



Economics 



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

 the three proposed f-lew 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 million, $13.05 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 facili- 

 ties. The estimates are reasonably consistent with the 1980 FEIS predic- 

 tions that the cost of using the 106-Mile Site would be twice that of the 

 60-Mile Site and six to eight times the cost of the 12-Mile Site. 



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

 costs of monitoring and surveillance (Chapter 19). Since the costs of 

 monitoring and surveillance at the 106-Mile Site would be expected to be 

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

 ring sewage sludge dumping to the 106-Mile Site would be considerably 

 larger than reflected by estimated escalations in operating costs alone. 

 The major impact of any decision to transfer dumping from the 12-Mile 

 Site to a more remote location, such as the 106-Mile Site, would most 

 likely be these cost increases associated with the dumping operations, 

 monitoring, and surveillance. As noted above in the 1980 FEIS, "Use of 

 the 106-Mile Site for sewage sludge disposal would be environmentally 

 acceptable under carefully controlled conditions.. .however, substitution 

 of the 106-Mile Site for existing Shelf sites would impose severe eco- 

 nomic burdens, surveillance and monitoring difficulties, and logistics 

 problems" (EPA 1980, p. 5-24). 



2.7 SURVEILLANCE AND MONITORING 



Monitoring and surveillance of dumping activities at the 106-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 difficult (some believe impossible) and extremely costly given the 

 distance from shore, the types of vessels required, the size of the 

 dumpsite, and the depth of the water column. Furthermore, no adequate 

 site-specific and seasonal database exists against which any effects of 

 dumping might be assessed (Chapter 19). 



Surveillance at the 106-Mile Site would be extremely costly, since ade- 

 quate surveillance would necessitate the use of shipboard observers, 

 perhaps on e^sry dumping vessel. It should be noted that the 1980 FEIS 



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