led 



231 



assumes that surveillance would be conducted ultimately through the use 

 of the Coast Guard's Ocean Dumping Surveillance System (ODSS) which was 

 under development at that time. Development of the ODSS has since been 

 abandoned and, therefore, shipboard observers are the only adequate means 

 of surveillance currently available (Chapter 19). 



Based on this extensive technical update of the 1980 FEIS, it is apparent 

 that the dumping of municipal sewage sludges at the 106-Mile Site would 

 not be expected to result in unreasonable or irreversible degradation of 

 the marine environment. The recent studies provide additional support to 

 the Agency's 1980 FEIS final conclusions that, although use of the site 

 for sewage sludge disposal is feasible and environmentally acceptable, 

 disposal of sludges currently dumped at the 12-Mile Site should not be 

 transferred to the 105-Mile Site until, and unless, it is shown that the 

 12-Mile Site cannot safely accommodate more sludge disposal without 

 endangering public health, severely degrading the marine environment, 

 or degrading coastal water quality. Further, in the absence of detai, 

 studies of continuous sewage sludge dumping at the 106-Mile Site or a 

 similar site, any dumping of sewage sludge at the 106-Mile Site should 

 be phased in gradually and accompanied by adequate monitoring. In order 

 to properly implement such a phase-in, the 106-Mile Site should be desig- 

 nated for authorized sewage dumping without the proposed five-year time 

 limit. However, the site should be managed according to the existing 

 regulations (40 CFR 228.10 and 40 CFR 228.11) which would ensure closure 

 of the Site only if a periodic evaluation of disposal impact indicated a 

 closure was necessary. Such evaluations should be performed on a con- 

 tinuing basis throughout the phase-in of any sewage sludge dumping. 



In conclusion, the 106-Mile Site should be formally designated for the 

 ocean disposal of municipal sewage sludges which qualify to receive a 

 special permit. However, the designation should not be limited to five 

 years, and any use of the site for sewage sludge should be phased in over 

 a period of years with adequate monitoring. 



Mayor Koch. May I have the commissioner make a comment. 



Mr. McGouGH. From hearing the different witnesses this morn- 

 ing and this afternoon, I think one of the things that seems to be of 

 concern is what benefit would there be to move from the 12-mile 

 site? I think that our findings demonstrate that the benefit, al- 

 though there might be some, would be slight. We believe that on 

 the basis of the technical data we have submitted to the members 

 and to the committee, this is demonstrated and would be further 

 demonstrated as the regulatory process goes forward. 



Thank you. 



Mayor Koch. Just so there won't be any inhibition about my 

 time, I will make the next plane. So not to worry about that. 



Mr. D' Amours. We appreciate that very much, Ed. 



I would like to begin by asking, relative to the stated total cost of 

 using the 106-mile site as opposed to the 12-mile site, you project a 

 total cost increase of $26.7 million annually. 



This subcommittee has requested information from one of the 

 larger marine transportation firms engaged in this type of oper- 

 ation, the A&S Transportation Co. of Somerset County, N.J. They 

 submitted a letter to the committee estimating the cost to barging 

 sludge to the 106-mile site to be in the range of $3.5 to $5 per wet 

 ton. That lower estimate, $3.5 per wet ton, is based on a contract 

 running 5 to 7 years; the higher estimate being based on a 1-year 

 contract. 



