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(4) I understand that when considering heavy metal 

 constituents. New York's sludge may be "cleaner" than the 

 sludge from New Jersey Municipalities; and conversely, with 

 regard to some constituents. New York's sludge is the 

 "dirtier." Could you comment more specifically on the 

 difference in "sludge quality"? 



We have completed a very thorough analysis of the constituents 

 that make up New York City's sludge as part of the work done in 

 preparing both our Special Permit application and our comments 

 in support of Designation of all three ocean disposal sites. 

 This information has been and will continue to be submitted to 

 U.S. EPA for their review. We believe that the New Jersey 

 sewage authorities are doing likewise. Any comparisons between 

 -our sludge and theirs should be done by the regulatory agencies 

 concerned. 



(5) With regard to PCB's, the consultant's report on site 

 designation appears to contradict figures which were previously 

 given to the Merchant Marine and Fisheries Committee by NOAA 

 scientists regarding the percentage of PCB contamination which 

 ocean dumping adds to the New York Bight. Could you explain the 

 methodology which NY used in reaching these substantially lower 

 figures? Are New York's sludges lower in PCB levels than 

 similar sludges from New Jersey municipalities? 



The City's consultant estimates that sewage sludge dumping at 

 the 12-Mile Site currently contributes approximately 3 percent 

 of the total PCB input to the New York Bight apex. The two 

 major sources of PCBs are the Hudson-Raritan Estuary discharge 

 and dredged material dumping. 



In preparing their report of March 9, 1983 on site designation, 

 the City's consultant reviewed the information provided to the 



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