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ATTACHMENT III 

 Questions for NOAA and EPA 



1. Assuming it is desirable to require any sewage sludge which 



is ocean-dumped to be dumped in deepwater, at a site further offshore 

 than the current 12-Mile Site, would you agree — as EPA noted in 

 a December 20, 1982 Federal Register notice--that such a shift in 

 dumping location should occur under conditions that permit "further 

 studies of the site and careful monitoring of the impacts of 

 disposal at the site"? 



2. Would you also agree that one of the important conditions on 

 which the ability to meet study and monitoring objectives may depend 

 is the distance separating sewage sludge and industrial waste 

 dumping activities, the opportunities for initial mixing with 

 seawater before commingling of the affected water masses occurs, 

 and generally the potential for interaction of the different wastes? 



3. The National Wildlife Federation, at the May 25th hearing, 

 stated that, to get an acceptable degree of dilution of a conservative 

 sewage sludge contaminant like PCBs so that interaction could be 

 minimized would require an initial dilution on the order of a 

 million-fold. This is based, presumably, on the assumed presence 



of PCBs in sludge at the part-per-million level, and on an assumed 

 acceptable water quality requirement of ambient marine water column 

 PCB levels in the part-per-trillion range. Do you agree with NWF ' s 

 estimate of the degree of initial dilution required to ensure 

 sufficient separation of nearby dumping activities? If not, 

 please provide your own best estimate, and indicate the basis for 

 this estimate. 



4. The suggestion was made at the May 25th hearing that the 

 106-Mile Deepwater industrial waste dumpsite is sufficiently large 

 that a large separation between industrial wastes and sewage sludge 

 could be achieved within the boundaries of this site (e.g., by 

 requiring the two types of wastes to be dumped at opposite corners 

 of the site) . Please provide your best estimates for the maximum 



and minimum (i.e., worst-case) initial dilutions (i.e., within 1 hour) 

 that could be anticipated in the course of a year (or longer) for 

 wastes dumped at various locations within the 106-Mile Site. How 

 confident can we really be that sludge containing 1 ppm of PCBs, 

 if dumped in one quadrant of the 106-Site will undergo a millionfold 

 (or other required degree of) dilution within an hour, or before 

 impinging on other quadrants of the dumpsite? 



5. At least 2 or 3 other deepwater ocean dumpsites located to 

 the north of the 106-Mile Site have been historically used for 

 explosives and/or chemical wastes (see attachments) . As you know, 

 the 106-Mile Site is itself a former explosives dumping site. For 

 each of the indicated alternative sites, please indicate if there 



is any basis for believing, by virtue of prevailing current patterns 

 or the distribution of fishery or other biotic resources, that that 

 site would be a less suitable repository for ocean-dumped sewage 



