FINAL
ENVIRONMENTAL IMPACT STATEMENT (EIS)
for
106-MILE OCEAN WASTE
DISPOSAL SITE DESIGNATION
December 1979
75'
73'
72'
41'
40'
1. New York Bight Acid
Wastes Dispoal Site
2. Northern Area
3. Southern Area
4. Delaware Bay Acid
Waste Disposal Site
5. 106-Mile Ocean
Waste Disposal Site
MfW IERSEV
40'
75'
74'
72"
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Oil and Special Materials Control Division
Marine Protection Branch
Washington, D.C. 20460
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FINAL
ENVIRONMENTAL IMPACT STATEMENT (EIS)
for
106-MILE OCEAN WASTE
DISPOSAL SITE DESIGNATION
December 1979
&EPA
Prepared Under Contract 68-01-4610
T. A. Wastler, Project Officer
for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Oil and Special Materials Control Division
Marine Protection Branch
Washington, D.C. 20460
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ENVIRONMENTAL PROTECTION AGENCY
FINAL
ENVIRONMENTAL IMPACT STATEMENT ON
THE 106-MILE OCEAN WASTE DISPOSAL
SITE DESIGNATION
Prepared by: U.S. Environmental Protection Agency
Oil and Special Materials Control Division
Marine Protection Branch
Washington, D.C. 20460
Approved by:
T. A. Wastler Date
Project Officer
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SUMMARY SHEET
ENVIRONMENTAL IMPACT STATEMENT
FOR
106-MILE OCEAN WASTE DISPOSAL SITE DESIGNATION
( ) Draft
(X) Final
( ) Supplement to Draft
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER PROGRAM OPERATIONS
MARINE PROTECTION BRANCH
1. Type of Action
(X) Administrative/Regulatory action
( ) Legislative action
2. Brief description of background of action and its purpose indicating what
States (and counties) are particularly affected.
The proposed action is the designation of the 106-Mile Ocean Waste
Disposal Site for continuing use. The site is approximately 130 nmi
(240 km) east of Cape Henlopen, New Jersey, and is primarily used by
industries in the New York-New Jersey-Delaware area. The purpose of the
action is to provide an environmentally acceptable area for the disposal
of wastes which (1) comply with EPA's rigid marine environmental impact
criteria, or (2) must be ocean-disposed until a suitable land-based
disposal method is available.
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3. Summary of major beneficial and adverse environmental and other impacts.
The 106-Mile Site has been used for ocean disposal since 1961. Since
that time, it has received a wide variety of waste materials with no
apparent long-term adverse impact. Short-term impacts of current dumping
are known to occur - primarily on the plankton in the barge wake. Other
impacts are still subjects of research studies underway at the site.
EPA's site management policies mitigate adverse impacts by regulating
amounts and kinds of wastes, and discharge frequencies and rates. None
of the environmental impacts of waste disposal at the 106-Mile Site is
known to cause irreversible damage to the site environment.
4. Major alternatives considered.
The alternatives considered in this EIS are (1) no action, which would
require the use of land-based methods or the shutdown of the waste
producing manufacturing processes, and (2) use of another ocean site for
these wastes - the New York Bight Acid Wastes Site, the Delaware Bay Acid
Waste Site, or the Northern and Southern Areas near the Hudson Canyon.
5. Comments have been requested from the following:
Federal Agencies and Offices
Council on Environmental Quality
Department of Commerce
National Oceanic and Atmospheric Administration
Maritime Administration
Department of Defense
Army Corps of Engineers
Office of the Oceanographer of the Navy
Department of the Air Force
Department of Health, Education, and Welfare
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Department of the Interior
Fish and Wildlife Service
Bureau of Outdoor Recreation
Bureau of Land Management
Geological Survey
Department of Transportation
Coast Guard
National Aeronautics and Space Administration
Water Resources Council
National Science Foundation
States and Municipalities
Connecticut, Delaware, Maryland, Massachusetts, New Jersey, New York,
Pennsylvania, Rhode Island, Virginia
New York City, N.Y.; Camden, N.J.; Office of the Public Advocate,
Trenton, N.J.; Philadelphia, Pa.
Private Organizations
National Wildlife Federation
American Eagle Foundation
Sierra Club
Environmental Defense Fund, Inc.
Resources for the Future
Water Pollution Control Federation
National Academy of Sciences
American Littoral Society
Center for Law and Social Policy
American Chemical Society
Manufacturing Chemists Association
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Academic/Research Institutions
Lamont-Doherty Geological Observatory
University of Rhode Island
Woods Hole Oceanographic Institute
University of Delaware
New York State University
Rutgers University
6. The draft statement was officially filed with the Director, Office of
Environmental Review, EPA, on or about June 22, 1979.
7. The 45-day review period for comments on the Draft EIS began on June 29,
1979.
Comments on the Final EIS should be addressed to:
Mr. T.A. Wastler
Chief, Marine Protection Branch (WH-548)
Environmental Protection Agency
Washington, D.C. 20460
Copies of the Final EIS may be obtained from:
Environmental Protection Agency
Marine Protection Branch (WH-548)
Washington, D.C. 20460
Environmental Protection Agency
Region II
Surveillance and Analysis Division
Edison, N.J. 08817
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The final statement may be reviewed at the following locations:
Environmental Protection Agency
Library
401 M Street, SW
Washington, D.C.
Environmental Protection Agency
Region II
Library, Room 1002
26 Federal Plaza
New York, N.Y.
Environmental Protection Agency
Region II
Woodbridge Ave.
GSA Raritan Depot
Edison, N.J.
NOAA/MESA NY Bight Project
Old Biology Bldg.
State University of New York
Stony Brook, N.Y.
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SUMMARY
This Environmental Impact Statement (EIS) provides
documentation of data and analyses supporting the formal
designation of the 106-Mile Ocean Waste Disposal Site for
continued ocean waste disposal. It evaluates the types of
industrial materials which may be disposed of at the site,
presents rationale for consideration of the site as an
alternate site for the emergency disposal of sewage sludge,
and provides guidance for EPA management of the site through
the ocean dumping permit program.
ORGANIZATION OF THE ENVIRONMENTAL IMPACT STATEMENT
The EIS has three levels of detail: This summary highlights significant
points of the chapters, thereby permitting readers to understand major points
without reading the entire text. The main text contains additional technical
information, with full discussions of the options and decisions. The
Appendices contain supplemental technical data and information which amplify
and support the decisions. It is not necessary to read the Appendices to
understand the rest of the document.
Five chapters comprise the main body of the EIS:
Chapter 1 specifies the purpose of and need for the proposed action
and presents background material relevant to ocean waste disposal.
The legal framework by which EPA selects, designates, and manages
ocean waste disposal sites is described.
Chapter 2 presents alternatives to designating the 106-Mile Site,
outlines procedures by which alternatives were chosen and evaluated,
and summarizes the relevant comparisons of all alternatives.
Chapter 3 describes the environmental features of the 106-Mile Site
and the alternative sites. The history of waste disposal and other
activities in the site vicinities is fully described.
Chapter 4 discusses the environmental consequences of waste disposal
at the alternative sites and at the proposed site.
Chapter 5 discusses the feasibility of sewage sludge disposal at the
106-Mile Site.
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Five Appendices are included to support the text:
Appendix A is a compendium of environmental data and information on
the 106-Mile Site.
Appendix B discusses in detail current and historical waste disposal
practices at the 106-Mile Site.
Appendix C provides information on present monitoring practices at
the site, and defines general guidelines for future site monitoring.
Appendix D presents Chapter III of the Final Environmental Impact
Statement on the Ocean Dumping of Sewage Sludge in the New York
Bight (EPA, 1978), describing alternatives to ocean dumping of
sewage sludge.
Appendix E contains public comments received 'on the draft EIS and
EPA's responses.
PROPOSED ACTION
EPA proposes to designate the 106-Mile Ocean Waste Disposal Site (Figure
S-l) for continuing use. This action will satisfy the need for a suitable
location off the Middle Atlantic States for the disposal of certain wastes
which satisfy the criteria for ocean disposal under EPA's ocean dumping permit
program. The criteria are based on a demonstrated need for ocean disposal in
preference to land-based alternatives, and an evaluation of the potential
impact on the marine environment.
As this EIS demonstrates, there is a present need for ocean disposal of
some industrial chemical wastes and municipal sewage sludge in the north-
eastern United States. This need comprises four categories of materials:
(1) Materials which comply with the marine environmental impact criteria
and for which land-based disposal alternatives are less acceptable
than ocean disposal
(2) Materials which comply with the impact criteria and for which land-
based alternatives are under development
(3) Materials which do not comply with the impact criteria but for which
land-based alternatives will be imposed by 1981
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41°
75°
1. New York Bight Acid
Wastes Dispoal Site
2. Northern Area
3. Southern Area
4. Delaware Bay Acid
Waste Disposal Site
5. 106-Mile Ocean
Waste Disposal Site
74°
73°
72°
40°
39°
38°
41°
40°
39°
38°
75°
74°
73°
72°
Figure S-l. Proposed Site and All Alternative Sites
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(4) Materials which must be ocean-dumped under emergency conditions,
either because they represent a health hazard, or because no
feasible alternative is available at the time of the emergency.
The 106-Mile Site was first used for waste disposal in 1961. In 1973, the
site was designated by EPA for disposal of industrial wastes on an interim
basis, pending completion of trend assessment surveys. Designation of the
site for continuing use will permit approved disposal of industrial wastes
presently dumped there and will provide for a disposal site for new wastes
judged acceptable for disposal.
More than 100 industries previously dumped wastes at the 106-Mile Site, but
only four industrial permittees now remain: E.I. du Pont de Nemours and Co.
(Edge Moor and Grasselli plants), Merck and Co., and American Cyanamid Co. Of
the four, Du Pont-Edge Moor, Merck, and American Cyanamid are scheduled to
cease ocean disposal by the end of 1981, when they will complete imple-
mentation of land-based alternatives. Du Pont-Grasselli, the remaining
permittee, will continue ocean disposal, since no viable land-based
alternatives to ocean disposal are presently available which are environ-
mentally acceptable, and the waste presently complies with EPA's marine
environmental impact criteria.
Municipal sewage sludge has been dumped at the 106-Mile Site. The City of
Camden, New Jersey, used the site during 1977 and 1978; digester clean-out
sludges from New York/New Jersey metropolitan area wastewater treatment plants
have also been dumped there. Future use of the site for additional sewage
sludge disposal will be considered only if it is determined by EPA that the
New York Bight ("12-Mile") Sewage Sludge Disposal Site cannot safely
accommodate any more sewage sludge without endangering public health or
degrading coastal water quality.
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OVERVIEW
Ocean dumping, particularly in the heavily populated northeast, has been
used as an ultimate means of waste disposal for generations in the United
States. Before the early 1970's, there was very little regulation of ocean
waste disposal. Limited regulation was provided primarily by the New York
Harbor Act of 1888, which empowered the Secretary of the Army to prohibit
disposal of wastes, except from streets and sewers, into the harbors of New
York, Hampton Roads, and Baltimore. The Refuse Act of 1899 prohibited the
disposing of materials into navigable waters when disposal impeded safe
navigation. Under these Acts, selection of disposal locations by the U.S.
Army Corps of Engineers (CE) and the issuance of permits for ocean disposal
were based primarily on transportation and navigation factors rather than on
environmental concerns.
Public interest in the effects of ocean disposal was aroused in 1969 and
1970 by a number of incidents involving the disposal of warfare agents in the
ocean. Simultaneously, studies by the National Oceanic and Atmospheric
Administration (NOAA), and several universities, identified potentially
adverse effects of sewage sludge and industrial waste disposal in the New York
Bight. The Council on Environmental Quality (CEQ) 1970 report to the
President identified poorly regulated waste disposal in the marine environment
as a potential environmental danger.
CEQ's report, and the increasing public awareness of the potential
undesirable effects of poorly regulated ocean waste disposal, were primarily
responsible for the enactment of the Marine Protection, Research, and
Sanctuaries Act (MPRSA) of 1972, the primary U.S. legislation now regulating
barged waste disposal in the ocean. In the fall of 1972, when it became
apparent that Congress would promulgate an act to regulate ocean disposal, EPA
began developing criteria to provide an effective technical base for the
regulatory program. During the development of the technical criteria, EPA
sought advice and counsel from EPA marine scientists, and from marine
specialists in universities, industries, environmental groups, and Federal and
State agencies. The criteria were published in May 1973, finalized in
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October 1973, and revised in January 1977. The criteria are used in
evaluating the need for ocean waste disposal and potential impact on the
marine environment.
Ocean disposal became an international topic of concern and discussion in
this same period. An intergovernmental conference, held in London in the fall
of 1972, developed the Convention on the Prevention of Marine Pollution by
Dumping of Wastes and Other Matter. This Convention regulates ocean waste
disposal at the international level with provisions for prohibited materials
and regulation of dumping by participating nations. The MPRSA was amended in
March 1974 to bring the national legislation into full compliance with the
International Convention.
The EPA Ocean Dumping Regulations and Criteria contain provisions for
selecting, designating, and managing ocean disposal sites, and for issuing
permits to use the sites for waste disposal. Thirteen interim municipal and
industrial waste disposal sites (most of them located in the U.S. mid-
Atlantic) were listed in EPA's Final Ocean Dumping Regulations and Criteria
published in January 1977. Existing sites will continue to be used for the
disposal of specific materials on an interim basis, pending completion of
baseline or trend assessment surveys, and ultimate designation for continuing
use or termination of use. EPA and NOAA are presently conducting trend
assessment surveys to support preparation of Environmental Impact Statements
(EIS's) on most sites proposed for continuing use. The subject of this EIS is
the proposed designation of the 106-Mile Ocean Waste Disposal Site for
continuing use and a determination of the types and quantities of wastes which
can be disposed of at the site in an environmentally acceptable manner.
MAJOR ALTERNATIVES
The major alternatives to designation of the 106-Mile Site for continuing
use are: (1) no action, thereby requiring current permittees to use other
disposal methods (primarily land-based), or, in the absence of non-ocean
xvi
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alternatives, forcing shutdown of activities which generate wastes presently
dumped at the site; and (2) use of an alternative ocean disposal site for
106-Mile Site wastes - either an existing site or a new one. The mid-Atlantic
Continental Shelf and Slope were evaluated for potential alternative disposal
sites. As a result of this evaluation, four locations were selected for
detailed evaluation as possible alternative sites: the New York Bight Acid
Wastes Disposal Site, the Delaware Bay (formerly Du Pont) Acid Waste Disposal
Site, the New York Bight Southern Area, and the New York Bight Northern Area
(Figure S-l). Each alternative was evaluated for environmental acceptability,
monitoring and surveillance requirements, associated economic burden, and
logistics, and compared to use of the 106-Mile Site. As a result of this
evaluation, the 106-Mile Site was judged the best location.
Of the eight existing waste disposal sites in the mid-Atlantic, two were
considered viable alternatives to the 106-Mile Site - the New York Bight and
Delaware Bay Acid Waste Sites. The remaining sites are used only for disposal
of non-industrial wastes, are small, and are in heavily utilized areas.
Two other alternative locations on the mid-Atlantic Continental Shelf were
also examined in detail: the so-called Northern and Southern Areas, located
mid-way between the nearshore alternative sites and the 106-Mile Site.
Although not previously designated disposal sites, these areas were surveyed
by NOAA and EPA to provide background environmental data for assessing the
advisability of using one of the locations for sewage sludge disposal. As a
result of this analysis, a small portion of the Northern Area is now a
designated alternate sewage sludge disposal site.
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AFFECTED ENVIRONMENT
The 106-Mile Site is in the mid-Atlantic just beyond the edge of the
Continental Shelf. The site is oceanic in nature; it is deep (1,400 m to
2,800 m) and the water masses and biology of the area are more like the open
ocean to the east than the coastal environment to the west. Typical of
surrounding waters, the site does not appear to be highly productive. The
bottom terrain is a vast plain sloping to the east, punctuated by several
submarine canyons. The site is currently used primarily for ocean disposal of
industrial chemical wastes and its use is managed by EPA Region II. From 1961
to 1978, approximately 5.1 million metric tons of chemical wastes, 102
thousand metric tons of sewage sludge, and 287 thousand metric tons of
digester residue were dumped at the site. An inactive munitions disposal site
is located within the boundaries of the 106-Mile Site and an inactive
radioactive waste disposal site is 10 nmi (18 km) south of the southern edge
of the 106-Mile Site. Results of surveys conducted at the site are summarized
later in this section.
The New York Bight Acid Wastes Site and the Northern and Southern Areas are
in the New York Bight, over the Continental Shelf. The sites are shallow (25
to 53 m), and the water and biota are characteristic of the Shelf region. The
Hudson Canyon separates the Southern and Northern Areas and terminates near
the Acid Site. Potentially valuable biological resources exist near the Acid
Site and Southern Area. Mineral resource development is occurring near the
Southern Area. Waste disposal in the Acid Site and Southern Area could
conflict with these other uses. Activities which could conflict with waste
disposal operations are not expected to occur in the Northern Area.
Only the New York Bight Acid Wastes Site, 15 nmi (28 km) offshore, has been
used for ocean waste disposal. From 1958 to 1978, 45.2 million metric tons of
acid and caustic wastes were released at the site. After numerous special
studies and a continuing environmental monitoring program, only short-term
XVlll
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adverse effects from waste disposal have been observed. Long-term adverse
effects of waste disposal at the Acid Site may be masked by the presence of
many more significant sources of contamination in the Bight. Because of the
difficulty of differentiating the effects of the different pollutants, no
long-term effects unique to the acid waste have been identified, nor is it
known if any significant long-term effects of this waste exist. Waste
disposal has not occurred in either the Southern or Northern Areas, although
the Alternate New York Sewage Sludge Site has been designated for use, if
required, and comprises a small section on the eastern edge of the Northern
Area.
The Delaware Bay Acid Waste Site is just south of the New York Bight,
approximately 30 nmi (55 km) off the Delaware coast. The site is located on
the Continental Shelf and is shallow (38 to 45 m). Water and biota in the
site vicinity are- typical of other mid-Atlantic Shelf regions. Bottom
sediments are medium to fine sands; the relatively smooth topography is
punctuated with sand ridges and swales. Valuable shellfish resources exist in
and near the site, however, their exploitation is currently restricted because
the area is closed to shellfishing due to the Philadelphia Sewage Sludge Site,
located only 5 nmi (9 km)south. From 1973 to 1977, 2.3 million metric tons of
Du Font-Edge Moor acid wastes were released at the site; it has been inactive
since March 1977 when Du Font's dumping was transferred to the 106-Mile Site.
Environmental studies and monitoring for impacts of acid disposal on the
environment have been inconclusive. Preliminary studies identified elevated
vanadium concentrations in shellfish from the site vicinity; however, no
direct link has been established between these observations and the acid waste
disposal.
ENVIRONMENTAL CONSEQUENCES
Environmental consequences of industrial waste disposal at the proposed
site and alternative sites were assessed. The total environmental
consequences of industrial waste disposal at the 106-Mile Site are uncertain
despite several years of study; however, continuing to use this site for waste
xix
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disposal is judged acceptable, given the alternatives. Two characteristics of
the 106-Mile Site make it the best ocean location for disposing of industrial
wastes: extreme depth and low biological productivity.
The depth of the 106-Mile Site is its greatest advantage over all
alternative sites, which are shallower. This permits materials dumped at the
site to disperse widely and dilute rapidly. As long as a waste resides in the
water column, it is subject to horizontal dispersion. Once the waste reaches
the seafloor, it may persist in one location and perhaps accumulate there.
Studies at the site have shown that the wastes are generally restricted to the
water column above the seasonal or permanent thermocline and do not reach the
seafloor in measureable quantities.
The standing crop of organisms at the 106-Mile Site is often less than the
standing crop on the Continental Shelf, therefore the total damage to
organisms from dumping will be less at the 106-Mile Site than at alternative
sites. However, studies show that some oceanic organisms are more sensitive
to wastes than similar organisms taken from heavily used coastal areas.
Therefore, while waste dilutions are sufficient to minimize adverse effects in
the water, effects on indigenous organisms are more likely at the 106-Mile
Site than at alternative sites. Although less total damage will occur at the
106-Mile Site than at alternative coastal sites, the potential for localized
damage is probably greater.
Known negative consequences of ocean disposal are expected at the 106-Mile
Site; however, these negative factors (primarily economic), do not outweigh
the potential negative environmental consequences of using alternative sites:
• The distance of the 106-Mile Site from ports requires (for disposal
and monitoring) the use of vessels with extended sea-going
capability. Increased wages, fuel costs, and other operating
expenses, make waste disposal at a distant site economically
disadvantageous to waste generators, compared to disposal at
nearshore sites.
• Unless automatic surveillance is developed and implemented,
surveillance at the 106-Mile Site will usually require the use of
shipriders.
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• Laboratory and field studies indicate that acute short-term
mortality of sensitive plankton will occur immediately upon
discharge of wastes; however, mortality will be mitigated by the
rapid dilution and dispersion of wastes in seawater within the site.
Short-term plankton mortality would be expected at any ocean
disposal site, however, oceanic organisms may be more sensitive to
stress than coastal organisms.
The state of knowledge on adverse dumping effects at this site, especially
long-term effects, is incomplete. Several years of background work were
necessary before studies of specific long-term effects could be initiated.
During that time, successful techniques for tracking and sampling the waste
plume were developed. These refined sampling techniques and the past data on
background environmental conditions at the site, will permit future studies at
the site to concentrate on effects of the waste on the biota in the waste
plume. t^ofes ^; ' > ^ •' • -> *f ' ~ "•
SEWAGE SLUDGE DISPOSAL
The feasibility of using the 106-Mile Site for municipal sewage sludge
disposal is addressed as a special case. It is acknowledged that the only
reasonable long-term solution for disposal of harmful sewage sludge is by
means of land-based processes; however, adverse conditions at the existing New
York Bight Sewage Sludge Site could require moving sludge disposal to another
site. Effects of past sludge disposal at the 106-Mile Site and at other sludge
disposal sites were evaluated to provide a basis for determining impacts from
future sludge disposal at the 106-Mile Site. On this basis, use of the site
for sludge disposal is determined to be feasible, provided that monitoring of
short- and long-term effects is instigated concurrent with sludge dumping and
that chemical wastes and sewage sludge are separated. Other conditions are
treated in Chapter 5.
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CONCLUSIONS
After carefully evaluating all reasonable alternatives, EPA proposes that
the 106-Mile Ocean Waste Disposal Site receive final designation for
continuing industrial waste disposal, in accordance with the EPA Ocean Dumping
Regulations and Criteria. However, in keeping with the MPRSA, exploration of
alternatives to ocean disposal should continue, and such research and
development should be conditions imposed on waste generators receiving ocean
disposal permits.
/ " ^N
Industrial wastes permitted for disposal at the site should/ have the
following characteristics:
• Aqueous, with concentrations of solids sufficiently low, so that
waste materials are dispersed within the upper water column
• Neutrally buoyant or slightly denser than seawater such that, upon
mixing with seawater, the material does not float
• Demonstrate low toxicity and low bioaccumulation potential to
representative marine organisms
• Contain no materials prohibited by the MPRSA or the London Ocean
Dumping Convention
• Contain constituents in concentrations which are diluted such that
the limiting permissible concentration for each constituent is not
exceeded beyond the disposal site boundaries during initial mixing
(4 hours) and not exceeded inside or outside of the .site after
initial mixing
• Dischargeable from a moving vessel, to enable rapid and immediate
dilution.
Each waste load should be sufficiently small to permit adequate dispersal
of the waste constituents before disposal of the next load, and to prevent
accumulation of waste materials due to successive dumps. Vessels releasing
wastes simultaneously should be located in different quadrants of the site, to
provide for maximum dilution of wastes within the site boundaries.
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All future permits should^eontain the following conditions:
(1) Independent shiprider surveillance of disposal operations will be
conducted by the USCG or an objective observer (the latter at
permittee's expense) with a program goal of 75% surveillance.
(2) Comprehensive monitoring for long-term impacts will be accomplished
by Federal agencies and for short-term impacts by permittees or by
environmental contractors (the latter at permittee's expense). All
permittee monitoring studies are subject to EPA approval.
Short-term monitoring should include laboratory studies of waste
characteristics and toxicity, and field studies of waste behavior
following discharge and the effect of wastes on local organisms.
Long-term monitoring should include studies of chronic toxicity of
the waste at low concentrations and field studies of the fate of
materials, especially any particulates formed after discharge.
(3) EPA will enforce a discharge rate based on the limiting permissible
concentration, disposal in specified quadrants of the site, and
maintenance of a 0.5 nmi (0.9 km) separation distance between
vessels.
(4) Key constituents will be analyzed routinely in waste samples, at
frequencies to be determined by EPA on a case-by-case basis, but
sufficient to evaluate accurately mass loading at the site.
(5) Routine bioassays will be performed on waste samples using
appropriate sensitive marine organisms.
It is further proposed that use of the site for sewage sludge disposal be
decided by EPA case-by-case, and on the basis of severity of need. Any permit
issued should include provisions for adequate monitoring and surveillance to
ensure that no significant adverse impacts result from disposal. Sludge
disposal Ishould^be allowed at the site only under the following conditions:
• Provided the existing New York Bight Sewage Sludge Site cannot
safely accommodate more sludge disposal without endangering public
health, severely degrading the marine environment, or degrading
coastal water quality.
• Independent surveillance by the U.S. Coast Guard or an unbiased
observer (the latter at the permittee's expense) will be conducted.
• Monitoring for short- and long-term impacts will be accomplished by
Federal agencies and environmental contractors (the latter at the
permittee's expense). This monitoring must include studies of the
fate of solids and sludge micro-organisms, inside and outside of the
site, and a comprehensive analysis of environmental effects.
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• Vessels will discharge the sludge into the wake so that maximum
turbulent dispersion occurs.
• Vessels discharging sludge will be sufficiently separated from
vessels discharging chemical wastes to prevent the two types of
wastes from mixing.
• Key constituents of the sludge will be routinely analyzed in barge
samples at a frequency to be determined by EPA on a case-by-case
basis, but sufficient to evaluate accurately mass loading at the
site.
• Routine bioassays will be performed on sludge samples using
appropriate sensitive marine organisms.
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TABLE OF CONTENTS
Chapter Title Page
SUMMARY xi
ORGANIZATION OF THE ENVIRONMENTAL IMPACT STATEMENT xi
PROPOSED ACTION xii
OVERVIEW xv
MAJOR ALTERNATIVES xvi
AFFECTED ENVIRONMENT xviii
ENVIRONMENTAL CONSEQUENCES xix
SEWAGE SLUDGE DISPOSAL xxi
CONCLUSIONS xxii
1 PURPOSE OF AND NEED FOR ACTION 1-1
FEDERAL LEGISLATION AND CONTROL PROGRAMS 1-3
Marine Protection, Research, and Sanctuaries Act .... 1-5
Ocean Disposal Site Designation 1-9
Ocean Dumping Permit Program 1-13
INTERNATIONAL CONSIDERATIONS 1-15
2 ALTERNATIVES INCLUDING THE PROPOSED ACTION 2-1
NO-ACTION ALTERNATIVE 2-2
CONTINUED USE OF THE 106-MILE SITE 2-3
Environmental Acceptability 2-4
Environmental Monitoring 2-7
Surveillance 2-8
Economics 2-8
Logistics 2-10
USE OF ALTERNATIVE EXISTING SITES 2-10
New York Bight Acid Wastes Disposal Site 2-12
Delaware Bay Acid Waste Disposal Site 2-18
USE OF NEW SITES 2-22
Locations on the Continental Shelf 2-22
Locations Off the Continental Shelf 2-28
SUMMARY 2-29
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TABLE OF CONTENTS (continued)
Chapter Title Page
BASES FOR SELECTION OF THE PROPOSED SITE 2-34
Geographical Position, Depth of Water Bottom
Topography and Distance from Coast 2-34
Location in Relation to Breeding, Spawning, Nursery,
Feeding, or Passage Areas of Living Resources in
Adult or Juvenile Phases 2-35
Location in Relation to Beaches and
Other Amenity Areas 2-35
Types and Quantities of Wastes Proposed to be
Disposed of, and Proposed Methods of Release,
Including Methods of Packing the Waste, if Any 2-35
Feasibility of Surveillance and Monitoring 2-36
Dispersal, Horizontal Transport and Vertical
Mixing Characteristics of the Area, Including
Prevailing Current Direction and Velocity 2-36
Existence and Effects of Current and Previous
Discharges and Dumping in the Area
(Including Cumulative Effects) 2-36
Interference with Shipping, Fishing, Recreation,
Mineral Extraction, Desalination, Fish and Shellfish
Culture, Areas of Special Scientific Importance,
and Other Legitimate Uses of the Ocean 2-37
The Existing Water Quality and Ecology of the Site
as Determined by Available Data or By Trend
Assessment or Baseline Surveys 2-37
Potentiality for the Development or Recruitment of
Nuisance Species in the Disposal Site 2-38
Existence at or in Close Proximity to the Site of any
Significant Natural or Cultural Features of
Historical Importance 2-38
CONCLUSIONS AND PROPOSED ACTION 2-38
Types of Wastes 2-38
Waste Loadings 2-39
Disposal Methods 2-40
Dumping Schedules 2-40
Permit Conditions 2-41
3 AFFECTED ENVIRONMENT 3-1
THE 106-MILE SITE 3-1
Physical Conditions 3-1
Geological Conditions 3-4
Chemical Conditions 3-5
Biological Conditions 3-6
Waste Disposal at the Site 3-7
Concurrent and Future Studies 3-7
Other Activities in the Site Vicinity 3-8
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TABLE OF CONTENTS (continued)
Chapter Title Page
ALTERNATIVE SITES IN THE NEW YORK BIGHT 3-11
Physical Conditions 3-12
Geological Conditions 3-12
Chemical Conditions 3-13
Biological Conditions 3-15
Waste Disposal at the New York Bight Acid Wastes Site . . 3-16
Concurrent and Future Studies 3-24
Other Activities in the Site Vicinity 3-25
DELAWARE BAY ACID WASTE DISPOSAL SITE 3-36
Physical Conditions 3-36
Geological Conditions 3-36
Chemical Conditions 3-36
Biological Conditions 3-36
Waste Disposal at the Site 3-37
Concurrent and Future Studies 3-40
Other Activities in the Site Vicinity 3-40
4 ENVIRONMENTAL CONSEQUENCES 4-1
EFFECTS ON PUBLIC HEALTH AND SAFETY 4-2
Commercial and Recreational Fish and Shellfish 4-2
Navigational Hazards 4-7
EFFECTS ON THE ECOSYSTEM 4-9
Plankton 4-12
Nekton 4-16
Benthos 4-17
Water and Sediment Quality 4-19
Short Dumping 4-28
UNAVOIDABLE ADVERSE ENVIRONMENTAL EFFECTS
AND MITIGATING MEASURES 4-30
RELATIONSHIP BETWEEN USE OF THE SITE
AND LONG-TERM PRODUCTIVITY 4-31
IRREVERSIBLE OR IRRETRIEVABLE COMMITMENTS OF RESOURCES .... 4-31
5 SEWAGE SLUDGE DISPOSAL AT THE 106-MILE SITE 5-1
AMOUNTS OF SLUDGE DUMPED 5-6
ENVIRONMENTAL ACCEPTABILITY 5-6
Fate of Sewage Sludge 5-9
Effects upon Water Chemistry 5-12
Interactions with Industrial Waste 5-16
Effects upon Organisms 5-17
Survival of Pathogens 5-18
ENVIRONMENTAL MONITORING 5-22
SURVEILLANCE 5-23
ECONOMICS 5-23
XXV11
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TABLE OF CONTENTS (continued)
Chapter Title Page
LOGISTICS 5-24
SUMMARY 5-24
CONCLUSIONS 5-25
6 LIST OF PREPARERS 6-1
7 GLOSSARY AND REFERENCES 7-1
GLOSSARY 7-1
UNITS OF MEASURE 7-18
REFERENCES 7-19
APPENDICES
A ENVIRONMENTAL CHARACTERISTICS OF THE 106-MILE
OCEAN WASTE DISPOSAL SITE A-l
B CONTAMINANT INPUTS TO THE 106-MILE OCEAN WASTE DISPOSAL SITE ... B-l
C MONITORING C-l
D CHAPTER III, FINAL EIS ON OCEAN DUMPING OF
SEWAGE SLUDGE IN THE NEW YORK BIGHT D-l
E COMMENTS ON THE DRAFT EIS E-l
ILLUSTRATIONS
Number Title Page
S-l Proposed Site and All Alternative Sites xiii
2-1 Proposed Site and All Alternative Sites 2-5
2-2 Existing Disposal Sites in the Mid-Atlantic 2-11
3-1 Alternative Disposal Sites 3-2
3-2 Location of the 106-Mile Site 3-3
3-3 Oil and Gas Leases in the New York Bight 3-9
3-4 Benthic Faunal Types in the Mid-Atlantic Bight 3-10
3-5 Distribution of Surf Clams, Ocean Quahogs, and Sea Scallops
in the Mid-Atlantic 3-17
3-6 Total Commercial Landings of Marine Finfishes
in the New York Bight Area, 1880-1975 3-26
3-7 Total Landings of Commercial Marine Shellfish in the
New York Bight Area, 1880-1975 3-27
3-8 Location of Foreign Fishing off the U.S. East Coast 3-28
3-9 Gravel Distribution in the New York Bight 3-31
3-10 Navigational Lanes in the Mid-Atlantic 3-32
3-11 Ocean Disposal Sites in the New York Bight Apex 3-34
3-12 Oil and Gas Leases Near Delaware Bay 3-42
5-1 Alternative Sewage Sludge Disposal Sites 5-2
XXV111
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TABLE OF CONTENTS (continued)
TABLES
Number Title Page
1-1 Responsibilities of Federal Departments and Agencies for
Regulating Ocean Waste Disposal Under MPRSA 1-7
2-1 Comparison of Contaminant Inputs to the New York Bight, 1973 . . . 2-13
2-2 Summary Comparative Evaluation of Alternative Toxic
Chemical Waste Disposal Sites 2-31
3-1 Disposal Volumes at the New York Bight Acid Wastes Disposal Site . 3-18
3-2 Reported Dilution Values for Wastes Dumped at the Acid Site .... 3-20
3-3 Estimated Amounts of Trace Metals Released Annually at the
New York Bight Acid Wastes Disposal Site 3-21
3-4 Mass Loads of Trace Metals Entering the New York Bight, 1960-1974 . 3-22
3-5 Total Landings in 1974 of Five Major Commercial Finfishes
in the New York Bight 3-26
3-6 Total New York-New Jersey Commercial Landings in 1974
and 1976 of Important Shellfish Species in the New York Bight . . . 3-27
3-7 Quantities of Waste Dumped Annually at the Delaware Bay
Acid Waste Disposal Site 3-38
3-8 Estimated Quantities of Trace Metals Dumped Annually at the
Delaware Bay Acid Waste Disposal Site 3-39
3-9 Commercial Landings of Three Major Species of Finfish
for the Delaware Region, 1974 3-41
4-1 Characteristics of the Total Metal Analyses Used in
Studies at the 106-Mile Site 4-21
4-2 Worst-Case Contribution of Waste Metal Input to the Total Metal
Loading at the New York Bight Acid Waste Site 4-24
4-3 Round-Trip Transit Times to Alternative Sites (in Hours)
Based on Varied Vessel Speeds 4-29
5-1 History of the Proposal to Relocate Sewage Sludge Disposal
to the 106-Mile Site 5-4
5-2 Comparison of Typical Physical, Chemical, and Toxicological
Characteristics of Sewage Sludge and Industrial Waste
Dumped at the 106-Mile Site 5-7
5-3 Estimated Quantities of Sewage Sludge to be Dumped in the
New York Bight 1979 to 1981 5-8
5-4 Worst-Case Projections of Metal Loading Due to Sewage Sludge
Disposal in a Quadrant of the 106-Mile Site 5-15
5-5 Worst-Case Projections of Inorganic Nutrient Loading Due to
Sewage Sludge Disposal in a Quadrant of the 106-Mile Site .... 5-16
5-6 Important Sludge-Associated Human Pathogens 5-19
5-7 Factors Identified as Contributing to the "Die-Off" or
Decline of Sewage Pathogens 5-21
XXIX
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Chapter 1
PURPOSE OF AND NEED FOR ACTION
EPA proposes to designate the 106-Mile Ocean Waste Disposal
Site for continuing use in accordance with the January 11,
1977 EPA Ocean Dumping Regulations and Criteria. The site is
needed because land-based disposal methods for some
industrial wastes are not presently available. Chapter 1
defines the action to be taken, discusses the history of the
regulation of ocean disposal, and summarizes the legal regime
for identifying and evaluating viable options.
Disposal of waste materials in the ocean has been practiced for generations
on an international scale. Since enactment in the early 1970's of U.S.
legislation and international agreements controlling ocean disposal, the
numbers of industries and municipalities dumping wastes in the ocean have
decreased dramatically due to development of land-based disposal alternatives.
However, some industries and municipal waste treatment facilities produce
wastes that cannot, using current technology, be treated or disposed of safely
or economically on land, but can be disposed of in the ocean without seriously
degrading the marine environment. Most of this waste-generating activity is
centered around the heavily populated and industrialized East Coast. To help
safely accommodate this need for ocean waste disposal, the U.S. Environmental
Protection Agency (EPA) proposes to designate the 106-Mile Ocean Waste
JU
Disposal Site (hereafter 106-Mile Site ) for continued use.
The 106-Mile Site has been used intermittently for ocean disposal since
1961. A wide variety of waste materials has been released within and near the
site. These included munitions, radioactive materials, acid,
*Also known elsewhere as Chemical Waste Site, Deepwater Dumpsite 106, Toxic
Chemical Site, Industrial Waste Site.
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nonspecific chemical wastes, sewage sludge, and residues from sewage sludge
digesters. In 1973, EPA designated the site primarily for the interim
disposal of industrial chemical wastes, while studies of the effects of waste
disposal at the site were underway. These research studies have continued
since the spring of 1974. After five years of intensive study, no significant
adverse effects have been demonstrated from disposal of any of the waste
materials.
More than 100 different dumpers have used the 106-Mile Site for waste
disposal since 1961. At present only four permittees are using the site (E.I.
du Pont de Nemours and Co. (Edge Moor and Grasselli plants), Merck and
Company, Inc., and American Cyanamid Co.). Despite this large decrease in
ocean disposal activity at the site, a present and future need exists for its
continued use. The reasons for this continuing need are four-fold: (1)
although three of the four current permittees (Du Font-Edge Moor, American
Cyanamid, and Merck) will cease ocean disposal within the next two years, they
must continue to dispose of their wastes in the ocean while alternative
land-based disposal methods are under development; (2) there are some Du
Pont-Grasselli wastes which cannot be disposed of by land-based methods, but
which can be dumped safely at the 106-Mile Site without degrading the
environment; (3) some municipal permittees dumping sewage sludge at the New
York Bight Sewage Sludge Site may be required to move ocean disposal
operations to the 106-Mile Site if public health is endangered or marine water
quality at the existing sludge site is severely degraded; and (4) a site of
known environmental characteristics is required for disposal of some wastes
under emergency conditions.
By January 1, 1982 only wastes that can be demonstrated to comply with
EPA's environmental impact criteria and cannot be discarded on land, will be
permitted to be dumped in the ocean. For the short term, however, while
land-based disposal methods are being developed, some industrial chemicals arid
sewage sludge must continue to be disposed of in the ocean, even though these
materials have not been demonstrated to meet the impact criteria. Neither
Merck, American Cyanamid, nor the municipal sludge permittees have demon-
strated compliance with the impact criteria; however, because they have
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demonstrated an adequate need for ocean disposal, accompanied by a schedule
for developing suitable land-based alternatives, these dumpers are permitted
to use the ocean for waste disposal on interim bases.
As part of its decision-making process, EPA has investigated all reasonable
alternatives to the continued use of the 106-Mile Site. Two broad categories
of alternatives exist: (1) take no action, thereby requiring use of other
disposal methods, or, if other disposal methods are unavailable, causing
cessation of the waste-producing processes; or (2) designate and use another
ocean location for disposing of these wastes. After a careful review of the
alternatives, EPA has determined that designation of the 106-Mile Site for
continued use is the most favorable course of action.
Therefore, based upon the continued need for ocean disposal, the lack of
any significant adverse impact as determined by the research studies conducted
at the site, and the lack of a better alternative to designating this
particular site, EPA proposes to designate the 106-Mile Site for continued
use. Continued use of the site will allow approved dumping of the wastes
released there under current ocean dumping permits, and will provide for the
disposal of new wastes which the EPA deems acceptable for ocean disposal. EPA
Region II will manage the site; regulate times, rates, methods of disposal,
and quantities and types of materials disposed; develop and maintain effective
monitoring programs for the site; conduct disposal site evaluation studies;
and recommend modifications in site use or designation as necessary.
FEDERAL LEGISLATION AND CONTROL PROGRAMS
Before the early 1970's, there was little regulation of ocean waste
disposal. Limited regulation was provided primarily by the New York Harbor
Act of 1888, which empowered the Secretary of the Army to prohibit disposal of
wastes, except from streets and sewers, into the harbors of New York, Hampton
Roads, and Baltimore. The Refuse Act of 1899 prohibited the disposal of
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materials into navigable waters when disposal impeded safe navigation. Under
these Acts, selection of disposal locations by the U.S. Army Corps of
Engineers (CE) and the issuance of permits for ocean disposal were based
primarily upon transportation and navigation factors rather than upon
environmental concerns.
Public interest in the effects of ocean disposal was aroused in 1969 and
1970 by a number of incidents involving the disposal of warfare agents in the
ocean. Simultaneous studies by the National Oceanic and Atmospheric
Administration (NOAA), and several universities, identified potential adverse
effects of sewage sludge and industrial waste disposal in the New York Bight.
The Council on Environmental Quality (CEQ) 1970 report to the President,
identified poorly regulated waste disposal in the marine environment as a
potential environmental danger.
CEQ's report and the increasing public awareness of the potential
undesirable effects of poorly regulated ocean waste disposal were primarily
responsible for the enactment of the Marine Protection, Research, and
Sanctuaries Act (MPRSA) of 1972, the primary U.S. legislation now regulating
barged waste disposal in the ocean. In the fall of 1972, when it became
apparent that the Congress would promulgate an act to regulate ocean disposal,
EPA began to develop criteria which would provide effective technical bases
for the regulatory program. During the development of the technical criteria,
EPA sought advice and counsel from EPA marine scientists, and from marine
specialists in universities, industries, environmental groups, and Federal and
state agencies. The criteria were published in May 1973, finalized in October
1973, and revised in January 1977. The criteria are used to evaluate the need
for ocean waste disposal, and the potential impact of disposal on the marine
environment.
Legislation dates back almost 100 years for controlling waste disposal into
rivers, harbors, and coastal waters; however, ocean waste disposal was not
specifically regulated in the United States until passage, in October 1972, of
the Marine Protection, Research, and Sanctuaries Act (MPRSA, PL 92-532, as
amended). To enable better understanding of this important legislation, it is
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discussed here in detail, together with other relevant Federal legislation,
Federal control programs initiated by MPRSA, and EPA programs for ocean
disposal site designation and issuance of ocean disposal permits.
The Clean Water Act (CWA) of 1977 (PL 95-217) amended and replaced earlier
legislation which established a comprehensive regulatory program to control
discharges of pollutants from outfalls into navigable waters of the United
States, including ocean waters. The primary objective of the CWA is to
restore and maintain the chemical, physical, and biological integrity of the
nation's waters. CWA regulates discharges by the promulgation of criteria to
prevent degradation of the marine environment (Section 403), and the
application of the criteria in the issuance of permits (Section 402). Thus,
CWA and MPRSA are the primary Federal legislative means which are used to
control ocean waste disposal, via ocean outfalls or by dumping at offshore
disposal sites.
MARINE PROTECTION, RESEARCH, AND SANCTUARIES ACT
The MPRSA regulates the transportation and ultimate dumping of waste
materials in ocean waters. The Act is divided into three parts: Title
I - Ocean Dumping, Title II - Comprehensive Research on Ocean Dumping, and
Title III - Marine Sanctuaries. This EIS concentrates on Title I,
specifically Section 102(c), which charges EPA with the responsibility for
designating sites and times for dumping.
Title I, the primary regulatory section of the Act, establishes the permit
program for the disposal of dredged and non-dredged materials, mandates
determination of impacts, and provides for enforcement of permit conditions.
Through Title I, the Act provides a procedure for regulating ocean disposal of
waste originating from any country, into ocean waters under the jurisdiction
or control of the United States. Any transport for dumping in U.S. waters
requires a similar permit. Title I requires that a permit be obtained by any
person of any nationality wishing to transport waste material from any U.S.
port or under a U.S. flag with the intention of disposing of it anywhere in
the world's oceans.
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Title I prohibits the dumping in ocean waters of certain wastes, among them
biological, radiological, and chemical warfare agents, and all high-level
radioactive wastes. Title 1 was further amended in November 1977 (PL 95-153)
*
to prohibit dumping of harmful sewage sludge after December 31, 1981. The
provisions of Title I include criminal fines of $50,000 maximum and jail
sentences of up to one year for every unauthorized dump or violation of permit
requirement, and a civil fine of $50,000 maximum. Any individual may seek an
injunction against any unauthorized dumper with possible recovery of all costs
of litigation.
Title II of MPRSA provides for comprehensive research and monitoring of
ocean dumping effects on the marine environment. Under Title II, The National
Oceanic and Atmospheric Administration's (NCAA's) ocean dumping program has
conducted extensive survey and laboratory investigations over the past several
years at ocean waste disposal sites in the North Atlantic Ocean. This work
aids EPA in site management by providing data for site-use decisions.
Several Federal departments and agencies share responsibilities under the
Act (Table 1-1). The major responsibilities are mandated to EPA to review,
grant, and enforce dumping permits for all wastes except dredged materials,
and to designate and manage all disposal sites. In October 1973, EPA
implemented its responsibility for regulating ocean dumping under MPRSA by
issuing final Ocean Dumping Regulations and Criteria (hereafter the "Ocean
Dumping Regulations"), which were revised in January 1977 (40 CFR, Parts 220
to 229). These regulations established procedures and criteria for:
designating and managing ocean disposal sites (Part 228), reviewing ocean
disposal permit applications and assessing impacts of ocean disposal and
Harmful sewage sludge is defined by PL 95-153 as sewage sludge that "may
significantly degrade or endanger human health, welfare and amenities, the
marine environment and ecological systems, or economic potential."
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TABLE 1-1
RESPONSIBILITIES OF FEDERAL DEPARTMENTS AND AGENCIES
FOR REGULATING OCEAN WASTE DISPOSAL UNDER MPRSA
Department /Agency
U.S. Environmental Protection Agency
U.S. Department of the Army
Corps of Engineers
U.S. Department of Transportation
Coast Guard
U.S. Department of Commerce
National Oceanic and Atmospheric
Administration
U.S. Department of Justice
U.S. Department of State
Responsibility
Issuance of waste disposal permits,
other than for dredged material.
Establishment of criteria for
regulating waste disposal.
Enforcement actions.
Site designation and management.
Overall ocean disposal program
management .
Issuance of dredged material
disposal permits.
Surveillance, enforcement, issuance
of regulations, review of permit
applications.
Long-term monitoring and research.
Comprehensive ocean dumping impact
and short-term effect studies.
Marine sanctuary designation.
Court actions.
International agreements.
(Part 227), and enforcing permits. Interim disposal sites were authorized
pending final designation for continuing, or a decision to terminate use. The
106-Mile Site was one of 13 municipal and industrial sites approved for
interim use.
The U.S. Army Corps of Engineers (CE) issues permits for disposal of
dredged material after determining compliance of the material with EPA's
environmental impact criteria (40 CFR 227). Compliance with the criteria is
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alternative disposal methods subject to EPA's concurrence. The CE is
responsible for evaluating disposal applications and granting permits to
dumpers of dredged materials, whereas dredged material disposal sites are
designated and managed by EPA.
Under MPRSA, the Commandant of the U.S. Coast Guard (USCG) is assigned
responsibility by the Secretary of Transportation for conducting surveillance
of disposal operations to ensure compliance with permit conditions and to
discourage unauthorized disposal. Violations are referred to EPA for
enforcement. Surveillance is accomplished by means of spot checks of disposal
vessels for valid permits, interception or escorting of dump vessels, use of
shipriders, aircraft overflights during dumping, and random surveillance
missions at land facilities. An automated Ocean Dumping Surveillance System
(ODSS) based on electronic navigation has been field-tested and evaluated by
the USCG for future use in routine surveillance. For the present, shipriders
are the primary means of surveillance at the 106-Mile Site.
Under Title II of MPRSA, NOAA conducts comprehensive monitoring and
research programs on the effects of ocean dumping on the marine environment,
including short-term effects and potential long-term effects of pollution,
over-fishing, and other man-induced changes in oceanic ecosystems. Title III
of MPRSA authorizes NOAA to designate coastal marine sanctuaries, after
consultation with other affected federal agencies, and to regulate all
activities within the sanctuaries.
The Department of Justice initiates relief actions in court, at EPA's
request in response to violations of the terms of MPRSA. When necessary,
injunctions to cease ocean dumping are sought. Criminal fines and jail
sentences may be levied, based upon the magnitudes of the violations.
The Department of State seeks effective international action and
cooperation in protection of the marine environment by negotiating inter-
national agreements which further the goals of MPRSA. The most significant
international negotiation with respect to ocean dumping is the Convention on
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the Prevention of Marine Pollution by Dumping of Wastes and Other Matter
(hereafter the "Convention" or the "Ocean Dumping Convention") which is
discussed later in this chapter.
The MPRSA has been amended several times since its enactment in 1972. Most
amendments provide for annual appropriations for administration of MPRSA.
However, two of the amendments are noteworthy. First, passage of an amendment
in March 1974 (PL 93-254), brought the Act into full compliance with the
Convention. Second, an amendment (PL 95-153) passed in November 1977,
prohibits disposal of harmful sewage sludge in ocean waters after December 31,
1981.
OCEAN DISPOSAL SITE DESIGNATION
Under Section 102(c) of the MPRSA, the EPA Administrator is authorized to
designate sites and times for ocean disposal, provided that the waste does not
contain prohibited materials, and will not significantly degrade, or endanger,
human health, welfare, and amenities, the marine environment and ecological
systems, or economic potential. In response to this mandate, EPA established
criteria for designating sites in its Ocean Dumping Regulations and Criteria
(Part 228). These include criteria for site selection and procedures for
designating the sites for disposal. General criteria for selection of sites,
as provided in the Regulations, are:
(a) The dumping of materials into the ocean will be
permitted only at sites or in areas selected to minimize the
interference of disposal activities with other activities in
the marine environment, particularly avoiding areas of
existing fisheries or shellfisheries, and regions of heavy
commercial or recreational navigation.
(b) Locations and boundaries of disposal sites will be so
chosen that temporary perturbations in water quality or other
environmental conditions during initial mixing caused by
disposal operations anywhere within the site can be expected
to be reduced to normal ambient seawater levels or to
undetectable contaminant concentrations or effects before
reaching any beach, shoreline, marine sanctuary, or known
geographically limited fishery or shellfishery.
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(c) If at anytime during or after disposal site evaluation
studies, it is determined that existing disposal sites
presently approved on an interim basis do not meet the
criteria for site selection set forth in [Sections] 228.5 to
228.6, the use of such sites will be terminated as soon as
suitable alternate disposal sites can be designated.
(d) The sizes of ocean disposal sites will be limited in
order to localize for identification and control any
immediate adverse impacts and permit the implementation of
effective monitoring and surveillance programs to prevent
adverse long-term impacts. The size, configuration, and
location of any disposal site will be determined as a part of
the disposal site evaluation or designation study.
(e) EPA will, wherever feasible, designate ocean dumping
sites beyond the edge of the continental shelf, and other
such sites that have been historically used. [Section 228.5]
Factors considered under the specific criteria for site selection relate
more closely to conditions at the proposed sites by treating the general
criteria in additional detail. A proposed site which satisfies the specific
criteria for site selection conforms to the broader general criteria. The
factors to be considered are:
(1) Geographical position, depth of water, bottom topography
and distance from coast;
(2) Location in relation to breeding, spawning, nursery,
feeding, or passage areas of living resources in adult or
juvenile phases;
(3) Location in relation to beaches and other amenity areas;
(4) Types and quantities of wastes proposed to be disposed
of and proposed methods of release, including methods of
packing the waste, if any;
(5) Feasibility of surveillance and monitoring;
(6) Dispersal, horizontal transport and vertical mixing
characteristics of the area, including prevailing current
direction and velocity, if any;
(7) Existence and effects of current and previous discharges
and dumping in the area (including cumulative effects);
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(8) Interference with shipping, fishing, recreation, mineral
extraction, desalination, fish and shellfish culture, areas
of special scientific importance, and other legitimate uses
of the ocean;
(9) The existing water quality and ecology of the site as
determined by available data or by trend assessment or
baseline surveys;
(10) Potentiality for the development or recruitment of
nuisance species in the disposal site;
(11) Existence at or in close proximity to the site of any
significant natural or cultural features of historical
importance [Section 228.6].
These factors are addressed relative to the 106-Mile Site in Chapter 2.
Once designated, the site must be monitored for adverse impacts of waste
disposal. EPA monitors the following types of effects to determine the extent
of marine environmental impacts due to material released at the site:
• Movement of materials into estuaries or marine
sanctuaries, or onto oceanfront beaches, or shorelines;
• Movement of materials toward productive fishery or
shellfishery areas;
• Absence from the disposal site of pollution-sensitive
biota characteristic of the general area;
• Progressive, non-seasonal, changes in water quality or
sediment composition at the disposal site, when these
changes are attributable to materials disposed of at the
site;
• Progressive, non-seasonal, changes in composition or
numbers of pelagic, demersal, or benthic biota at or
near the disposal site, when these changes can be
attributed to the effects of materials disposed of at
the site;
• Accumulation of material constituents (including without
limitation, human pathogens) in marine biota at or near
the site [Section 228.10b].
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EPA has established impact categories in its Ocean Dumping Regulations
(Section 228.10) which specify impacts, detected by means of site monitoring,
which require modifications in disposal site usage:
(1) IMPACT CATEGORY I: The effects of activities at the
disposal site shall be categorized in Impact Category I when
one or more of the following conditions is present and can
reasonably be attributed to ocean dumping activities:
(i) There is identifiable progressive movement or accumu-
lation, in detectable concentrations above normal ambient
values, of any waste or waste constituent from the disposal
site within 12 nautical miles of any shoreline, marine
sanctuary designated under Title III of the Act, or critical
area designated under Section 102 (c) of the Act; or
(ii) The biota, sediments, or water column of the disposal
site, or any area outside the disposal site where any waste
or waste constituent from the disposal site is present in
detectable concentrations above normal ambient values, are
adversely affected by the toxicity of such waste or waste
constituent to the extent that there are statistically
significant decreases in the populations of valuable
commercial or recreational species, or of specific species of
biota essential to the propagation of such species, within
the disposal site and such other area as compared to
populations of the same organisms in comparable locations
outside such site and area; or
(iii) Solid waste material disposed of at the site has
accumulated at the site or in areas adjacent to it, to such
an extent that major uses of the site or of adjacent areas
are significantly impaired and the Federal or State agency
responsible for regulating such uses certifies that such
significant impairment has occurred and states in its
certificate the basis for its determination of such
impairment; or
(iv) There are adverse effects on the taste or odor of
valuable commercial or recreational species as a result of
disposal activities; or
(v) When any toxic waste, toxic waste constituent, or toxic
byproduct of waste interaction, is consistently identified in
toxic concentrations above normal ambient values outside the
disposal site more than four hours after disposal.
(2) IMPACT CATEGORY II: The effects of activities at the
disposal site which are not categorized in Impact Category I
shall be categorized in Impact Category II [Section 228.10c].
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OCEAN DUMPING PERMIT PROGRAM
EPA's Ocean Dumping Regulations establish a program for the application,
evaluation, and issuance of ocean dumping permits. When a site is selected
and duly designated, permits for the use of the site can be issued by CE for
dredged material dumping and by EPA for other dumping. The Ocean Dumping
Regulations are specific about the procedures used to evaluate permit
applications, and the granting or denial of such applications. EPA and the CE
evaluate permit applications principally to determine whether there are (1) a
demonstrated need for ocean disposal and proof that no other reasonable
alternatives exist (40 CFR 227 Subpart C), and (2) compliance with the
environmental impact criteria (40 CFR 227 Subparts B, D, and E).
Compliance with EPA's environmental impact criteria ensures that the
proposed waste disposal will not "unduly degrade or endanger the marine
environment," and will not cause unacceptable adverse effects on human health,
the marine ecosystem, or other uses of the ocean. The criteria are too
lengthy to include here; however, the relevant points are briefly summarized
below.
• Prohibited Materials: High-level radioactive wastes; materials
produced for radiological, chemical, or biological warfare; unknown
materials; persistent floatable materials which interfere with other
uses of the ocean
• Materials present as trace contaminants only except on an emergency
basis: Organohalogens; mercury and mercury compounds; cadmium and
cadmium compounds; oil; known or suspected carcinogens, mutagens, or
teratogens
• Trace contaminants in the liquid fraction must neither exceed the
marine water quality criteria, nor exist in toxic and bioaccumu-
lative forms after initial mixing
• Bioassays on the suspended particulate or solid fractions must not
indicate occurrence of significant mortality or significant adverse
sublethal effects, including bioaccumulation due to waste dumping
• When bioassay methods are unavailable: Maximum concentrations of
mercury and cadmium apply; organohalogen concentrations must be less
than is known to be toxic to organisms; oils in the waste must not
produce a visible sheen on the water
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Trace contaminants must neither render edible marine organisms
unpalatable nor endanger health of humans, domestic animals,
shellfish, or wildlife.
Six types of ocean dumping permits may be issued: Interim, Special,
General, Emergency, Research, and Incineration-at-Sea. With few exceptions,
EPA has issued only Interim Permits. These permits are valid for one year
maximum. They are issued when the permittee cannot demonstrate compliance of
the waste with the environmental impact criteria, but can demonstrate that the
need for ocean disposal is of greater significance to the public interest than
possible adverse environmental impacts. Moreover, Interim Permits cannot be
issued to applicants who were not issued dumping permits before April 23,
1978. Holders of present Interim Permits must have a compliance schedule
which will ensure either the complete phaseout of ocean dumping or compliance
with the environmental impact criteria by December 31, 1981. After that date,
EPA will not issue Interim Permits and ocean disposal of harmful wastes will
cease. At the 106-Mile Site, American Cyanamid and Merck are dumping under
Interim Permits.
Special Permits, which are issued when the applicant can adequately
demonstrate compliance of the wastes with the environmental impact criteria
and can demonstrate a need for ocean disposal, may be issued for a maximum of
three years. Holders of Special Permits are not subject to the 1981 deadline
for cessation of the ocean disposal of harmful wastes. Some industrial
permittees have been granted Special Permits. Specifically, at the 106-Mile
Site, Du Pont-Edge Moor and Du Pont-Grasselli are holders of Special Permits.
General Permits may be issued for ocean disposal of small amounts of
materials which will have minimal adverse effects upon the environment.
Examples of materials which warrant a General Permit include human remains or
ashes for burial at sea, target vessels for ordnance testing, and derelict
vessels transported for scuttling.
Emergency Permits may be issued for ocean disposal of materials which pose
an unacceptable risk to human health, and for which there is no other
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reasonable disposal technique. Emergency Permit requests are considered
case-by-case by EPA on the basis of the waste's characteristics and the safest
means for its disposal.
Research Permits may be issued for dumping material into the ocean as part
of a research project, when the scientific merit of the project outweighs the
potential adverse impacts of the dumping. EPA designates the disposal site(s)
to be used by Research Permit holders on the basis of the nature of the study
project.
Incineration-at-Sea Permits are either Research, Interim, or Special
permits. Current Incineration-at-Sea permits are Special Permits, issued for
disposal at the New York Bight Wood Incineration Site. As Special Permits,
they are issued for a maximum of three years. Burning is conducted under
controlled weather conditions; the ash is transported back to shore and used
as landfill. Research and Interim Permits have been issued for the
incineration of organochlorine wastes.
INTERNATIONAL CONSIDERATIONS
The principal international agreement governing ocean dumping is the
Convention on the Prevention of Marine Pollution by Dumping of Wastes and
Other Matter (Ocean Dumping Convention), which became effective in August
1975, upon ratification by 15 contracting countries. Designed to control
dumping of wastes in the oceans, the Convention specifies that contracting
nations will regulate disposal in the marine environment within their
jurisdiction, disallowing all disposal without permits. Certain other
hazardous materials are prohibited, such as biological, radiological, and
chemical warfare agents and high-level radioactive matter. Certain other
materials (e.g., cadmium, mercury, organohalogens and their compounds, oil,
and persistent synthetic materials which float) are prohibited, except when
present as trace contaminants. Other materials - arsenic, lead, copper, zinc,
cyanide, fluoride, organosilicon, and pesticides - while not prohibited from
ocean disposal, require special care. Permits are required for at-sea
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disposal of materials not specifically prohibited. The nature and quantities
of all waste material, and the circumstances of disposal, must be periodically
reported to the Intergovernmental Maritime Consultative Organization (IMCO)
which is responsible for administration of the Convention. Effective in March
1979, the Convention was amended to incorporate regulations for control of
incineration of wastes at sea to, be enforced nationally.
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Chapter 2
ALTERNATIVES INCLUDING THE PROPOSED ACTION
Some industrial waste products, which cannot be disposed
of using land-based methods, can be safely dumped in the
ocean until other disposal alternatives are developed. To
meet the need for a suitable oceanic location for waste
disposal, EPA evaluated five sites for environmental
acceptability, feasibility and ease of monitoring and
surveillance, economic burden, and logistics. Based upon
this evaluation, the 106-Mile Site was determined to be the
best location for disposal of the industrial wastes under
consideration. As a special case, EPA evaluated the
feasibility of using the 106-Mile Site for sludge disposal.
It was determined that, under suitable conditions, the site
could provide an alternative location for short-term sewage
sludge disposal.
After reviewing the alternatives, EPA proposes that the 106-Mile Ocean
Waste Disposal Site be designated for continuing use. The following
alternatives were considered:
• No Action.
• Proposed Action: Designate the 106-Mile Site for continuing use.
• Use of Other. Sites: Designate a site other than the 106-Mile Site.
Evaluation of the alternatives was based upon several factors:
• Environmental acceptability
• Feasibility and ease of monitoring
• Feasibility and ease of surveillance
• Economic burden
• Logistics
This EIS does not specifically address land-based alternatives to ocean
disposal because feasibility of using land-based disposal processes is
assessed on a case-by-case basis as part of EPA's ocean dumping permit
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process. For example, Merck, American Cyanaraid, and Du Font-Edge Moor,
presently authorized to dump wastes at the 106-Mile Site, are only using ocean
disposal pending development of land-based processes which will permit
reclamation or disposal of the wastes. However, present-day technology is
inadequate to supply land-based disposal alternatives for Du Pont-Grasselli1s
waste. Du Pont-Grasselli has demonstrated that its waste satisfies EPA's
environmental impact criteria, thus EPA has authorized disposal of this waste
at the 106-Mile Site, with the stipulation that Du Pont continue to seek
land-based alternatives for the waste.
Use of the 106-Mile Site as an alternate site for sewage sludge disposal
was addressed in the Final EIS on the Ocean Dumping of Sewage Sludge in the
New York Bight (EPA, 1978). This EIS presents additional considerations about
the environmental acceptability of sewage sludge at the 106-Mile Site (Chapter
5) and includes Chapter III - Alternatives to the Proposed Action - of the
earlier EIS as Appendix D. Land-based alternatives are discussed in
Appendix D.
NO-ACTION ALTERNATIVE
The No-Action alternative would result in canceling or postponing the
designation of an industrial waste disposal site off the Middle Atlantic
States, thus requiring disposal of industrial wastes by other means; or, if
other means of disposal were unavailable, would require^ termination of the
waste-producing processes. This alternative would be feasible under certain
conditions: (1) existence of technologically, environmentally, and
economically feasible land-based disposal methods; or (2) evidence that ocean
disposal causes sufficiently adverse environmental consequences to preclude it
from consideration. Neither of these No-Action conditions applies to the
proposed use of the 106-Mile Site for waste disposal.
In Chapter 1, a need was established for designating the 106-Mile Site for
continued use. EPA evaluates the feasibility of land-based disposal methods
when evaluating applications for ocean dumping permits, and permits are not
issued if a waste can be disposed of safely on land. Therefore, the present
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106-Mile Site permittees have adequately demonstrated that land-based disposal
is currently unfeasible for their wastes. The consequences of terminating the
waste generation, because no disposal methods were available, would be
dramatic. In the case of American Cyanamid, for example, shut-down of the
Warners plant would result in the direct loss of 850 jobs, valued at
$14,000,000 annually (Reid, 1978). The impact would have other effects.
American Cyanamid is the sole U.S. producer of malathion, a nonpersistent
insecticide, which is widely used for protection of crops and eradication of
several disease-causing insects. Termination of malathion production would be
felt around the world. Shut-down of any of the other permittees could have
negative consequences.
Most important, past dumping at the 106-Mile Site has not appeared to cause
sufficiently severe adverse effects to preclude use of the site for waste
disposal. This subject is treated more fully in Chapter 4. The short-term
dumping effects on organisms at the site are generally known. In the initial
stages of waste dilution, acute plankton mortality occurs as the pH of the
receiving water changes. But this effect is mitigated by the subsequent rapid
dilution and neutralization which occurs as the waste is dispersed throughout
the mixing zone. After dumping, levels of trace elements in the water are
elevated for a period of time; however, barge speeds and waste discharge
rates, which are stipulated in the dumping permit, ensure that waste
concentrations do not exceed the limiting permissible concentration at any
time. Studies are still underway investigating the subtle and long-range
effects of dumping at the site.
CONTINUED USE OF THE 106-MILE SITE
The proposed action is to continue use of the 106-Mile Site for waste
disposal. This section summarizes anticipated impacts, forming the basis for
comparison with the other alternatives (discussed later in this chapter).
The 106-Mile Site was established in 1965 for the disposal of industrial
wastes not suitable for land disposal. It is located approximately 110 rani
(200 km) southeast of Ambrose Light, New York, and approximately 130 nmi
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(240 km) east of Cape Henlopen, Delaware (Figure 2-1). The site covers almost
2 2
500 nmi (1,700 km ) on the Continental Slope and Continental Rise, and its
latitudes and longitudes are 38°40'N to 39°00'N, and 72°00'W to 72°30'W,
respectively. Water depths at the site range from 1,440 m (in the topo-
graphically rugged northwest corner) to 2,750 m (in the relatively flat
southeast corner). An inactive munitions waste disposal site is within the
site boundaries, and an inactive radioactive waste disposal area is 10 nmi
(18 km) due south.
NOAA, assisted by other government agencies and academic institutions, has
been surveying this site for many years, and has published its observations in
two summary reports (NOAA, 1975, 1977), several memoranda, public hearing
testimony, and in its annual report to Congress (NOAA, 1978). A private
contractor, acting on behalf of the permittees, has been monitoring the site
for two years.
ENVIRONMENTAL ACCEPTABILITY
Continued use of the 106-Mile Site for waste disposal will not directly
endanger public health. The site is not in a commercially or recreationally
important fishing or shell fishing area. Most raid-Atlantic fishing is on the
Continental Shelf or along the Shelf/Slope break. Infrequent domestic and
foreign fishing occurs at or near the site, but usage is variable and
dependent on occurrence of water masses or eddies which affect fish abundance
and distribution. There is a slight potential that some of the nekton caught
at or near the site may have accumulated low levels of trace contaminants from
wastes dumped at the site. However, the low level of fishing activity in the
area, in combination with the extreme conditions necessary for bioaccumulation
of contaminants in amounts which are unhealthy to man, make the potential
threat to human health from dumping at this site slight.
Thus far, no studies have shown long-term adverse effects on water and
sediment quality or on the site biota. The natural variability of the water
at the site, resulting from the interaction of three major water masses,
causes much greater changes in the biotal assemblages of the site and vicinity
than waste disposal.
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41°
75°
1. New York Bight Acid
Wastes Dispoal Site
2. Northern Area
3. Southern Area
4. Delaware Bay Acid
Waste Disposal Site
5. 106-Mile Ocean
Waste Disposal Site
74°
73°
72°
40°
39°
38°
41°
40°
39°
38°
75°
74°
73°
72°
Figure 2-1. Proposed Site and All Alternative Sites
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Routine laboratory bioassay tests performed on the waste, together with
field dispersion data, indicate that levels of contaminants in the waste are
rapidly diluted upon discharge, and concentrations of the waste contaminants
do not remain elevated long enough to cause significant mortality in
organisms. Field monitoring by NOAA (1975, 1977) has confirmed these
observations. Laboratory studies on wastes currently being released at the
site have shown adverse effects only at concentrations much higher than those
occurring in the site. Although laboratory studies cannot be directly
extrapolated to the ocean environment, the differences between the concen-
trations found at the site and the very high concentrations required for
measurable effects in the laboratory, provide safety factors for short-term
and long-term adverse impacts. Detailed discussions of environmental
consequences of waste disposal at the site appear in Chapter 4.
The wastes presently permitted to be dumped at the site are primarily
aqueous solutions and are discharged relatively slowly over a large area, thus
there is extensive dilution and dispersion of disposed wastes. Monitoring by
acoustic means has shown that pycnoclines act as barriers to downward movement
of waste materials. Consequently, adverse bottom impacts are highly unlikely.
This conclusion has been corroborated by benthic investigations at the site.
Future wastes, with chemical and physical properties similar to present
wastes, are expected to behave in the same manner, thus causing no adverse
impacts .
Sewage sludge disposal at the 106-Mile Site will be considered only upon a
finding by EPA that the New York Bight (12-Mile) Sewage Sludge Site cannot
safely accommodate additional sludge release without endangering public health
or unacceptably degrading coastal water quality. The alternative sites
discussed later in this chapter would be designated for industrial wastes, not
sewage sludge. Chapter 5 discusses in more detail the environmental
acceptability of releasing sewage sludge at the site; the major findings are
summarized here:
Volumes of sludge requiring ocean disposal will increase 150% from
1978 to 1981.
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Settling of sludge particles would be strongly inhibited by the
seasonal and permanent pycnoclines at about 10 to 50 in and 100 to
150 m depth, respectively.
Horizontal dispersion would probably exceed vertical settling by at
least two orders of magnitude.
Sludge would add only 1% additional nitrogen to the site.
Therefore, excessive phytoplankton blooms are not expected.
ENVIRONMENTAL MONITORING
The purpose of monitoring a waste disposal site is to ensure that long-term
adverse impacts do not develop unnoticed, especially adverse impacts which are
irreversible or irretrievable. As NOAA has observed in its baseline report on
effects of dumping at the 106-Mile Site, monitoring is more difficult at sites
beyond the Continental Shelf:
This is due to factors such as greater depths of water and
distances from shore and also to the general paucity of
environmental and biological information in off-the-shelf
areas. In the case of [the 106-Mile Site], this situation
is further complicated by the interactions of major water
masses, Shelf Water, Slope Water, and Gulf Stream eddies.
The [site] is a complex oceanographic area in which to
assess natural environmental conditions and the impact of
man's activities upon those conditions (NOAA, 1977).
Another problem in monitoring involves assessing the interaction of liquid
wastes with the surrounding water and marine life. Under the dynamic
conditions at the 106-Mile Site, long-term impacts will be nearly impossible
to measure because affected plants and animals will most likely have moved out
of the area, either by swimming or drifting with the water. The difficulty of
monitoring long-term impacts in the water column is inherent in aqueous waste
disposal at any oceanic site. Monitoring at the site is further complicated
by the presence of sunken munitions within the site boundaries and radioactive
waste barrels just outside the southern site boundary. Any benthic sampling
near these locations must.be carefully conducted.
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SURVEILLANCE
Nearshore sites permit use of patrol vessels and helicopters for
surveillance; however, until other techniques are developed, surveillance at
the 106-Mile Site will require use of observers (shipriders) because the site
is located outside the range of other means of surveillance. The USCG has
stated that the program goal for surveillance at industrial waste sites is 75%
coverage of all industrial dumping operations.
ECONOMICS
TRANSPORTATION COSTS
The cost of barging chemical wastes to the 106-Mile Site is estimated to be
in the range of $8.80 to $11.00 per metric ton ($8.00 to $10.00 per ton).
Therefore, the total cost of industrial waste disposal at the site in 1978
(730,000 metric tons) was about $6.4 to $8.0 million for all permittees. The
port of departure affects the costs somewhat because vessels transiting from
ports in Delaware Bay must travel a greater distance to the site than vessels
coming from New York Harbor. The total cost of disposal at the site will drop
as some permittees phase out ocean dumping; however, the costs to individual
permittees will rise as a result of inflation and increased fuel prices.
MONITORING COSTS
The costs of monitoring at the 106-Mile Site are high compared to other
areas, because of the complexity of the environment and distance from shore.
NOAA is responsible for comprehensive and continuing monitoring. A cost to
NOAA of $1 million per year has been estimated to conduct seasonal monitoring
surveys, based on a cost ranging from $200,000 to $300,000 for EPA or NOAA
baseline surveys (Breidenbach, 1977). The cost to permittees for monitoring
is high, primarily due to the site's great distance from shore.
If new materials, industrial and/or municipal sludge for example, were
permitted to be released at the site, monitoring costs would increase
substantially. The new permittees would be required to perform dispersion
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studies and other investigations concerned with short-term effects of waste
discharges, which would augment the existing monitoring program. NOAA would
have to intensify its monitoring to determine if the biota is affected by
interactions between waste types, and to assess long-term trends.
SURVEILLANCE COSTS
The current U.S. Coast Guard Instruction regarding surveillance and
enforcement of ocean disposal sites establishes a goal of observing 75% of all
industrial waste disposal operations (USCG, 1976). Surveillance activities
include stationing a shiprider onboard the vessel to observe the disposal
operation, conducting random spot checks before the barge leaves port, and
checking vessel logs for departure and arrival times. The USCG presently
assigns several full-time people to the surveillance of disposal activities in
the Bight, including the 106-Mile Site.
LOSS OF BIOTIC OR MINERAL RESOURCES
Almost all U.S. fishing activities are located over the Continental Shelf.
Wastes dumped at the site would be extremely dilute, when and if they reached
the Continental Shelf. It is unlikely that stocks would be adversely affected
by disposal operations.
Red crabs on the Continental Shelf/Slope break near the site represent a
potentially valuable resource which may be further exploited in the future.
However, no crabs of commercial size occur in the site, and the adult crabs
are taken sufficiently far from the site, so that wastes released at the site
are not likely to reach them.
Foreign ships fish along the edge of the entire Continental Shelf from
Georges Bank to Cape Hatteras, especially during the late winter and early
spring. However, the site is not a unique location for foreign fishermen, nor
does it obstruct migration routes of species valuable to foreign fishermen.
Therefore, the probability of foreign fish stocks being affected by disposal
operations at the site is extremely remote.
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Future oil and gas development is possible near the site, although
virtually no mid-Atlantic oil exploration occurs presently off the U.S. Outer
Continental Shelf. Waste disposal would not interfere with petroleum
exploration or production activities. The only potential navigational hazard
would result from barge traffic to and from the site.
LOGISTICS
Use of the 106-Mile Site presents some logistics problems. A distant
disposal site requires careful transport operation planning. Weather
conditions in the mid-Atlantic are subject to rapid change, and must be
carefully monitored for adequate passages to permit a barge or tanker to
complete transits in safety. Emergency discharge of wastes prior to reaching
the legal site (called "short dumping") becomes more likely in transit to a
distant site, as the length of time spent at sea increases.
The site is outside the heavily used transit lanes to New York Harbor, and
is convenient to the ports of New York, Philadelphia, and Baltimore. This
location has advantages over several existing nearshore New York Bight sites
which are near the entrance to New York Harbor, an area congested with ship
traffic of all types. Therefore, the dumping operation (which can take 5 to 6
hours) at the 106-Mile Site is less likely to impact other ship traffic
adversely.
USE OF ALTERNATIVE EXISTING SITES
Eight municipal and industrial waste disposal sites (aside from dredged
material sites and the proposed site) exist presently in the mid-Atlantic
(Figure 2-2): six in the New York Bight, and two near Delaware Bay. Two of
the sites discussed in this section have been used for industrial chemical
waste disposal (the New York Bight and Delaware Bay Acid Wastes Sites) and
were considered viable alternatives. The other existing sites were eliminated
from further consideration for several reasons:
• None of the sites has ever been used for industrial waste disposal.
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74'
4V
1. DREDGED MATERIAL
2. CELLAR DIRT
3. SEWAGE SLUDGE
4. ACID WASTES
5. SEWAGE SLUDGE
6 WRECKS
7. WOOD INCINERATION
8. CHEMICAL WASTES
9. ACID WASTES
10. SEWAGE SLUDGH
40°
39'
38'
41'
40*
39'
50
38'
75"
74'
72=
Figure 2-2. Existing Disposal Sites in the Mid-Atlantic
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• All of the sites are small and additional activity would create
logistics problems.
• The small size of the sites might preclude safe accommodation of
more waste material.
• The sites are all located close to shore in areas which are heavily
used for a wide variety of activities.
Consequently, most of the existing sites were eliminated from consideration
for dumping the industrial wastes presently permitted at the 106-Mile Site.
A discussion of the New York Bight and Delaware Bay Acid Wastes Disposal
Sites follows; these sites are individually compared with the 106-Mile Site.
NEW YORK BIGHT ACID WASTES DISPOSAL SITE
This disposal site was established in 1948 for the disposal of acid wastes
generated by industries in the New Jersey-New York areas (Figure 2-1). The
site is situated on the Continental Shelf 14.5 nmi (27 km) from the New Jersey
7 o
and Long Island coasts, and covers 12 nmi (41.2 km ). The site boundaries
are latitudes 40°16'N to 40°20'N, and longitudes 73°36'W to 73°40'W. The site
bottom is relatively flat, with an average depth of 25.6 m (b4 ft).
The primary waste dumper since the site was first established has been NL
Industries, Inc., which presently dumps about 95% of the site's total annual
volume. The only other active permittee is Allied Chemical Corporation. Du
Pont-Grasselli released some caustic wastes at this site until 1975, when the
disposal operation was moved to the 106-Mile Site.
The effects of waste disposal on the Bight Apex, including those at the
Acid Site, have been investigated extensively by the NOAA-Marine Ecosystems
Analysis Program (MESA) New York Bight Project, the NFMS-Sandy Hook Labora-
tory, and the permittees. The site environment, the history of waste disposal
at the site, and the primary waste constituents presently dumped there are
described in Chapter 3. Chapter 4 includes a description of the environmental
consequences of acid wastes disposal at this site.
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ENVIRONMENTAL ACCEPTABILITY
Several materials are present in wastes currently barged to the 106-Mile
Site which are not presently released at the Acid Site or at any other
location in the New York Bight Apex. These include nonpersistent organo-
phosphate pesticides; surfactants; and by-products from the manufacture of
rubber, mining, and papers, chemicals. Since such waste materials are not
known to be entering the Apex from other sources, if released at the Acid
Site they would represent an additional contaminant load on the environment of
that area.
Several waste constituents dumped at the 106-Mile Site are present in
wastes discharged at the Acid Site. Compared to the present mass loading of
wastes at the Acid Site, significant amounts of cadmium, mercury, oil and
grease, and petroleum hydrocarbons would be added by dumping 106-Mile Site
wastes at the Acid Site. However, additional loading of these contaminants at
the Acid Site would be a small fraction of the total amount of material
already flowing into the area from rivers and land discharges (Table 2-1).
The Acid Wastes Site is in relatively shallow water. Hence, the potential
for accumulation of waste constituents in shellfish and other organisms
marketed for human consumption exists, and would be aggravated by further
TABLE 2-1
COMPARISON OF CONTAMINANT INPUTS TO THE NEW YORK BIGHT, 1973
Contaminant
Cadmium
Mercury
Oil and Grease
Petroleum Hydrocarbons
(Metric Tons/Day)
All Sources
2.4
0.52
782.7
No Data
Acid Site
Permittees
0.001
0.02
0.1
0.08
106-Mile Site
Permittees
0.0003
0.0002
0.09
0.2
Source: Adapted from Mueller et al., 1976.
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waste discharges in the area. However, to date, benthic populations at the
Acid Site have not shown evidence of uptake as the site is presently used.
Additional discussion of this subject appears in Chapter 4.
Considering environmental acceptability, disposal at the New York Bight
Acid Wastes Site of wastes from the 106-Mile Site must be discouraged for
several reasons:
• Materials not presently entering the Bight Apex would be introduced,
thus possibly placing greater strain on a system which is already
impacted by man's wastes.
• Significantly greater amounts of waste constituents, which are
presently disposed of at the site, would be introduced.
• Some constituents of the wastes presently dumped at the deepwater
106-Mile Site, could adversely affect the bottom dwelling organisms
at the shallow Acid Site.
ENVIRONMENTAL MONITORING
The Bight Apex, including the Acid Site, is one of the most intensively
studied regions in the world. Beginning in 1973, the NOAA-MESA New York Bight
project has coordinated the study of all oceanographic disciplines within the
Bight and has provided data and guidance for environmental management
decisions (NOAA-MESA, 1977). Numerous other studies of the Acid Site
environment and the effects of waste disposal have continued since 1948
(Redfield and ttalford, 1951; Ketchum and Ford, 1948; Ketchum et al., 1958b,
1958c; Vaccaro et al., 1972). The current permittees, in compliance with
condition of their permits, are sponsoring a monitoring program to evaluate
the short-term effects of their waste discharges.
^
Relocating wastes from the 106-Mile Site to the New York Bight Acid Site
would cause difficulty in monitoring waste effects at the site. The three
decades of studies of the Acid Site provide an excellent historical baseline
for acid dumping, particularly by NL Industries. If subtle long-term changes
are taking place as a result of acid waste disposal, other waste discharges
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would complicate the use of the data base for detecting such changes.
Long-term environmental changes caused by acid dumping would be difficult, if
not impossible, to differentiate from impacts caused by the new waste
materials.
SURVEILLANCE
The Acid Site is adaptable to surveillance. The proximity of the site to
shore permits use of patrol vessels and aircraft to conduct surveillance and
record dumping vessel sightings, activities, and positions. Shipriders,
although effective as a means of surveillance, are rarely used at this site
because of the significant commitment of manpower and the adequacy of other
surveillance methods. Any additional surveillance, however, would require
additional operating hours, fuel, and man-hours.
ECONOMICS
Transportation Costs
The costs of barging wastes to the Acid Site are estimated to be in the
range of $0.90 to $2.50 per metric ton ($0.80 to $2.25 per ton). The total
cost of ocean disposal in 1978 for 106-Mile Site permittees leaving New York
Harbor (360,000 metric tons), would therefore have ranged from $324,000 to
$900,000 at the Acid Site. For permittees leaving Delaware Bay, the Acid Site
is about the same distance as the 106-Mile Site, and the barging costs would
not be significantly reduced by using the Acid Site instead of the 106-Mile
Site. Using the previously calculated costs for disposal at the 106-Mile Site
($8.80 to $11.00 per metric ton), the 1978 barging cost from Delaware Bay to
the Acid Site would have been in the range of $3.3 to $4.1 million. Thus, the
total annual transportation cost to the permittees barging from Delaware Bay
and New York Harbor would range from $3.6 to $5.0 million at the Acid Site.
In the future, this total cost would drop as some permittees phased out ocean
disposal; however, the cost to individual permittees would rise as a result of
inflation and increased fuel prices.
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Monitoring Costs
As previously noted, several groups are presently studying the effects of
waste disposal in the New York Bight Apex. Unlike the permittees' programs,
the other monitoring programs are not specifically oriented to evaluating the
effects of acid waste disposal. However, if new wastes were released at the
site, NOAA and EPA programs would probably conduct special studies at the
site. New permittees would be required to conduct dispersion studies and
participate in an existing monitoring program to evaluate short-term effects
of waste. Since other types of wastes are released at the site, a rigorous
monitoring program would be required to distinguish the effects of the new
chemical wastes from the effects of acid wastes presently permitted at the
site.
The cost of monitoring at this site cannot be reliably estimated. Although
the site is shallow and located close to shore, the costs would still probably
be substantial. The Bight Apex has numerous sources of contaminants, and
other waste types are released at the site; consequently, a substantial effort
would be required to evaluate the effects of new wastes. The cost would be
borne by the permittees, in determining waste dispersion and short-term
effects, and the Federal government, in investigating trends and chronic,
long-term effects.
Surveillance Costs
The cost of surveillance for additional waste disposal operations in the
Bight Apex would be relatively low. The site is well within the normal range
of Coast Guard ships and aircraft, and surveillance is routinely carried out
for the permittees now using disposal sites in the Bight; however, additional
surveillance would require additional operating hours, fuel, and man-hours.
Loss of Biotic and Mineral Resources
Except for whiting, the most valuable commercial fish and shellfish taken
in the New York Bight are either not present near the site, would not be
affected by the chemical waste, or have been contaminated by other pollutants.
2-16
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Disposal of additional chemical wastes at this site would threaten the
commercial whiting fishery near the site during the late autumn and winter.
No dollar value can be estimated accurately on these resources since the
magnitude of the fishing effort near the site is unknown.
More important, the Bight Apex is a highly stressed ecosystem (NOAA-MESA,
1978), and adding new contaminants would increase the stress. Since other
disposal sites are nearby, interactions between different waste types could
cause unpredictable adverse effects on the ecosystem. It does not appear that
fishery resources, in addition to these already mentioned, would be
threatened; however, the possibility of a significant, deleterious change in
the total Bight environment would exist with additional waste loading at the
site.
Acid-iron wastes released presently at the Acid Site have been reported to
attract bluefish (a popular sport fish) and, during spring and summer, the
area is a popular fishing ground (Westman, 1958). If bluefish are, in fact,
attracted to the site, the release of additional wastes could cause several
problems: (1) fishermen might avoid the area because of the increased barge
traffic and the presence of wastes which are perceived as more toxic than
those currently permitted at the site; (2) the fish might no longer
concentrate in the area; or (3) the fish might accumulate contaminants from
the new wastes, causing the area to be closed to fishing to protect public
health. The loss of this fishing area would cause significant economic impact
on the charter and party fishing boats which presently use the area.
Potential mineral resources in the Bight Apex have been contaminated by other
pollutant sources, therefore there would probably be no additional loss from
additional industrial wastes.
LOGISTICS
The present permittees using the New York Bight Acid Wastes Site and the
106-Mile Site barge wastes approximately once daily. Use of the Acid Site for
the wastes presently being dumped at the 106-Mile Site would double the
disposal activity at the Acid Site, thereby increasing the navigational
2-17
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hazards to waste disposal vessels and other shipping, since the site is
situated across the outbound lane and separation zone of the Ambrose-Hudson
Canyon Traffic Lane. (See Chapter 3, Figure 3-10.)
OVERALL COMPARISON WITH THE 106-MILE SITE
Permitting 106-Mile Site industrial permittees to use the New York Bight
Acid Wastes Site instead of the 106-Mile Site would result in decreased
transportation costs for most dumpers, easier surveillance of the disposal
operations, and, possibly, a greater ease of monitoring total impacts.
However, the ability to monitor the specific impacts of the existing wastes
released at the site would be degraded, and there would be a significantly
increased shipping hazard. Most important, contaminants not presently dumped
in the Bight Apex would be discharged, and these wastes could cause additional
damage to an already highly stressed ecosystem. Therefore, this alternative
is rejected in favor of the 106-Mile Site'.
DELAWARE BAY ACID WASTE DISPOSAL SITE
This interim disposal site, centered approximately 35 nmi (65 km) southeast
of Cape Henlopen, Delaware, is bounded by latitudes 38°30'N and 38°35'N, and
longitudes 75°15'W and 74°25'W (Figure 2-1). It encompasses a rectangular
2 2
area of about 51 nmi (175 km ), with depths of water ranging from 38 to 45 m
(125 to 150 ft). The Philadelphia Sewage Sludge Site is 5 nmi (9 km)
southeast of the site.
Du Pont-Edge Moor dumped acid-iron waste at this site from 1969 to 1977,
when the operation was moved, at Du Font's request, to the 106-Mile Site.
During this period, the Edge Moor plant's titanium dioxide manufacturing
process changed from a sulfate process to a chloride process, producing
different acid wastes.
Du Pont sponsored several monitoring surveys at the site between 1969 and
1971. In 1973, EPA Region III initiated a monitoring program at the site and
the nearby sewage sludge site. EPA still maintains historical stations in and
around the site which are sampled twice yearly to monitor the site's recovery
2-18
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towards natural conditions. Since September 1979, EPA and NOAA jointly
monitor the acid waste and sewage sludge disposal sites.
ENVIRONMENTAL ACCEPTABILITY
Use of the Delaware Bay Acid Waste Site for disposal of wastes presently
dumped at the 106-Mile Site would not be environmentally acceptable.
Industrial wastes dumped at this shallow site could reach the seafloor which
is inhabited by potentially valuable fishery resources (primarily surf clams",
ocean quahogs, and scallops). However, the area is presently closed to some
shell fishing because of the threat of bacterial contamination from the nearby
sewage sludge disposal site. Past studies on benthic organisms from the
vicinity of the Acid Site reported uptake of vanadium in scallops from the
area. The acid waste dumped at the time of the study contained large amounts
of vanadium, whereas the sewage sludge dumped nearby contained significantly
lesser amounts of this metal. A link between the elevated vanadium
concentrations in tissues and the acid waste was not clearly established;
however, renewed industrial waste disposal at the site is not prudent in light
of this observation.
Use of the Acid Site for industrial waste disposal, instead of the 106-Mile
Site, would require transit by dump vessels from New York Harbor along the
coast of New Jersey. Any emergency short dumping along this route could cause
health hazards to beaches, coastal industry, or the extensive commercial and
recreational fishing along this coast.
ENVIRONMENTAL MONITORING
Several years of background environmental data exist at the Delaware Bay
Acid Waste Site. Pre-dumping surveys provide a marginal basis for comparison
with post-dumping surveys, primarily because the latter work was much more
extensive and more quantitative. However, there are enough data from the area
to provide the basis for comparison.
Monitoring of the Delaware Bay Acid Waste Site would be complicated by the
proximity of the Philadelphia Sewage Sludge Site. The primary net water
2-19
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movement in the area is to the southwest; however, storms may affect the
direction of water movement, causing water from the vicinity of the sewage
sludge site to migrate northward. Therefore, it would be difficult to
differentiate the effects of proposed industrial waste disposal, and previous
acid waste disposal, from that of municipal waste disposal.
SURVEILLANCE
Since the Delaware Bay Acid Waste Site is presently inactive, USCG surveil-
lance activities in the vicinity involve only the nearby sewage sludge site.
The current USCG policy is to monitor 10% of the sludge disposal operations,
and 75% of the industrial waste discharges. Therefore, a substantial increase
in surveillance activities would be necessary if the Acid Site were
reactivated for industrial waste disposal. However the increase in
surveillance at the Acid Site would incur a decrease in surveillance at the
106-Mile Site.
ECONOMICS
Transportation Costs
The site is close to Delaware Bay, thus the hauling costs for vessels
leaving New York Harbor will be significantly higher than for vessels
from Delaware' Bay. The site is about the same distance from New York as the
106-Mile Site, and the annual barging costs for dumpers in the New York area
will probably be about the same - $8.80 to $11.00 per metric ton, or $3.2 to
$4.0 million. The round trip would take between 54 and 72 hours (average
speed 5 to 7 kn) through the coastal waters off New Jersey. The cost would be
much less for vessels coming from Delaware Bay. Based upon the respective
distances to the Acid Site and the 106-Mile Site, barging costs would be from
$2.20 to $2.75 per metric ton, or $0.8 to $1.0 million annually. Thus, the
annual total transport cost for this site would be about $4.0 to $5.0 million.
The total cost of disposal at the site would decrease as some permittees
phased out ocean dumping; however, the costs to individual permittees would
rise as a result of inflation and increased fuel prices.
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Monitoring Costs
The monitoring cost for the Delaware Bay Acid Waste Site is difficult to
estimate, but would probably be lower than the cost of monitoring the 106-Mile
Site. Effects of industrial wastes on the environment would have to be
separated from the effects of nearby sewage sludge disposal and from the
effects of water flowing out of Delaware Bay. EPA Region III and NOAA are
currently jointly monitoring the sewage sludge site, and these surveys could
be expanded at an additional cost to evaluate long-term effects of industrial
waste disposal. Since the site was used until 1977, and was surveyed several
times, sufficient data exist to recognize long-term environmental changes;
extensive additional surveys would not be required.
Surveillance Costs
The Delaware Bay Acid Waste Site is near the limits of the range for Coast
Guard ships and aircraft normally used for ocean dumping surveillance.
Surveillance would require shipriders on some of the disposal vessels.
Loss of Biotic or Mineral Resources
Commercial surf clam beds exist in the vicinity of the Delaware Bay Acid
Waste Site, but not close enough to be adversely affected by industrial waste
disposal. Other shellfish, such as sea scallops and ocean quahogs, are
abundant in the area, and scallops are presently being harvested. The site is
sufficiently shallow, so that wastes could reach the bottom, perhaps
contaminating these shellfish. At this time, the site is still closed to
shell fishing by FDA because of the proximity of the sewage sludge site.
Mineral resources are not present at the site. Industrial waste disposal
at this site would not interfere with oil and gas exploration and development
east of the area.
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LOGISTICS
The Delaware Bay Acid Waste Site is outside major shipping lanes, and daily
use, if maintained at the level occurring presently at the 106-Mile Site,
would present few, if any, navigational hazards to the dumping vessels within
the site. However, the site's great distance from New York Harbor would
necessitate careful planning and scheduling of trips.
OVERALL COMPARISON WITH THE 106-MILE SITE
The Delaware Bay Acid Waste Site is more convenient to one of the
permittees using the 106-Mile Site, but little economic advantage would be
gained by moving waste disposal operations from the 106-Mile Site to this
location. The risks associated with renewed industrial waste discharges at
the Acid Site and the possible adverse impact on potential fishery resources
in the area make this alternative less preferable than continued use of the
106-Mile Site.
USE OF NEW SITES
New sites on or beyond the Continental Shelf (Figure 2-1) provide alterna-
tives to disposal at the 106-Mile Site. Sites in the New York Bight and over
the Continental Slope along the eastern edge of the Bight were considered. A
new site for ocean dumping must meet the site selection criteria in Part 228
of the Ocean Dumping Regulations. The site must not conflict with other uses
of the area, such as resource development or commercial fisheries, nor
endanger human health or amenities, and should be located within the range of
the current fleet of waste disposal vessels in order to make ocean disposal
economically feasible.
LOCATIONS ON THE CONTINENTAL SHELF
The New York Bight is one of the busiest oceanic regions in the world; uses
include extensive commercial shipping, fishing, shellfishing, recreation,
resource development, and waste disposal. In selecting a site within the
2-22
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Bight for ocean waste disposal, other conflicting activities in the area were
evaluated for potential effects on disposal operations and vice versa.
Additionally, adequate background environmental information on the area must
presently exist to provide firm bases for projecting impacts of waste
disposal.
Most of the survey work in the Bight has centered around existing disposal
sites. However, two candidate areas for sewage sludge disposal have been
studied extensively: the so-called Northern and Southern Areas (Figure 2-1).
These areas were selected for study by NOAA, in part to avoid conflict with
living marine resources (NOAA-MESA, 1976) and, therefore, were concluded to be
the most reasonable new candidate locations for industrial waste disposal.
Within the large areas suggested by NOAA for consideration, two smaller areas
were studied in detail, the Northern and Southern Areas discussed below.
SOUTHERN AREA
The Southern Area (Figure 2-1) is square, centered at latitude 39°41'N and
2 9
73°18'W, with an area of 144 nmi (484 km ). The average water depth in the
area is 40 m (130 ft) .
Environmental Acceptability
The Southern Area contains presently and potentially valuable commercial
fishery resources. The surf clam, sea scallop, and ocean quahog are often
found in numbers suitable for commercial harvesting. Therefore, there exists
significant risk in using the Southern Area to dispose of industrial wastes,
since they contain elements which could be assimilated by organisms.
Environmental Monitoring
Due to the existence of the NOAA data base on predisposal conditions in the
Southern Area, monitoring would be feasible. This site is outside the heavily
contaminated Bight Apex, thus monitored waste disposal impacts at the site
would not be confused with contaminants from other sources.
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Surveillance
The Southern Area is outside the range of USCG patrol vessels and aircraft
normally used for ocean dumping surveillance, therefore shipriders would be
required. This would not result in a much shorter transit time arid fewer
shiprider hours per trip than surveillance at the 106-Mile Site.
Economics
Transportation Costs - The costs of transporting wastes to the Southern
Area would be intermediate between those for a nearshore site and one beyond
the Continental Shelf. The estimated barging costs for vessels leaving New
York Harbor for the Southern Area would be $2.70 to $10.00 per metric ton, or
$1.0 to $3.6 million annually. A round trip would take from 38 to 44 hours
(average speed from 5 to 7 kn) through the coastal waters off New Jersey.
Permittees' barging costs from Delaware Bay would probably be about
three-quarters of the cost of barging to the 106-Mile Site (based on the
distances to the respective sites), i.e., $6.60 to $8.25 per metric ton, or
from $2.4 to $3.1 million annually. The travel time would be 38 to 48 hours
(average speed from 5 to 7 kn).
The total annual transportation cost for all waste disposal at the Southern
Area would range from $3.4 to $6.7 million. The total cost of waste disposal
at the site would decrease as some permittees phased out ocean dumping;
however, the costs to individual permittees would rise as a result of
inflation and increased fuel prices.
Monitoring Costs - Monitoring costs at the Southern Area would probably be
lower than at either a nearshore or an off-Shelf site. Since NOAA has
completed predisposal studies in the area (NOAA-MESA, 1976), and other
contaminants are not present, monitoring would be fairly uncomplicated.
Surveillance Costs - The site is outside the range of Coast Guard ships and
aircraft normally used for ocean dumping surveillance; therefore, surveillance
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of actual ocean disposal operations would require shipriders. Surveillance of
this site would require fewer man-hours, since the transit time is less than
that required for the 106-Mile Site.
Loss of Biotic or Mineral Resources - Biological and mineral resources
exist near the Southern Area. The potential loss of the former could be sub-
stantial. Economically important finfish (sculpin and whiting) and shellfish
(lobster, surf clams, scallops, and ocean quahogs) inhabit the area. Since
the area is in shallow water, wastes may reach the bottom and shellfish may be
contaminated. Finfish may either avoid the area or accumulate contaminants
from wastes. Thus, use of this location for industrial waste disposal could
cause a significant adverse economic impact on living resources, although the
impact could not be reliably estimated because the actual amount of fish and
shellfish taken from the area is unknown.
Use of the Southern Area for industrial waste disposal would not be
expected to affect nearby mineral resource development.
Logistics
Navigation of dump vessels in this location might be complicated by traffic
(e.g., work boats, supply ships, oil tankers) associated with development of
nearby oil and gas lease tracts (see Chapter 3, Figure 3-3). The likelihood
of these hazards occurring would depend upon the speed and scope of oil and
gas development in the area and upon the magnitude of ocean dumping at the
site.
Overall Comparison with the 106-Mile Site
Waste disposal in the Southern Area would present some advantages over the
106-Mile Site, mainly in the ease of monitoring the site and in reduced
transportation costs. However, the existence of a fishery resource in the
area, the possibility of adversely affecting that resource, and the economic
consequences of such an impact, make this alternative less favorable when
compared to the 106-Mile Site.
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NORTHERN AREA
The Northern Area (Figure 2-1) is a rectangle centered at approximately
latitude 40°10'N and longitude 72°46.5'W, comprising 224 nmi2 (770 km2).
Water depths in the area average 55 m (180 ft). The inactive Alternate Sewage
Sludge Disposal Site is within the Northern Area at latitudes 40°10.5'N to
40°13.5'N, and longitudes 72°40.5'W to 72°43.5'W, comprising an area of 9 nmi2
(31 km2).
Environmental Acceptability
Although the Northern Area is not known to be fished, it contains sea
scallops and ocean quahogs which may be caught in the future. The shallowness
of the site makes bottom effects from waste disposal possible, and there are
slight to moderate possibilities of modifying the benthic community of the
area, and/or bioaccumulation of contaminants in benthic organisms.
Environmental Monitoring
An adequate data base on predisposal conditions at this site exists for
monitoring. Possible sewage sludge dumping near one edge of the study area
could complicate the differentiation of industrial waste effects from sludge
effects.
Surveillance
The Northern Area is outside the range of USCG patrol vessels and aircraft
normally used for ocean dumping surveillance, thus shipriders would be
required for surveillance. Surveillance at the Northern Area would require
fewer shiprider hours per trip than for surveillance of the 106-Mile Site
since the transit time to the Northern Area is less.
Economics
Transportation Costs - Transportation costs for the Northern Area are
similar to those for the Southern Area. The costs for hauling waste material
2-26
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to this site would be intermediate between those for a nearshore site and
those for an off-Shelf site. Estimated barging costs for vessels leaving New
York Harbor are $3.60 to $7.50 per metric ton, or $1.3 to $2.7 million
annually. A round trip would take between 38 and 44 hours (average speed 5 or
7 kn), through the coastal waters off Long Island.
The cost to permittees barging from Delaware Bay would be about the same as
present transportation costs for ocean disposal at the 106-Mile Site, since
the Northern Area is about the same distance from the mouth of the Bay as the
existing site. Thus, the estimated cost per metric ton would be $8.80 to
$11.00, or $3.3 to $4.1 million annually. A round trip would take 54 to
72 hours.
Total annual transportation costs of all waste disposal at this site would
be from $4.6 to $6.8 million - slightly greater than costs for the Southern
Area. Total cost would decrease as some permittees phased out ocean disposal,
although the costs to individual permittees would rise as a result of
inflation and increased fuel prices.
Monitoring Costs - Monitoring costs for the Northern Area would probably be
similar to those for the Southern Area and less than those for a site off the
Shelf or a nearshore site with other sources of contaminants nearby.
Surveillance Costs - The site is outside the range of Coast Guard ships and
aircraft normally used in ocean dumping surveillance, thus surveillance of
actual disposal operations would require shipriders. However, surveillance of
this area would require fewer man-hours per mission than for the 106-Mile
Site.
Loss of Biotic or Mineral Resources - The Northern Area is within the
normal range of surf clams, but they are not abundant at the site. Ocean
quahogs and sea scallops are abundant, and industrial waste disposal could
possibly impact the development of these potentially valuable crops by
affecting populations or by providing contaminants for uptake by the
organisms .
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Ocean disposal in the Northern Area would not interfere with the
development of mineral resources. The site is approximately 60 nmi (110 km)
northeast of the oil and gas lease tracts identified on the mid-Atlantic Shelf
(see Chapter 3, Figure 3-3). Industrial waste disposal would not interfere
with exploration or development of the oil and gas reserves which are presumed
to occur in the vicinity of the Southern Area.
Logistics
No significant logistics problems would be expected in using the Northern
Area for industrial waste disposal unless the Alternate Sewage Sludge Site
was activated. The large volume of sludge that is presently dumped in the
Bight requires a steady sequence of trips to the 12-Mile Site. If sewage
sludge disposal operations were transferred to the Alternate Site,
barge/vessel traffic in the Northern Area would increase. Thus use of this
area for sludge disposal and industrial waste disposal would present problems
in scheduling and navigation.
Overall Comparison to the 106-Mile Site
Use of the Northern Area for industrial waste disposal would have an
economic advantage over the 106-Mile Site in transportation costs. However
potential sludge disposal at the Alternative Sewage Sludge Site in addition to
industrial waste disposal would create monitoring and logistics difficulties.
Lastly, the Northern Area would not be environmentally favorable over the
106-Mile Site because of the presence of a potential shellfish resource which
could be adversely affected by industrial waste disposal.
LOCATIONS OFF THE CONTINENTAL SHELF
Information on the mid-Atlantic Continental Slope and Continental Rise is
generally lacking except for the vicinity of the 106-Mile Site (TRIGOM, 1976).
The 106-Mile Site is the closest point to New York Harbor beyond the
Continental Shelf (Figure 2-1). Hudson Canyon is immediately north of the
site, and is believed to be a major migratory route for fish entering the New
York Bight. Waste disposal near the Canyon would be environmentally
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unacceptable primarily because migrating organisms could accumulate toxic
constituents from the waste, presenting a potential health hazard to humans
consuming the contaminated animals. The environment immediately southwest of
the 106-Mile Site along the Continental Slope is unknown. Designating a site
for waste disposal in that area would require extensive baseline survey work.
There are no data indicating that the 106-Mile Site is over or near a
unique portion of the Slope or Rise. The same physical processes affect this
entire region and the benthos is uniform over large horizontal distances at
these depths. Other localities, farther northeast or south of the 106-Mile
Site, would add considerably to round-trip distances to the site without any
clear environmental benefit. The increased travel time raises the probability
of emergencies occurring, which could result in short dumps.
OVERALL COMPARISON WITH THE 106-MILE SITE
The 106-Mile Site is clearly the best alternative for an ocean waste
disposal site beyond the Continental Shelf for a number of reasons. Unlike
other areas off the mid-Atlantic Continental Shelf, the 106-Mile Site has been
studied extensively, so more information exists for projecting impacts of
disposal activities. Use of any other Continental Slope area would require
extensive survey work to produce the quantity of data presently available for
the 106-Mile Site. The site is over that portion of the Continental Slope
closest to New York Harbor (Figure 2-1), and thus is the Continental Slope
location most convenient to potential users of an off-Shelf site. In
conclusion, no advantage would be gained by favoring another off-Shelf
location over the 106-Mile Site.
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SUMMARY
Several alternative locations on and off the Continental Shelf were
evaluated as potential industrial waste disposal sites. A number of features
of the 106-Mile Site make it the best choice among the alternatives examined:
The site is in deep water, so dilution and dispersion of introduced
wastes are enhanced.
The site is not in an area of significant commercial or recreational
fishing or shell fishing.
The site is convenient to the major ports in the Middle Atlantic
states.
The site conforms with the MPRSA directive to locate ocean disposal
off the Continental Shelf whenever feasible.
The site has been studied extensively for many years.
Only limited adverse environmental impacts of waste disposal have
been demonstrated at the site.
Thus, in considering all reasonable alternatives to the proposed action,
the proposal of designating the 106-Mile Ocean Waste Disposal Site for
continued use is the most favorable alternative for the foreseeable future.
There are risks involved in this action (discussed in detail in Chapter 4);
however, the environmental risk of waste disposal at this site is judged to be
less serious than the risk of disposing of these industrial wastes at
locations on the Continental Shelf or at other locations the Continental Slope
or Continental Rise. If subsequent monitoring at the site shows negative
impacts resulting from waste disposal to be greater than anticipated, EPA may
discontinue or modify use of the site, in accordance with Section 228.11 of
the Ocean Dumping Regulations.
Table 2-2 presents the comparative evaluation of the possible effects of
industrial wastes at the alternative sites discussed in this chapter. The
effects on environmental acceptability, environmental monitoring, surveil-
lance, economics, and logistics are summarized.
2-30
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TABLE 2-2
SUMMARY COMPARATIVE EVALUATION OF ALTERNATIVE
TOXIC CHEMICAL WASTE DISPOSAL SITES
ho
I
OJ
CRITERIA
ENVIRONMENTAL ACCEPTABILITY
IMPACTS ON PUBLIC HEALTH
Commercial Fish and
Shellfish
Uec rea tion.n 1 Fish and
Shellfish
Navi gationnl Hazards
IMPACTS ON THE ECOSYSTEM
Plankton
106-MILE SITE
Extremely st ight
potential for
adversely affecting
public health from
to si te . Very si ight
potential for long-
term impacts on eco-
Nont! to very si ight
potential for adverse
impacts.
No potential for con-
sumption of contam-
inated fish or shell-
fish as commercia 1
fishing is not concen-
trated in this region.
Mo potential adverse
site is beyond the
normal range of recre-
ational fisherman.
Very si ight risk
because of the. great
distance to the site.
Ve ry s 1 i gli t po t en t i a 1
Ve ry s 1 i gh t shor t -
term effects. None
lo verv si ( ght
potential for accu-
i nants .
NEW YORK BIGHT
ACID WASTES SITE
potent i al for adverse
impact s on pub I ic
heal Lh because the
areas of coramerc i al
and recreat ional fish-
ing and heavy ship
traffic. Very si ight
to moderate potential
for long-term impacts
on the ecosystem.
potential for adverse
impacts .
Moderate potential for
con sump t ion of contam-
inated fish or shell-
fish.
Moderate potential for
adverse short and long-
term effects .
Severe risk because
the site is smal I ,
located close to shore,
and located within
the central traffic
lane to New York
Harbor.
Very slight to moder-
ad verse impacts.
SI ight short-term
adverse effects when
the wastes are
accumu lation of con-
taminants due to
sources .
DELAWARE BAY
ACID WASTE SITE
Very slight to moderate
potent ial for adversely
affect ing fishing from
transit to the site,
and from on-site
disposal ope rat ions.
Slight to moderate
potent ial for long-
term impacts on the
ecosystem.
Very slight to moderate
potential for adverse
impact s .
Moderate potential for
consumption of contam-
inated fish or shell-
fish as commercially
abundant resources
exist near the site .
None to very s Light
potential for adverse
effects as the area
is beyond the normal
range of most fishing.
Slight, risk because
barge traffic must
travel down the coast
of New Jersey and an
accident could occur
near f i shing grounds .
Very slight to moder-
ate potential for
adverse impacts .
Slight short-term
adverse effects when
the wastes are
released, with poten-
tial of some accumu-
lation of con t ami -
nants .
NORTHERN
AREA
None to very slight
potent ial for adverse
impacts on fishing.
Very slight to si ight
potential for long-
term impac t s on the
ecosystem.
None to very slight
potential for adverse
impacts .
Low potential for
consumption of contam-
inated fish or shell-
fish as the area does
not have commercially
abundant fish and
shellfish.
None to very slight
potential for adverse
effects since the
area is beyond the
norma 1 range of most
recreational fishing.
No anticipated risk.
Very slight to slight
impacts .
Slight short-term
adverse effects when
the wastes are
released with poten-
tial of some accumu-
lation of contam-
inants.
SOUTHERN
AREA
Very slight to moder-
ate potential for
adverse impacts on
public health. Very
slight to slight poten-
tial for adverse long-
term impacts on the
ecosystem.
Very slight to moder-
ate potential for
adverse impacts .
Moderate potential
for consumption of
contaminated fish or
shellfish as commer-
cially exploitable
shellfish exist in
the area.
None to very si ight
potential for adverse
effects as the area
is beyond the normal
range of most recrea-
tional fishing.
Slight risk because
barges must transit
through fishing
areas.
Very slight to slight
impacts .
Slight short-term
adverse effects when
the wastes are
released with poten-
tial of some accumu-
lation of contam-
inants .
-------
TABLE 2-2 (Continued)
10
to
CRITERIA
Nt-kton
Bontlms
Water Qual ity
Sod i merit Qua I ity
Short Dumping
ENVIRONMENTAL MONITORING
106-MILE SITE
Very si ight potent ia I
for accumulat ion of
contaminants .
No potenti al for
adverse effects
because of adequate-
waste di 1 ut ion .
Slight rise in
concentration when
wastes released , with
very si ight potential
for longer term mod-
ification of ambient
levels.
No potential for
adverse effect s .
Slight potential for
emergency because of
ex t reme round -trip
distance to site. No
significant threat to
at" ional fisheries .
Some difficulty in
eftects of waste since
the site is so far
from shore. Moderate to
severe difficulties in
trends as site's env i-
ronmenL is complex .
Data base is large
and expanding.
NEW YORK BIGHT
ACID WASTES SITE
Very slight potentia I
for accumulation of
contaminants .
Moderate potentia 1 for
adverse effects. Dif-
ficult to differentiate
from adverse effects
of other nearby
dumping.
Slight rise in concen-
tration when wastes
re leased , wi th ve ry
slight potential for
longer term modifi-
cation of ambient
level s .
adverse effects. Dif-
ficult to differentiate
from adverse effects
of other nearby
dumping.
Very si ight potentia I
for emergency since
site is so close to
sli o re .
No difficulty in
effects of waste.
Severe difficulties in
detecting long-term
trends as other permit-
other contaminant
inputs would mask this
waste . Monitoring
is compl icated by
close proximity of
other disposal sites.
DELAWARE BAY
ACID WASTE SITE
Ve r y s i i gh t po t e n t i a 1
for accumulation of
contaminants.
Moderate potenti a 1 for
adverse effects .
Slight rise in concen-
tration when wastes
released , with very
slight potential for
longer term modifi-
cation of ambient
levels.
Moderate potential for
long-term accumu la-
tion .
Slight potential for
emergency because of
extreme round- tri p
di stance to site.
Severe potentia 1 threat
to commerc ia 1 and
recreational fisheries.
No difficulty in moni-
effects of waste.
Moderate difficulties
in detecting long-term
trends since the site
another disposal site
is nearby.
NORTHERN
AREA
Ve r y s 1 i gh t po t en t i a 1
for accumulation of
Slight to moderate
potential for adverse
effects.
Slight rise in concen-
tration when wastes
released, with very
slight potential for
longer term modifi-
cation of ambient
levels .
Slight to moderate
potential for long-
term accumulation .
Slight potential for
emergency .
No di f f iculty in
monitoring short-term
effects of waste .
Slight difficulties in
detect ing long-terra
pi icated if the alter-
nate sewage s ludge site
is act ivated .
SOUTHERN
AREA
Very slight potential
for accumulation ot"
contaminants .
Slight to moderate
potential for adverse
effects.
Slight rise in concen-
tration when wastes
released , wi th vtry
slight potential for
longer term modifi-
cation of ambient
levels.
Slight to moderate
potential for long-
term accumulation.
Slight potential for
emergency.
No difficulty in
monitoring short-term
effects of waste .
Slight difficulties
in detecting long-
-------
TABLE 2-2 (Continued)
CRITERIA
SURVEILLANCE
ECONOMICS
Transport , -it ion Costs
(. \ nc 1 . t-nergy costs)
Monitoring Costs
Surve i 1 1 ance Cost s
Loss of Mineral Resources
LOGISTICS
106-MILE SITE
Sli i p riders required .
portaLion mid moni-
toring. No conflict
with otlicr uses of
the area .
Estimated to be $8.80
to $11 .00 per metric
ton.
Directly related to
d i f f iculty of mon itor-
ing. No dollar value
aval Lable .
Expensive unless ODSS
is implemented since
area is outside nor-
mal Coast Guard patrol
ranges .
of re so u re e since po p-
ulations are not cx-
tial of interference
with a lobster or red
crab fishery.
No conflict.
Moderate scliedu 1 ing
and operational dif-
ficulties because of
extreme distance to
site. No conflicts
wi tli shipping .
NEW YORK BIGHT
ACID WASTES SITE
Witliin the range of
convent la 1 survei t lance
by aircraft and vessels.
tation and surveil-
lance. SI ight possi-
bility of adversely
affecting f t shery
resource.
Estimated to be $0.90
to $2.50 per metric
ton .
Directly re la ted to
difficulty of monitor-
Ing. No dollar value
aval lable .
No exceptional expense
as many disposal oper-
ations in the area
undergo routine survei 1-
lance.
Slight potential for
loss of sign i f icant
portion of recre-
No conflict.
Some conflict with
other shipping
because the site is
located in a traffic
zone.
DELAWARE BAY
ACID WASTE SITE
Sliipri tiers required .
Hi gh cost of trans-
portation . Slight pos-
sibility of adversely
a f fee ting fishery
resources .
Estimated to be $8.80 to
$11.00 per metric ton
from New York Harbor.
Direct ly related to
difficulty of moni-
toring. No dollar va lue
avai lable .
Expensive unless ODSS
is implemented . Some
mitigation of expense
due to other site in
area .
Slight potential for
loss of future com-
mercia 1 shellfish
resource .
No conflict.
Moderate scheduling
and operational dif-
of distance from New
York Harbor. No con-
flicts with shipping
near site.
NORTHERN
AREA
Shipriders required.
Moderate transportation
cost. Slight potential
for adversely affecting
future fishery resource .
Estimated to be $3.60
to $7.50 per metric ton
from New York Harbor.
Direct ly related to
difficulty of moni-
toring. No dollar
value available.
Expensive unless ODSS
is implemented as area
is outside normal
Coast Guard patrol
ranges.
None to very slight
potential for loss
of future resource.
No conflict.
No conflict with
shipping.
SOUTHERN
AREA
Shipriders required.
Moderate transpor-
tation cost. Slight
affecting present
fishery resources.
Estimated to be $2.70
to $10.00 per metric
ported from New York
Harbor.
Directly related to
difficulty of moni-
toring. No dollar
value available .
Expensive unless ODSS
is implemented as area
i s ou t s i de no rma 1
Coast Guard patrol
ranges.
Slight potential for
adverse effects on
resources and very
slight potential for
loss of significant
Possible very slight
conflict.
Very slight potential
conflict with oil and
gas development.
ro
(^>
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BASES FOR SELECTION OF THE PROPOSED SITE
Part 228 of the Ocean Dumping Regulations and Criteria describes general
and specific criteria for selection of sites to be used for ocean waste
disposal. In brief, the general criteria state that site locations will be
chosen:
"...to minimize the interference of disposal activities
with other activities in the marine environment..."
"...[so] temporary perturbations in water quality or
other environmental conditions during initial
mixing...can be expected to be reduced to normal ambient
seawater levels or to undetectable contaminant
concentrations or effects before reaching any beach,
shoreline, marine sanctuary, or known geographically
limited fishery or shellfishery."
"[site sizes] will be limited in order to localize for
identification and control any immediate adverse impacts
and permit the implementation of effective monitoring and
surveillance programs to prevent adverse long-range
impacts."
"EPA will, whenever feasible, designate ocean dumping
sites beyond the edge of the continental shelf and other
such sites that have been historically used."
The 106-Mile Ocean Waste Disposal Site complies with all of the above
criteria.
Eleven specific site selection criteria are presented in Section 228.6 of
the Ocean Dumping Regulations. The following discussion consolidates the
information for the 106-Mile Site, demonstrating the site's compliance with
the site selection criteria. Additional information is provided in Chapter 3
(Affected Environment) and Chapter 4 (Environmental Consequences).
GEOGRAPHICAL POSITION, DEPTH OF WATER,
BOTTOM TOPOGRAPHY AND DISTANCE FROM COAST
The 106-Mile Site is beyond the mid-Atlantic Continental Shelf, over
portions of the Continental Slope and Continental Rise (Figure 2-1). Its
2-34
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coordinates are latitudes 38°40'N to 39°00'N and longitudes 72°00'W to
72°30'W. Water depths at the site range from 1,440 m (in the topographically
rugged northwest corner) to 2,750 m (in the relatively flat southeast corner).
The nearest point of land is the. New Jersey coast north of Cape May, located
approximately 90 nmi (170 km) from the northwest corner of the site.
LOCATION IN RELATION TO BREEDING. SPAWNING, NURSERY, FEEDING.
OR PASSAGE AREAS OF LIVING RESOURCES IN ADULT OR JUVENILE PHASES
All of these activities occur in some measure within the oceanic region
along the Shelf break which contains the 106-Mile Site; however, no feature of
the life history of valuable organisms is known to be unique to the 106-Mile
Site or its vicinity.
Rare or endangered species may be present occasionally at the 106-Mile
Site. However, the site is not a concentration point for these animals, which
are migratory and would be present for only a few hours. Turtles (e.g.,
hawksbill and leatherback) and whales (e.g., sperm and right) may occasionally
pass through the site. The possibility that these animals would be affected
by a waste disposal operation is remote. Rare or endangered birds are not
present at the site (Gusey, 1976).
LOCATION IN RELATION TO BEACHES AND OTHER AMENITY AREAS
The site is 90 nmi (170 km) from the nearest point of land, the coast of
New Jersey. This distance is adequate to provide for extensive dilution and
dispersion of wastes before reaching shore. Therefore, use of the site should
not impinge on recreation, coastal development, or any other amenities along
the shoreline.
TYPES AND QUANTITIES OF WASTES PROPOSED TO BE DISPOSED OF, AND PROPOSED
METHODS OF RELEASE. INCLUDING METHODS OF PACKING THE WASTE, IF ANY
Wastes to be disposed of at the site must meet the EPA environmental impact
criteria outlined in Part 227, Subparts B, D, and E of the Ocean Dumping
Regulations, or, as in the cases of some of the present permittees using the
2-35
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site, dumping of wastes not complying with the impact criteria must be phased
out by December 31, 1981. In all cases, a need for ocean dumping must be
demonstrated in accordance with Subpart C. Upon site designation, types and
quantities of wastes presently dumped will apply. At this time, no new permit
applications are anticipated. All wastes expected to be disposed of now, and
following final site designation, will be aqueous industrial wastes (and
possibly municipal sewage sludge) transported by vessels with subsurface
release mechanisms. None of the wastes will be packaged in any way.
FEASIBILITY OF SURVEILLANCE AND MONITORING
Both activities are feasible at the 106-Mile Site, although costly. This
subject was addressed earlier in Chapter 2.
DISPERSAL, HORIZONTAL TRANSPORT AND VERTICAL MIXING CHARACTERISTICS
OF THE AREA. INCLUDING PREVAILING CURRENT DIRECTION AND VELOCITY
The physical oceanographic characteristics of the 106-Mile Site are
described in detail in Appendix A. Waste dispersal is discussed in Chapter 4
and Append ix B.
EXISTENCE AND EFFECTS OF CURRENT AND PREVIOUS DISCHARGES
AND DUMPING IN THE AREA (INCLUDING CUMULATIVE EFFECTS)
Chapter 4 and Appendices A and B provide additional details on effects of
dumping at the site. This EIS is limited to discerning effects of industrial
waste dumping. The effects of past munitions disposal within the site are
unknown. Likewise, the effects of radioactive waste disposal outside of the
site are unknown.
Based on survey work conducted at the 106-Mile Site and at other sites
where acid-iron wastes are dumped, short-term adverse effects of waste dumping
are generally known. These effects consist of plankton mortality in the waste
plume immediately upon discharge from the barge, pH changes within the plume,
increased concentrations of some waste constituents in the upper water column,
2-36
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and possible avoidance of the area by fish. Short-term effects are mitigated
by rapid dilution and dispersion of the wastes within the period of initial
mixing.
Other investigations of dumping effects have been made, but the studies are
still at a preliminary stage. Some observations include possible occurrence
of abnormal fish eggs and embryos in the waste plume, ingestion of waste
particulates by zooplankton, inhibition of organic carbon assimilation by
bacteria, reduced feeding rates in copepods, stimulation of diatom growth in
low waste concentrations and growth inhibition in elevated concentrations, and
possible transport of waste materials by vertically migrating zooplankton.
Most of this work has been hindered by the difficulty of tracking the plumes
and performing time-series sampling within plumes. These effects and others
are subjects for future research on waste disposal at the site.
INTERFERENCE WITH SHIPPING, FISHING, RECREATION, MINERAL
EXTRACTION, DESALINATION, FISH AND SHELLFISH CULTURE. AREAS OF
SPECIAL SCIENTIFIC IMPORTANCE, AND OTHER LEGITIMATE USES OF THE OCEAN
Present use of the 106-Mile Site interferes with none of the listed
activities, nor is future use of the site for dumping likely to cause an
obstruction. Most resource exploitation occurs on the Continental Shelf, so
use of a site off the Continental Shelf is not likely to influence such
activities adversely. The only relevant consideration is the effect, if any,
of transit to and from the site. Emergency waste dumping could cause wastes
being transported to the site to be short-dumped in an area where other
activites are occurring; however, such a situation would be expected to cause
only short-term interference and short-term adverse impacts, if any.
THE EXISTING WATER QUALITY AND ECOLOGY OF THE SITE AS DETERMINED
BY AVAILABLE DATA OR BY TREND ASSESSMENT OR BASELINE SURVEYS
No known pre-disposal baseline data from the site vicinity exist; however,
trend assessment surveys and limited laboratory studies have been conducted
since waste disposal began at the site. This work is detailed in Chapter 4
and Appendix A.
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POTENTIALITY FOR THE DEVELOPMENT OR RECRUITMENT
OF NUISANCE SPECIES IN THE DISPOSAL SITE
In several years of site survey work, since waste discharging began, no
development or recruitment of nuisance species has been observed.
EXISTENCE AT OR IN CLOSE PROXIMITY TO THE SITE OF ANY SIGNIFICANT
NATURAL OR CULTURAL FEATURES OF HISTORICAL IMPORTANCE
No such features are known to exist at or near the site. The site is
sufficiently distant from shore, so that wastes will not affect national or
state parks or beaches.
CONCLUSIONS AND PROPOSED ACTION
All future use of the 106-Mile Site for ocean waste disposal must comply
with the EPA Ocean Dumping Regulations and Criteria - a requirement which also
brings prospective dumping into compliance with the MPRSA and the London Ocean
Dumping Convention. EPA determines compliance with the Ocean Dumping
Regulations on a case-by-case basis as applications for disposal permits are
evaluated. This section offers general guidelines for determining accept-
ability of applicant wastes when a clear need for ocean disposal has been
demonstrated, due to a lack of land-based disposal methods.
TYPES OF WASTES
Waste materials similar to those presently dumped at the site (see
Appendix B) will be provisionally acceptable, since no significant adverse
environmental effects have yet been demonstrated from dumping these wastes.
If adverse effects are observed in later monitoring, dumping must be altered
(reduced or stopped) according to Section 228.11 of the Ocean Dumping
2-33
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Regulations until such effects do not occur. For the present, however,
industrial wastes having the following characteristics may be released at the
site:
Aqueous, with solids concentrations sufficiently low, so that waste
materials are dispersed within the upper water column
Neutrally buoyant or slightly denser than seawater, such that, upon
mixing with seawater, the material does not float
Demonstrate low toxicity and low bioaccumulation potential to
representative marine organisms
Contain no materials prohibited by the MPRSA or the London Ocean
Dumping Convention
Contain constituents in concentrations that are diluted, such that
the limiting permissible concentration for each constituent is not
exceeded beyond the disposal site boundaries during initial mixing
(4 hours), and not exceeded inside or outside of the site after
initial mixing
Sewage sludge represents a special category of waste being considered for
dumping at the site and is discussed in additional detail in Chapter 5.
WASTE LOADINGS
Since cumulative effects of past waste loading have not been demonstrated
at' the site, no upper limit can be defined beyond which effects could occur.
(See Appendix B.) The maximum historical input, roughly 800,000 metric tons
of industrial wastes and sewage sludge in 1978, has not caused observable
long-term adverse effects. However, the critical element for evaluating the
effects of waste loading at the site, is not the total annual input, but
rather the input of each individual dump. The rate of release of each waste
load must not be greater than the ability of the water to dilute it to
acceptable levels within a short time. Compliance with Section 227.8 of the
Ocean Dumping Regulations (limiting permissible concentration) should ensure
that the marine environment will not be adversely or irreversibly impacted.
The total assimilative capacity of the site is unknown because the physical
conditions which cause waste dispersal there are still not well understood.
2-39
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Therefore, making accurate predictions of maximum permissible waste loading is
impossible at this time. However, the emphasis of future NCAA research at the
site is to define the physical characteristics of the site and its action on
the waste in more detail. Each waste proposed to be dumped must be evaluated
individually, and in relation to other wastes being dumped, for dispersion
characteristics and input of toxic elements to the environment of the area.
In the absence of more accurate information, waste loadings increased above
the present level may be permitted as long as the site is carefully monitored
for adverse effects. However, the amount of material dumped in each barge
load must not be greater than that amount which can be reduced to acceptable
levels within the period of initial mixing (4 hours). EPA establishes the
size of barge loads and rates of release of materials at the site to meet this
objective.
DISPOSAL METHODS
Present disposal methods practiced by permittees at the site appear to be
acceptable for future waste disposal. Wastes are transported to the site in
specially constructed barges, or in self-propelled tankers, and discharged
from underwater valves while the barge/vessel is underway within the disposal
site boundaries. The turbulence created in the barge/vessel wakes causes
immediate dilution of the waste. This method (or any other method that
maximizes initial dilution upon discharge) is recommended for all future
disposal.
DUMPING SCHEDULES
EPA presently manages the disposal operations, such that different
quadrants of the site are used seasonally by each permittee. This plan
minimizes contact of wastes being released within the site at the same time
and maximizes the dilution of wastes by using the entire site for dumping.
When two or more waste vessels are discharging wastes simultaneously, the
vessels should be separated by the maximum possible distance (at least
0.5 nmi) within the quadrant to allow for adequate dilution of the wastes.
2-40
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PERMIT CONDITIONS
EPA specifies special conditions for .^inclusion in individual permits as
necessary. All future pennitsfshouLa minimally contain the following
conditions:
(1) Independent shiprider surveillance of all disposal operation will be
conducted by the USCG or an unbiased observer (the latter at
permittee's expense).
(2) Comprehensive monitoring for long-term impacts will be accomplished
by Federal agencies and monitoring for short-term impacts will be
accomplished by NOAA and the permittees (or by environmental
contractors at the permittee's expense). All monitoring studies of
permittees are subject to EPA approval. Short-term monitoring
should include laboratory studies of waste characteristics and
toxicity, and field studies of waste behavior upon discharge and its
effect on local organisms. Long-term monitoring should include
studies of chronic toxicity of the waste at low concentrations and
field studies of the fate of materials, especially any particulates
formed after discharge.
(3) EPA will enforce a discharge rate based on the limiting permissible
concentration, disposal in quadrants of the site, and maintenance of
a 0.5 nmi separation distance between vessels.
(4) Key constituents of the waste will be routinely analyzed in waste
samples at a frequency to be determined by EPA on a case-by-case
basis, but sufficient to evaluate accurately mass loading at the
. site.
(5) Routine bioassays will be performed on waste samples using
appropriate sensitive marine organisms.
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Chapter 3
AFFECTED ENVIRONMENT
This Chapter describes the environments of the proposed
site and the alternative sites. The 106-Mile Site is in deep
water off the Continental Shelf, thus it exhibits
environmental features different from the alternative sites,
which are in shallow water over the Continental Shelf. These
unique features of the 106-Mile Site make it a better
location for industrial waste disposal than any of the
alternative sites.
THE 106-MILE SITE
Detailed information on the 106-Mile Site (Figure 3-1) is given in
Appendix A. The following discussion is excerpted from Appendix A.
PHYSICAL CONDITIONS
The site is beyond the edge of the Continental Shelf within the influence
of the Gulf Stream (Figure 3-2), therefore surface water at the site may
belong to any or all of three different water masses, each having distinct
physical, chemical, and biological characteristics: Shelf Water, Slope Water,
and Gulf Stream Water. Slope Water normally occupies the site; however, when
the Shelf/Slope front migrates eastward, Shelf Water of equal or lower
salinity and temperature spreads over Slope Water, forming a relatively thin
surface layer. Occasionally, warm-core rings of water (eddies), break off the
Gulf Stream and migrate through the site, entraining Shelf Water or Gulf
Stream Water. The latter is of higher temperature and salinity than Slope
Water. Such eddies do not pass through the site on a seasonal basis, but they
have been observed to touch or completely occupy the site for about 70 days a
year (Bisagni, 1976).
As the surface waters of the site warm in late spring, the water stratifies
within 10 to 50 m of the surface, forming a seasonal thermocline. Stratifi-
cation persists until mid or late fall, when cooling and storm activity
3-1
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41°
75°
1. New York Bight Acid
Wastes Dispoal Site
2. Northern Area
3. Southern Area
4. Delaware Bay Acid
Waste Disposal Site
5. 106-Mile Ocean
Waste Disposal Site
74°
73°
72°
40°
39°
38°
41°
40°
39°
38°
75°
74°
73°
72°
Figure 3-1. Alternative Disposal Sites
3-2
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74°
72°
70°W
KILOMETERS
0 ' Tlo
NAUTICAL MILES
0 50
HUDSON
CANYON
>-MILE
40°
39°
38°N
Figure 3-2. Location of the 106-Mile Site (Shaded)
Source: Adapted from Warsh, 1975b.
destroy it. From fall through winter and into early spring, the temperature
of the water column is the same from the surface to a depth of approximately
100 m. At 100 to 150 m depth, however, a permanent thermocline exists,
dividing the water column into upper and lower regimes. Water below the
permanent thermocline is uniformly lower in temperature than water above the
thermocline. The different water densities of these regimes (caused by the
differences in temperatures) prevent large-scale mixing of the layers. Large
storms passing through the area will only disrupt this feature temporarily, if
at all. Physical characteristics of the site greatly influence the ultimate
fate of aqueous wastes dumped there.
3-3
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Few current measurements exist for the site; however, the literature
indicates that water at all depths in this area tends to flow southwest at a
speed of less than 0.2 kn, generally following the boundary of the Continental
Shelf and Continental Slope (Warsh, 1975b). Occasionally, the water flow may
change direction, particularly when Gulf Stream eddies pass through the area;
this effect has been observed at great depths at the site.
Physical and chemical characteristics at the site introduce biological
complexity because each water mass possesses unique associations of plants and
animals.
GEOLOGICAL CONDITIONS
The Continental Slope within the disposal area has a gentle (4%) grade,
which levels off (1%) outside the site in the region of the upper Continental
Rise. Sediments within the site are principally sand and silt, with silts
predominating (Pearce et al., 1975). Sediment composition is a major factor
determining the amounts and kinds of animals capable of colonizing the bottom
of the site. Generally, greater diversity and abundance of fauna are
associated with fine sediments (e.g., silt) than with coarse sediments (e.g.,
sand), although unusual physical conditions may alter this. Fine-grained
sediments are more likely to contain higher concentrations of heavy metals
than coarse sediments. Sand, gravel, and rocky bottoms rarely contain these
elements in high concentrations.
Continental Slope sediments in various parts of the site are subject to
different dynamic forces. The Upper Continental Rise is an area of tranquil
deposition, and the Lower Continental Rise is an area of shifting deposition.
Erosional areas (caused by currents) lie between these two provinces.
Depositional processes would determine the ultimate fate of any waste products
which reached bottom (anticipated to be quite small). In areas swept by
currents, waste products would be carried out of the disposal site by
currents, and greatly diluted. In areas of erosion and shifting deposition,
the same situation would exist, although the waste material could be
temporarily deposited before movement. With tranquil or slow deposition,
waste products would be buried slowly.
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CHEMICAL CONDITIONS
The amount of oxygen dissolved in seawater is a general indicator of the
life-supporting capacity of the water. Dissolved oxygen levels below 0.5
ml/liter stress some oceanic animals (Banse, 1964). Dissolved oxygen
concentrations at the 106-Mile site range from 4.6 to almost 7.5 ml/liter in
surface water.
Dissolved ofcygen levels are minimum at depths of 200 to 300 m (averaging
3.2 ml/liter), and slowly increase vertically (shallower or deeper) from the
stratification line. Summer and winter dissolved oxygen gradients at the site
are similar, the main difference being the higher surface concentrations
during winter. Any waste material which undergoes oxidation in seawater will
consume oxygen, thus lowering the quantity of dissolved oxygen present in
seawater.
Chemical research and monitoring surveys at the 106-Mile Site have analyzed
trace metal levels in the sediments, water, and selected organisms. Metals in
the sediments and water represent contaminants potentially available to site
organisms, and could possibly be assimilated (bioaccumulated) and concentrated
in toxic quantities within tissues.
Numerous metals are naturally present in seawater. Only concentrations of
metals which exceed natural background levels and approach known or suspected
toxicity levels would be expected to threaten marine organisms and man. The
most recent studies of trace metal levels in the water of the 106-Mile Site
found background levels typical of other uncontaminated Shelf-Slope regions
(Kester et al., 1977; Hausknecht and Kester, 1976a, 1976b).
Concentrations of trace metals in sediments all along the Continental Slope
and Continental Rise (including the site area) are generally elevated in
comparison to Continental Shelf values (Greig et al., 1976; Pearce et al.,
1975). This difference in concentrations is due partly to particle size
3-5
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differences between Shelf and Slope sediments, since contaminants are usually
more concentrated in finer grain sediments characteristic of the Slope region.
Thus, elevated values appear to be ubiquitous off the Shelf, and therefore are
not attributed to waste disposal activities at the site.
Analyses of trace metal concentrations in organisms at the site revealed
high cadmium levels in three sword fish livers, mercury levels above the Food
and Drug Administration action level ("unfit for human consumption") in most
fish muscle samples, and low to moderate copper and manganese concentrations,
similar to those in New York Bight finfish (Greig and Wenzloff, 1977; Greig et
al., 1976). However, ocean waste disposal at the site was not linked by
investigators to the metal concentrations found in any of the analyzed benthic
and pelagic organisms because the organisms were transients and not confined
to the site vicinity (Pearce et al., 1975).
BIOLOGICAL CONDITIONS
Plankton are microscopic plants and animals which drift passively with the
current or swim weakly. Plankton are divided into plants - the phytoplankton,
and animals - the zooplankton. Plankton are the primary source of food in the
ocean, so their health and ability to reproduce are of crucial importance to
all life in the ocean, including fish and shellfish of commercial importance.
Plankton at the 106-Mile Site are highly diverse due to the influence of
the Shelf, Slope, and Gulf Stream water masses, as previously discussed in the
section on physical conditions. High-nutrient Shelf Waters primarily
contribute diatoms to the site, while the low-nutrient Slope Waters contribute
coccolithophorids, diatoms, dinoflagellates, and other mixed flagellates
(Hulburt and Jones, 1977). Mixed assemblages of zooplankters, common to the
different water masses, occupy the site during winter, spring, and summer
(Sherman et al., 1977; Austin, 1975).
Fish have been surveyed at various depths within the site. The diversity
and abundance of fish found only in surface waters are similar inside and
outside the disposal site (Haedrich, 1977). The fauna found primarily at
3-6
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mid-depths (mesopelagic fish), are dominated by Slope Water species with Gulf
Stream eddies contributing some north Sargasso Sea species (Krueger et al.,
1975, 1977; Haedrich, 1977). At some depths, particularly in the lower water
column, the density of mesopelagic fish has been lower at the site, compared
with control areas (Krueger et al., 1977). Several migratory oceanic fish,
usually associated with the Gulf Stream, are often found at midwater depths
within the site. Benthic (bottom) fish in the site are similar to assemblages
in other Slope areas (Musick et al., 1975; Cohen and Pawson, 1977).
Abundance and diversity of invertebrates at the 106-Mile Site are similar
to those in most other mid-Atlantic Slope localities. As in similar areas,
the invertebrates on the bottom (the epifauna) of the 106-Mile Site are
dominated by echinoderms (e.g., brittle stars and sea urchins), while
segmented worms (polychaetes) are the dominant burrowing organisms.
No mammal sightings have been reported at the site, although the site is
within the distribution range of several species of whales and turtles, some
of which are rare or endangered. However, disposal activities at the 106-Mile
Site would not obstruct migrations nor harm these animals in any forseeable
way since, as migrants, they would only be in the site a few hours, at most,
and would tend to avoid dump vessels.
WASTE DISPOSAL AT THE SITE
Waste disposal at the 106-Mile Site is discussed in detail in Appendix B.
CONCURRENT AND FUTURE STUDIES
The NOAA Ocean Dumping and Monitoring Division and Ocean Pulse Program plan
to continue monitoring the 106-Mile Site. All permittees are required to
monitor waste discharges. Current permittees have contracted with a private
company to conduct quarterly monitoring.
3-7
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OTHER ACTIVITIES IN THE SITE VICINITY
Few activities occur in the site vicinity other than waste disposal
operations at the site. A large area immediately south of the site has been
proposed for ocean incineration. There are no other ocean disposal sites in
the vicinity. Oil and gas lease tracts are west and north of the site, along
the outer Continental Shelf (Figure 3-3). The Hudson Canyon Navigational Lane
crosses the Continental Slope north of the site, but no major shipping lanes
approach 106-Mile Site boundaries (Figure 3-4).
Limited fisheries resources occur at the 106-Mile Site and vicinity. Most
commercially important species of finfishes in the mid-Atlantic prefer to live
and spawn in Shelf areas and along the crest' of the Continental Shelf-Slope
break (NOAA-MESA, 1975; BLM, 1978; Chenoweth, 1976a). Consequently, most
foreign and domestic fish trawling is conducted at depths shallower than
1,000 m - much shallower than the 106-Mile Site. Waters near the site have
been used for the commercial longline fishing of marlin, sword fish, and tuna
(Casey and Hoenig, 1977). However, only 1,264 fish of these species were
reported caught between 1961 and 1974 in a large ocean area, of which the
106-Mile Site is a small part (Casey and Hoenig, 1977). Unknown additional
quantities of these species were caught by foreign fishermen. The commercial
longline effort is variable and dependent on the presence of eddies or other
water masses near the site that create interfaces between water masses which
are favorable to fishing (Casey, personal communication). In general, catch
statistics for Continental Slope areas are incomplete because fishing vessels
move from Shelf to Slope areas, mixing catches; landing records usually fail
to separate Shelf species from Slope species.
The red crab (Geryon quinquedens) is among the several species of crabs
collectively important to mid-Atlantic fisheries. The red crab is presently
considered a feasible fishery only when simultaneously collected with other
more commercially valuable species (Gusey, 1976). Adult red crabs have been
found to depths of 4,000 m and juvenile red crabs have been found from depths
of 500 to 1,000 m (Wigley, personal communication). Thus, the 106-Mile Site
occurs within the depth range of the species.
3-8
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41"
40'
75°
DCS
LEASE SALE NO. 49
| OCS LEASE
SALE NO. 40
1. NEW YORK BIGHT ACID SITE
2. NORTHERN AREA
3. SOUTHERN AREA
4. DELAWARE BAY ACID SITE
5. 106-MILE SITE
74°
73°
72°
39°
38"
4V
40°
39°
38'
75°
74°
73'
72°
Figure 3-3. Oil and Gas Leases in the New York BighC
Source: Adapted from EPA, 1978.
3-9
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75"
LONG ISLAND SOUND
1. NEW YORK BIGHT ACID SITE
2. NORTHERN AREA
3. SOUTHERN AREA
4. DELAWARE BAY ACID SITE
5. 106-MILE SITE
SAND FAUNA
SILTY-SAND FAUNA
SILTY-CLAY FAUNA
LONG ISLAND
0 50
NAUTICAL MILES
39' -
38
- 38'
Figure 3-4. Benthic Faunal Types in the Mid-Atlantic Bight
Source: Adapted from Pratt, 1973.
3-10
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The commercial fishing effort for red crabs is concentrated at depths of
300 to 500 m and does not presently occur at the 106-Mile Site or in water
depths similar to those at the site (Wigley, personal communication). The
greatest densities and biomass of red crabs occur at intermediate depths of
320 to 640 m (Wigley et al., 1975). Additional sampling is necessary to
verify the depth relationship between adult and juvenile crabs; however,
Wigley et al. (1975) found that some upslope migration of juvenile red crabs
occurs with increased age (size). The presence of adults to at least 4,000 m
depth suggests that downslope migration may occur. It is not known if
recruitment of red crabs exploited by the commercial industry is solely
dependent on individuals migrating from deeper water. Adequate abundance and
size-class data for the red crab are not presently available and additional
studies are needed (Wigley, personal communication). The effect of disposal
operations on the planktonic larvae of red crabs is unknown, but is expected
to be localized.
The commercial fishery for lobster (Homarus americanus) is one of the most
important fisheries in the Northwest Atlantic. Offshore fishing occurs to at
least 300 m depth and even with recent exploitation of lobsters on the
Continental Shelf, domestic catches of lobster have been declining since 1970.
Reported foreign catches are relatively small (Ginter, 1978). Lobsters occur
from the low intertidal down to at least 700 m, with the potential resource
occurring from 90 to 450 m depth (Larsen and Chenoweth, 1976; Gusey, 1976).
Lobster fishing is not presently conducted at or near the 106-Mile Site or in
water depths similar to those at the site (1,440 to 2,750 m). Lobsters prefer
habitats ranging from rock crevices to sand and mud burrows. The substrate at
the 106-Mile Site is predominantly silt, and therefore probably does not
provide adequate shelter.
ALTERNATIVE SITES IN THE NEW YORK BIGHT
Three New York Bight Sites (Figure 3-1) - the existing New York Bight Acid
Wastes Site, and the proposed alternative Northern and Southern Areas - were
3-11
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evaluated as alternative sites for the disposal of industrial wastes. Overall
conditions for the New York Bight are described below, emphasizing conditions
which are unique to each site.
PHYSICAL CONDITIONS
The physical characteristics of the New York Bight are complex. Seasonal
patterns of temperature, salinity, insolation, and river runoff are compli-
cated by strong meteorological events and intrusions of Slope Water (Bowman
and Wunderlich, 1977).
The hydrography of the New York Bight exhibits definite seasonal cycles in
temperature and salinity (hence density) structures. Two distinct oceano-
graphic regimes, with short transition periods, prevail during an annual
cycle. Early winter storm mixing and rapid cooling at the surface create a
well-mixed, unstratified water column. A moderate stratification develops in
early spring, which intensifies during summer (Charnell and Hansen, 1974).
The rapid formation of the seasonal thermocline divides the water column into
upper and lower layers. Bottom waters remain stable until storms break up the
thermocline in the late fall.
Conditions at the New York Bight Acid Wastes Site are more extreme than
conditions at the Northern or Southern Areas because the site is close to
shore and is affected by the fresh water outflow from New York Harbor. The
site receives a greater influx of fresh water and suspended particulate matter
(discussed below) than Shelf areas farther offshore, due to its proximity to
Hudson River drainage. The site experiences colder winter water temperatures,
since the site water lacks the tempering effect of deep waters and receives
substantial cold-water runoff during the winter season.
GEOLOGICAL CONDITIONS
The New York Bight Continental Shelf is a vast sandy plain, underlain with
clay (Emery and Schlee, 1963; Milliman et al., 1972). Sand is the most
abundant textural component on the Shelf, and significant deposits of gravel
and mud are also present. Surface sediments of the Acid Site and the Northern
3-12
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Area contain small percentages of mud, while the latter contains some gravel.
Surface sediments of the Southern Area are principally sand. The most
prominent feature of the bottom sediment in this area is a band of coarse
gravelly sand near the northeast rim of the Southern Area, parallel to the
Hudson Shelf Valley.
Suspended particulate matter includes fine material from natural and
man-made sources, which is suspended in seawater for long periods and may be
transported for some distance by waves and currents before sinking to the
bottom. After reaching the bottom, the material may be resuspended by bottom
currents or wave action and transported to other areas. A number of potential
environmental effects have been attributed to suspended particulate matter.
Higher levels of this material can increase the turbidity of the water,
thereby significantly limiting the depth at which plants can photosynthesize.
Suspended particulates can have toxic effects, or can bind or adsorb toxic
materials, which are eventually carried to bottom life. While suspended in
water, or lying on the bottom, the toxic material can be consumed by marine
organisms, or taken up by absorption.
The highest concentrations of suspended particulate matter in New York
Bight waters occur near shore. The New York Bight Acid Wastes Site, in
particular, has high levels of suspended particulate matter due to its
closeness to the coast and Hudson River runoff, a major source of this
material. Lower levels of suspended particulates are transported to and from
the Northern and Southern Areas by means of currents moving to replace water
which has moved out of the area.
CHEMICAL CONDITIONS
The coastal metropolitan area is the primary source of heavy metals
entering the New York Bight (Benninger et al., 1975; Carmody et al., 1973).
Concentrations of dissolved heavy metals in the water of the New York Bight
vary seasonally; background (natural) concentrations, however, are generally
higher than those reported for the open ocean (Brewer, 1975). Heavy metal
concentrations in bottom sediments are not uniformly distributed throughout
3-13
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the New York Bight, but vary according to sediment grain size, quality of
organic material present, mineral composition, and proximity to the metro-
politan area. In general, concentrations of dissolved heavy metals are
highest in the Bight Apex, where man's influence is greatest.
Concentrations of heavy metals in sediments and water of the Northern and
Southern Areas are low compared to those found in the Bight Apex, but all
other chemical parameters are typical of the New York Bight. Higher levels of
heavy metals have occasionally been found in the water of the New York Bight
Acid Wastes Site (Segar and Cantillo, 1976), and metal concentrations in the
sediments of the site are generally half as high as concentrations in Hudson
Submarine Canyon sediments. Normally, waste material dumped at the site is
confined to the water column; however an iron flocculent, which forms as the
acid-iron waste reacts with seawater, has contributed to high sediment-iron
concentrations in the site vicinity.
Surface waters of the New York Bight are saturated or nearly saturated with
oxygen. Dissolved oxygen levels in bottom waters begin to decline in spring
as the the surface mixing layer (thermocline) develops; by late summer, the
oxygen levels reach the lowest values. Oxygen saturation increases in the
fall, following breakup of the surface mixed layer, and continues to increase
as greater mixing occurs (Segar et al., 1975). Dissolved oxygen concen-
trations in surface, mid-depth, and bottom waters in the Northern and Southern
Areas are moderately to highly saturated during winter, spring, and critical
summer conditions. The saturation value for oxygen at these sampling depths
probably does not fall below 50% at any time of year, and is usually much
higher (75% to 110%).
Suspended particulates which may trap and transport toxic susbtances, are
found in highest concentrations near areas of wastewater discharge (outfalls)
and sewage sludge, dredged material, and cellar dirt disposal sites. All
three alternative sites display low levels of total organic carbon. No
comprehensive studies of chlorinated hydrocarbons exist for the New York
Bight, but dredged material and sewage sludge disposal are probably major
sources of these materials in the Bight (EPA, 1975; Raytheon, 1975a, 1975b) .
Industrial chemical waste generally contains low levels of chlorinated
hydrocarbons.
3-14
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BIOLOGICAL CONDITIONS
During most of the year, the ranges of daily phytoplankton production for
inshore and offshore areas of the New York Bight do not differ significantly
from one another (Ryther and Yentsch, 1958; Yentsch, 1963). Total annual
production, however, is higher in coastal waters. In broad terms, phyto-
plankton populations are dominated by diatoms during cold months and
chlorophytes during warm" months in the Hudson River estuary and Apex, and by
diatoms in the outer Bight. Zooplankton populations are dominated by copepods
and larvae of vertebrates and invertebrates during summer only in the estuary,
and by copepods in the outer Bight.
The fish population in the New York Bight includes nonmigrating species,
migrating species, and seasonal migrants (NYOSL, 1973). Many species of
coastal fishes use the New York Bight as a spawning ground, although no.
specific location is used exclusively or consistently by any one species. The
benthic fauna show a subtle gradient in the offshore direction, from sand
fauna, to silty-sand fauna, to silty-clay fauna, as the sediments become more
fine-grained (Figure 3-4).
At present, 21 species of finfish and 15 species of shellfish are commonly
harvested in the New York Bight, and several other species are potentially
important to future fishing. Fish exhibit unrestricted movement, thus
locations where specific finfish are caught vary considerably from year to
year. Fish mobility and the understandable lack of a requirement for
fishermen to report specific fishing grounds, makes mapping of finfisheries
nearly impossible.
Locations of specific shellfishing grounds in the mid-Atlantic are largely
unknown. However, since shellfish movement is restricted, assessment surveys
by NOAA's National Marine Fisheries Service (NMFS) are useful for locating
areas inhabited by shellfish in marketable quantities. High densities of
three of the most heavily utilized Bight shellfish resources - the surf clam,
3-15
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sea scallop, and ocean quahog - are shown in Figure 3-5. The assessment
surveys which provided these data were conducted in 1974 and 1975; actual
locations and densities of the shellfish may have changed since that time. In
addition, EPA (1978) reports that ocean quahogs are numerous around the
Northern area. The Northern Area was not sampled in the NMFS assessment
surveys.
Minor commercial fishing occurs around the New York Bight Acid Wastes Site.
A seasonal whiting fishery exists along the edge of the Hudson Shelf Valley
near the site during the winter, and lobster are taken inshore of the site.
Most of the Bight Apex is closed to shell fishing because of contamination from
the sewage sludge and dredged material sites, and the numerous effluent
outfalls along the Long Island and New Jersey shore.
Surf clams, sea scallops, and ocean quahogs inhabit the Northern and
Southern Areas on a nonexclusive basis for most (or all) life stages. Surf
clams are more prevalent in the Southern Area and scallops are more prevalent
in the Northern Area. However, neither area is known to be actively fished at
this time.
WASTE DISPOSAL AT THE NEW YORK BIGHT ACID WASTES SITE
The New York Bight Acid Wastes Site was established in 1948 for the
disposal of waste generated by industries in the New Jersey and New York
areas. The present site, designated as an interim disposal site by EPA in
1973, is bounded by latitudes 40°16'N to 40°20'N and longitudes 73°36'W to
73°40'W.
RECENT DISPOSAL PRACTICES
Three permittees were using the New York. Bight Acid Wastes Site when it
came under EPA regulation in April 1973. In 1974, the Du Pont-Grasselli waste
disposal operation was moved to the 106-Mile Site. Two permittees - NL
3-16
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41°
75°
1. NEW YORK BIGHT ACID SITE
2. NORTHERN AREA
3. SOUTHERN AREA
4. DELAWARE BAY ACID SITE
5. 106-MILE SITE
I OCEAN QUAHOC
I SEA SCALLOP
I SURF CLAM
74°
73°
72°
40°
39°
38°
41°
40°
39°
100
50
38°
75°
74°
73°
72°
Figure 3-5 .
Distribution of Surf Clams, Ocean Quahogs, and
Sea Scallops in the Mid-Atlantic
Source: Adapted from NOAA-NMFS, 1974, 1975.
3-17
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Industries, Inc., and Allied Chemical Corporation - are currently using the
Acid Wastes Site. The volume of waste discharged at the site decreased 65%
between 1973 and 1978 (Table 3-1), due to three factors:
(1) Du Pont-Grasselli abandoned the site in late 1974. Graselli waste
accounted for 5% of the total quantity disposed in 1973 and 1974.
(2) Allied Chemical shut down certain manufacturing processes, causing
the waste volume to decrease 74% between 1973 and 1978.
(3) ML Industries (the primary waste discharger) was either shut down or
operating at a reduced capacity (due to a strike) for an extended
period from 1976 to 1977. Normally, NL Industries contributes more
than 90% of the waste volume.
TABLE 3-1
DISPOSAL VOLUMES AT THE NEW YORK BIGHT ACID WASTES DISPOSAL SITE
(Metric Tons)
Permittee
NL Industries
Allied Chemical
Du Pont-Grasselli
TOTAL
Year
1973
2,300,000
59,000
142,000
2,505,000
1974
1,987,000
56,000
78,000
2,121,000
1975
1,842,000
48,000
1,890,000
1976
1,234,000
47,000
1,281,000
1977
605,000
29,000
634,000
1978
849,000
15,000
864,000
Total
8,822,000
254,000
220,000
9,295,000
NL Industries
NL Industries, in Sayreville, New Jersey, disposes of wastes generated
during the manufacture of titanium dioxide, an inert, nontoxic white pigment,
prepared in various grades for use in the paint, paper, plastic, drug, and
3-18
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ceramic industries. The waste consists of approximately 8.5% (by volume)
sulfuric acid (H»SO,) and 10% (by volume) ferrous sulfate (FeSO,) dissolved in
fresh water. When the waste is dumped, the ferrous sulfate colors the water
light green. Shortly thereafter the barge wake turns brown as the ferrous
sulfate is oxidized to form ferric hydroxide (rust). Insoluble materials
(e.g., silica and unrecovered titanium dioxide) are also present in the waste.
NL Industries waste represented 97% of the total material dumped at the Acid
Site between 1975 and 1978.
Allied Chemical Corporation
Allied Chemical, in Elizabeth, New Jersey, discharges wastes from the
manufacture of fluorocarbons. The waste material consists of approximately
30% hydrochloric acid (HC1), 2% hydrofluoric acid (HF) - both by volume - and
trace constituents in aqueous solution. The principal trace metals in the
waste are chromium, copper, lead, nickel, and zinc. Allied Chemical wastes
represented 3% of the total material dumped at the Acid Wastes Site between
1975 and 1978.
WASTE CHARACTERISTICS
Dispersion studies have been conducted periodically on NL Industries wastes
since waste disposal began in 1948. Table 3-2 summarizes results of
dispersion studies for NL Industries and Allied Chemical wastes, showing that
the wastes are diluted rapidly after discharge. Red field and Wai ford (1951)
reported that the maximum volume of water having an acid reaction was
3
162,000 m (640 m long, 23 m wide, and 11 m deep); the acid was neutralized
within 3.5 minutes after discharge. Recent EG&G studies (1977a, 1977b)
reported that the wastes did not penetrate the summer thermocline at 10 m, and
initial mixing was rapid. A detailed description of the dumping operation is
provided by Redfield and Walford (1951) and Peschiera and Freiberr (1968).
Trace Metals
The quantities of eight trace metals released at the Acid Site during the
years 1973 to 1978 are summarized in Table 3-3. Only chromium, vanadium, and
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TABLE 3-2
REPORTED DILUTION VALUES FOR WASTES DUMPED AT THE ACID SITE
1'ennitlce/
Reference
Industries:
Kefs:
Kt.-dfii.-ld dnd
Hdlford 1%)
Kelchinu and
lord. ]'J'..2
Vaccaro
el al., l'J/2*
MiUi Inc.
)'J77a
Allied C Ill-mica)
Corporal inn
Rel:
CG&C Inc.
Dilution
Seconds
15
700
30
250
Dilution
Minutes
1
2.700
2
1.200
3
6,500
4
1.500
1.500
5
1.200
12
3,000
22
23.000
30
3,900
39
9.400
55
6.600
66
40.000
180-
200
2.700
82,000
83.000
Dilution
Hours
4
90.000
143,000
18
116,000
* Keported thai the hiyhei.! particulate iron concentration observed wtr,
i;(|uivdlt:nt to a dilution of 39.000. lliv 1 inn- after discharge wJS
unknown but the acid pliuiie w.i', still visible.
I
N>
O
-------
zinc are present in large quantities, and if the total contaminant inputs to
the Bight are considered, inputs of these three metals from acid wastes are
insignificant. The total mass loads of several trace metals released annually
into the New York Bight from various sources are listed in Table 3-4. Wastes
discharged at the Acid Site contribute significant amounts of vanadium, iron,
and possibly nickel to the Bight. Red field and Wai ford (1951) reported that
the amount of iron barged to sea for disposal was about equal to the amount
discharged in the Hudson River outflow. Recent work (NOAA-MESA, 1975)
indicated that the Hudson estuary discharge is a major source of dissolved and
suspended particulate metals, particularly iron and manganese. The Acid
Wastes Site ranks fourth or fifth among the five possible sources of most
metals introduced to the Bight; ocean dumping at other sites (principally
dredged material and sewage sludge) and outflow from New York Harbor are the
dominant sources of contaminants.
TABLE 3-3
ESTIMATED AMOUNTS OF TRACE METALS RELEASED ANNUALLY
AT THE NEW YORK BIGHT ACID WASTES DISPOSAL SITE
Metal
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Vanadium
Zinc
Metric Tons/Year
1973
0.9
30.7
15.3
5.7
0.0
13.3
215.5
52.7
1974
0.9
25.5
6.5
2.6
0.1
14.3
127.7
42.5
1975
0.1
19.2
8.8
2.5
0.0
9.6
112.5
33.5
1976
0.3
5.4
2.1
3.0
0.005
3.8
NA
13.6
1977
0.1
58.3
2.2
0.9
0.003
3.4
NA
10.9
1978
0.2
8.2
3.1
1.3
0.004
4.8
NA
15.2
Total
2.5
147.3
38.0
16.0
0.1
49.2
NA
168.4
Average
0.4
24.5
6.3
2.7
0.02
8.2
NA
28.1
NA = Not analyzed
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TABLE 3-4
MASS LOADS OF TRACE METALS ENTERING THE NEW YORK BIGHT,
1960-1974
Metal
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Vanadium
Metric Tons
Ocean
Dumping*
30
880
2,573
1,993
10
NR
NR
Atmosphere
20
27
146
2,154
NR
NR
NR
Transect
ZoneT
13
803
2,263
2,117
94
NR
NR
New Jersey/
Long Island
Coastal Zone
5
81
54
32
7
NR
NR
Acid
Waste
1
31
15
6
0.01
13
216
Total
769
1,822
5,051
6,302
111
NR
NR
* Dredged Material and Sewage Sludge Sites
t Outflow from New York Harbor
NR => Not reported
Source: Adapted from Mueller et al., 1976.
Acid
The acid in NL Industries wastes is neutralized within a maximum of 40
minutes after discharge (EG&G, 1977a). Redfield and Walford (1951) calculated
that upon discharge, the sulfuric acid would be immediately diluted to 2 parts
in 10,000 and the seawater pH would not fall below 4.5. The actual pH
depression observed two minutes after discharge was 6.9. The pH returned to
normal level (8.2) within seven minutes. The EG&G (1977a) study found only
two stations where the pH was depressed more than 0.1 units 40 minutes after
the disposal of NL Industries waste.
In Allied Chemical waste dispersion studies, EG&G (1977b) reported a
minimum pH of 5.95 four minutes after disposal began. The pH increased (6.6 at
22 minutes, 7.3 at 37 minutes) and returned to ambient levels within one to
three hours.
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EFFECT ON ORGANISMS
Before regulation of ocean dumping by EPA, numerous laboratory and field
toxicity studies had been performed on the wastes dumped at the Acid Site.
Observations of relatively slight effects have been reported by Redfield and
Walford (1951), PHSSEC (1960), Ketchum et al. (1958b, 1958c), Vaccaro et al.
(1972), Wiebe et al. (1973), Grice et al. (1973), and Gibson (1973). In
contrast, NOAA-NMFS (1972) reported severe effects due to acid waste disposal.
However, the NMFS methods and conclusions have been criticized (Buzas et al.,
1972).
A variety of phytoplankters and zooplankters collected in the wake of an
acid waste discharge have been analyzed. Animals may be immobilized
immediately after disposal but recover quickly when the waste is diluted with
an equal volume of seawater. Several investigators reported that the
gastrointestinal tracts of copepods and ctenophores collected at the site
after a discharge contained iron particles from the waste, but the animals did
not exhibit any ill effects.
Laboratory work indicates that phytoplankton are unaffected by a concen-
tration of acid waste four times higher than concentrations observed in the
field. Zooplankton are chronically affected by concentrations of one part
waste in 10,000 parts seawater, causing impaired reproduction and retarded
development. However, this concentration of waste persists only for a few
minutes after disposal, and is a strictly local phenomenon. Investigations
have shown that the pH change causes the adverse effects rather than toxic
elements in the waste. Neutralized acid waste is not toxic to the test
organisms.
When the site was first established, there was controversy over possible
adverse effects on the migratory fish in the New York Bight. Westman
periodically surveyed the site and other fishing areas in the Bight (Westman,
1958, 1967 1969; Westman et al., 1961), and concluded that bluefish and
yellowfin tuna are attracted to the site, and that an active pelagic fishery
exists in the area; however, fish attraction was not demonstrated by
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comparative sampling, and increased catches of fish in the site may be related
to increased turbidity, consequent decreased recognition, and avoidance of
fishing gear.
The acid waste does not appear to be toxic to bottom-dwell ing animals. The
site supports a typical sand-bottom community, with biomass and species
diversity comparable to a control area (Vaccaro et al., 1972); however, the
total numbers of individuals of all species are significantly less than at the
control area. Other investigators (Westman, 1967, 1969; NOAA-NMFS, 1972) have
reported variable benthic communities at the site. Recent samples (Pearce et
al., 1976a, 1976b, 1977b) show that there is a wide natural variation at
stations in and around the site, and that such variability is common for
sand-bottom assemblages.
CONCURRENT AND FUTURE STUDIES
Several organizations are currently conducting research and survey
activities in the New York Bight. The MESA-New York Bight Project is
sponsoring work by a variety of Federal and academic investigators. This
phase of the project is scheduled to end in 1981. After 1981, less intensive
monitoring will continue under NOAA sponsorship.
The NOAA-National Marine Fisheries Service Laboratory at Sandy Hook, New
Jersey, is periodically sampling and evaluating the Bight as part of the Ocean
Pulse Program, designed to monitor and assess the health of the ocean's living
resources on the Continental Shelf of the Northwest Atlantic Ocean. This
program includes, as one of its objectives, the study of the effects of
pollutants on important marine species.
EPA requires Acid Site permittees to perform waste dispersion studies and
site monitoring surveys as permit conditions.
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OTHER ACTIVITIES IN THE SITE VICINITY
COMMERCIAL FISHERIES
Extensive finfish and shellfish fishing occurs in the New York Bight. Most
finfish fishing grounds are over the inner Continental Shelf or near the edge
of the Shelf. Most indigenous Bight shellfish exist throughout the Bight, but
certain species (e.g., lobster) are most abundant in Hudson Canyon or outer
Continental Shelf Areas.
Domestic
Table 3-5 shows the 1974 total yield and dollar value for the five major
species of commercial finfish in the New York Bight. The stock of most
commercial species is still substantial, but there has been an overall
decrease in annual yields of finfish over the last two decades (Figure 3-6),
with commercial landings of certain over-fished species (e.g., menhaden)
declining. The yield of the domestic shellfishery has increased greatly since
1960 (Figure 3-7). The once-important surf clam is becoming increasingly
scarce, and other shellfish species have recently begun to be exploited (e.g.,
red crab and ocean quahog). Table 3-6 shows the total annual values in 1974
and 1976 for the more important shellfish species. The American lobster is
the most important species fished along the Continental Shelf/Slope break, and
is quickly becoming the most important fishery resource of the New York Bight
(Chenoweth, 1976a).
Foreign
Nearly all foreign fishing in the north and mid-Atlantic regions of the
United States is conducted on the Continental Shelf, with the majority of
foreign vessels trawling in the outer Shelf region (Figure 3-8). Peak foreign
fishing activity in the New York Bight occurs during spring and early summer,
when the fleet moves south from its winter fishing grounds on the Georges
Bank. The foreign fleet greatly increases in size during this period in order
to harvest the greater numbers of fish which congregate at spawning grounds.
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TABLE 3-5
TOTAL LANDINGS IN 1974 OF FIVE MAJOR COMMERCIAL
FINFISHES IN THE NEW YORK BIGHT
Species
Fluke
Menhaden
Scup
Striped
Bass
Whiting
New York
000 Lb
2,487
576
3,635
1,409
1,955
$000
846
18
832
533
250
New Jersey
000 Lb
3,499
107,307
6,040
714
7,022
$000
1,153
2,735
880
177
587
Total
000 Lb
5,986
107,883
9,675
2,123
8,977
$000
1,999
2,753
1,712
710
837
Source: Adapted from NOAA-NMFS, 1977a.
30
25
20
a
§10
5 5
TOTAL MINUS SURF CLAM
1880 1890 1900 1910 1920 1930 1940 1950 1960 1970
Figure 3-6. Total Landings of Commercial Marine Food Finfishes
in the New York Bight Area, 1880-1975
Source: McHugh, 1978.
3-26
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35
30
25
Z
O
£ 20
O
i/i
Q
I '5
-------
41*
7T
1. NEW YORK BIGHT ACIO SITE
2. NORTHERN AREA
3. SOUTHERN AREA
4. DELAWARE BAY ACIO SITE
5. 106-MILE SITE
74"
73°
72°
40°
39"
38'
41°
40°
39'
38°
75°
74°
73°
72°
Figure 3-8. Location of Foreign Fishing off the U.S. East Coast
Source: Adapted from Ginter, 1978.
3-28
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An annual average of 1,000 foreign vessels fish along the mid-Atlantic
coast (Ginter, 1978). Foreign fishing in the New York Bight is dominated by
the Soviet Union, followed by East Germany, Spain, and Japan. Major foreign
fisheries are herring, silver and red hake, and mackerel. The seasonal
migrations of these species account for the north-to-south movement of the
foreign fleet throughout the year. New fishing efforts have been developed
recently for squid, butterfish, tuna, and saury; this has moderated the strict
north-south movement of foreign vessels.
Foreign vessels are prohibited from fishing such exclusive United States
fishery resources as lobster, but are not required to report the magnitude of
their annual harvest from United States waters. Consequently, no compre-
hensive foreign catch statistics are available.
RECREATIONAL FISHERIES
Most recreational fishing in the New York Bight is confined to inner
Continental Shelf Waters, since this area is the most accessible to the
public, and most sport species are found there (Chenoweth, 1976a). The
important species are striped bass, weakfish, bluefish, and mackerel. The
sport catch often equals or surpasses the commercial landings of certain
species (e.g. striped bass), and has contributed significantly to the
economics of several coastal areas. In 1970, for example, 1.7 million anglers
caught 2.7 million pounds of fish from the North Atlantic coast. Recreational
species fished further offshore are limited primarily to bluefin tuna, marlin,
and sword fish. No accurate catch statistics exist for these species.
SAND AND GRAVEL MINING
Sanko (1975) states that since 1963 the largest single source of sand for
New York City has been sand deposits in the Lower Bay of New York Harbor.
This is the only area in the New York Bight where sand is presently rained;
however, recent geological surveys show that sand could be mined nearly
anywhere in the New York Bight, with current technology limiting the outer
boundary to the 50-ra (165-ft) isobath. There is an estimated area of over
2 2
780 nmi (2,680 km ) suitable for sand mining between the 50-m isobath and the
3-29
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Long Island shoreline (Schlee, 1975). Most of this sand is of a uniform
grain-size, and contains a low percentage of fine particles. Gravel deposits
in the New York Bight have a much more limited distribution than sand.
Potential mining areas for gravel are fewer and are principally off the
northern coast of New Jersey (Figure 3-9).
OIL AND GAS EXPLORATION AND DEVELOPMENT
There are no present or future oil and gas lease tracts in any ocean
disposal site (Figure 3-3). The U.S. Department of the Interior Bureau of
Land Management (BLM) completed its first sale of oil and gas leases on the
Mid-Atlantic Outer Continental Shelf in August 1976 (Outer Continental Shelf
[DCS] Sale No. 40). Exploratory drilling at six of the 93 tracts leased in
OCS Sale No. 40 began in the spring and summer of 1978. On May 19, 1978, BLM
published a draft EIS on the proposed OCS Sale No. 49, which includes 136
tracts totalling 774,273 acres (313,344 hectares). Sale No. 49 is tentatively
scheduled for spring of 1979. A third sale (No. 59) is under consideration,
tentatively scheduled for August 1981 (BLM, 1978).
SHIPPING
The major trade routes charted by NOAA to serve the New York-New Jersey
area coincide with three major shipping lanes designated by the USCG: the
Nantucket, Hudson Canyon and Barnegat Navigational Lanes (Figure 3-10).
Hudson Canyon Lane lies across the New York Bight Acid Wastes Site, and the
other lanes straddle the Northern and Southern Areas. The trade routes within
the navigational lanes are usually the safest routes for shipping traffic, and
the Coast Guard recommends that they be used by all major shipping traffic.
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75°
74°
73°
72°
41°
1. NEW YORK BIGHT ACID SITE
2. NORTHERN AREA
3. SOUTHERN AREA
4. DELAWARE BAY ACID SITE
5. 106-MILE SITE
40°
39°
38°
41°
40°
39°
KILOMETERS
0 50
NAUTICAL MILES
100
50
38°
75°
74°
73°
72°
Figure 3-9. Gravel Distribution in the New York Bight
Source: Adapted from Schlee, 1975.
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LONG ISLAND SOUND
1. NEW YORK BIGHT ACID SITE
2. NORTHERN AREA
3. SOUTHERN AREA
4. DELAWARE BAY ACID SITE
5. 106-MILE SITE
LONG ISLAND
PRECAUTIONARY
ZONE
DELAWARE
BAY
FIVE FATHOM BANK
50
NAUTICAL MILES
38" -
73°
72°
Figure 3-10. Navigational Lanes in the Mid-Atlantic
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OCEAN WASTE DISPOSAL
The EPA permits ocean disposal at seven sites in the New York Bight (Figure
3-11). The Acid Wastes Site is considered in this EIS as a possible
alternative site for the industrial wastes presently released at the 106-Mile
Site.
12-Mile Sewage Sludge Site
There are 13 permittees dumping sewage sludge at this site, with the City
of New York discharging the largest percentage of the waste. The total volume
of sewage sludge to be disposed of by the 13 permittees in 1979 is estimated
3 3
to be 7,772 m , and is expected to reach 9,895 m by 1981. Sludge dumped at
this site is composed of municipal sewage wastes resulting from primary and
secondary treatment.
New York Bight Dredged Material Site
Several locations have been used historically as sites for the disposal of
material dredged from navigable waterways in the New York-New Jersey
metropolitan area. The present site was designated in 1940 as the exclusive
disposal site for this material. Until 1973, ash residues from fossil-fueled
power plants were also permitted to be dumped at the site.
Each year, the volume of dredged material dumped at this site exceeds that
of material dumped at any other disposal site. The average annual volume of
dredged material dumped at the site from 1960 to 1977 was approximately
3
6 million m . The annual volume is estimated to increase by 46,000 to
54,000 m . The dredged material dumped at this site is composed of
particulate solids which, because of the proximity of the dredging sites to
large metropolitan areas, contains higher levels of metals than any other
material dumped in the Bight.
New York Bight Cellar Dirt Site
The history of this site is similar to the history of the Dredged Material
site. The Cellar Dirt Disposal Site has been relocated several times to
3-33
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75°
74*
73°
72°
41°
1. DREDGED MATERIAL
2. CELLAR DIRT
3. SEWAGE SLUDGE
4. ACID WASTES
5. SEWAGE SLUDGE (ALTERNATE)
6. WRECKS
7. WOOD INCINERATION
40"
39'
38°
NEW YORK
BIGHT LIMIT
41°
40°
39°
38°
75°
74°
73°
72°
Figure 3-11. Ocean Disposal Sites in the New York Bight Apex
(Boundary Shown by Dark Line)
3-34
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prevent excessive local build-up of material; it has occupied the present
location since 1940. Relatively inert materials from land-based construction
projects (demolition wastes) are dumped at the site, including excavated
earth, broken concrete, rock, and other solid materials. The average annual
3
volume of cellar dirt dumped at the site from 1960 to 1977 was 450,000 m .
The average annual volume will continue to fluctuate from year to year
according to the activity of the construction industry.
Wreck Site
The Wreck Site was designated by EPA for disposal of derelict and wrecked
vessels. The site has been used infrequently for the past 17 years, and was
moved to a new location outside major navigational lanes in 1977.
Wood Incineration Site
The EPA designated this site for burning scrap wood from decaying
structures and construction sites. The site is used as needed, and only the
combustion products reach the ocean; the remaining ash is landfilled.
Alternative Sewage Sludge Site
This site was designated by EPA in May 1979 as an alternative to the
12-Mile Site for dumping sewage sludge. It has never been used.
MARINE RECREATION
The New York Bight encompasses many Federal and State beaches and wild life
refuges, located on the coast and on offshore islands. Activities in these
areas include swimming, hiking, and fishing.
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DELAWARE BAY ACID WASTE DISPOSAL SITE
PHYSICAL CONDITIONS
Like the New York Bight, the physical environment offshore of Delaware Bay
experiences marked changes with season. Warming of surface waters in late
spring creates a strong thermocline which becomes more pronounced as summer
progresses. Spring is associated with a flow of low-salinity water out of
Delaware Bay, which lowers the salinity of the site water. In late autumn and
winter, temperature and salinity values stabilize throughout the water column
from surface to bottom. The net current flow at the site is to the southwest.
Occasionally, strong summer winds reverse the surface flow.
GEOLOGICAL CONDITIONS
The Continental Shelf bottom off the Delaware coast is a gently sloping,
relatively smooth plain superimposed with low elevation sand ridges and
swales. Other small-scale relief is superimposed on the ridges, possibly due
to the cumulative effects of seasonal storms or the effects of a particular
storm. The sediments are composed of fine- and coarse-grained sands.
CHEMICAL CONDITIONS
Despite temporary, localized fluctuations, dissolved oxygen levels of
waters off Delaware Bay show seasonal patterns and values typical of the
Continental Shelf. Values near peak saturation are found throughout the water
column during winter; the summer thermocline separates the saturated surface
layer from a Relatively depleted bottom layer.
Discussions of sediment and water column trace metal chemistry for the site
appear in Chapter 4.
BIOLOGICAL CONDITIONS
The phytoplankton communities off Delaware Bay are dominated by
dinoflagellates in the summer and by diatoms in the winter (Smith, 1973,
3-36
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1974). Zooplankton communities off Delaware Bay are similarly characteristic
of the New York Bight (Falk et al., 1974; Forns, 1973). Copepods are the most
diverse and abundant taxon, with abundance peaking in summer and fall.
The benthic macro fauna in this area are characteristic of the firm sand-
shell-gravel community existing elsewhere in the mid-Atlantic (Pratt, 1973;
Falk et al., 1974; Lear et al., 1974). Annelid worms dominate in abundance
and numbers of species. The offshore area probably serves as an incidental
spawning ground for several commercially important species of fish found
generally throughout the mid-Atlantic; however, the site supports no known
finfishery at this time. Sea scallops have been harvested near the site, and
the ocean quahog is abundant throughout the area.
WASTE DISPOSAL AT THE SITE
HISTORY
The E.I. du Pont de Nemours plant, Edge Moor, Delaware, was the only
permittee using the so-called Du Pont Disposal Site after implementation of
the ocean dumping permit program in 1973. Du Pont-Edge Moor began to
discharge acid wastes at sea on a temporary basis in September 1968, in an
area centered about 10 nmi (19 km) southeast of the more recently used site.
This alternative site was used until July 1969, pending completion of the pre-
disposal surveys in the primary area. Surveys were conducted in May and June
of 1969, and barging began in the designated site in July 1969.
RECENT WASTE DISPOSAL PRACTICES
The volume of aqueous waste released at the Delaware Bay Acid Site
decreased 92%, from 867,000 metric tons in 1973, to 69,000 metric tons in the
first quarter of 1976. Actual amounts discharged by Du Pont from 1973 to 1976
are shown in.Table 3-7. The waste disposal operation was relocated to the
106-Mile Site in March 1977.
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TABLE 3-7
QUANTITIES OF WASTES DUMPED ANNUALLY AT THE
DELAWARE BAY ACID WASTE DISPOSAL SITE
Year
1973
1974
1975
1976
1977
Amount
(Thousand Metric Tons)
867
614
365
430
69
In 1973, Du Pont waste consisted of an aqueous solutions of iron and
miscellaneous chlorides, sulfates, and sulfuric and hydrochloric acid. The
waste was 17% to 23% sulfuric acid, and 4% to 10% ferrous sulfate. The waste
was generated from the production of titanium dioxide (TiO«) by the chloride,
sulfate, and color pigment processses. The waste was modified as manu-
facturing changed from a sulfate process to a chloride process. By 1976, the
waste consisted of an aqueous solution of iron, miscellaneous chlorides, and
hydrochloric acid. The material at that time ranged between 7.3% and 16%
hydrochloric acid, formed from the chlorine used in the manufacturing process.
The process modification resulted in a decrease of waste production from 1,300
to 3,000 metric tons per day to 1,500 to 2,000 metric tons per day.
WASTE CHARACTERISTICS
Analyses of barge loads dumped from 1973' to 1976 indicated a range of
specific gravity for Du Pont waste of 1.043 to 1.204; the specific gravity of
seawater is 1.025.
The behavior of the Du Pont ferrous sulfate waste in situ was investigated
at the site from spring 1969 to spring 1971 by Falk et al. (1974). The waste
did not penetrate the thermocline during summer, spring, and fall, but during
the winter a portion of the waste did reach the seafloor as a result of
barging procedures used at that time. The water column pH was depressed
following discharge, but returned to ambient levels within four hours. Iron
was used to trace' the waste up to 10 nmi (19 km) from the discharge point.
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Falk and Phillips (1977) reported on a waste dispersion study conducted at
the site in September 1976 by EG&G. Dispersion of the ferric chloride waste
was similar to that of the ferrous sulfate waste previously tested.
Heavy metals were the most significant waste constituents, both in terms of
amounts present and potential toxicity. From 1973 to 1977, the individual
proportions of metals discharged to the total volume of discharged material,
remained relatively constant (Table 3-8). The total mass loading of each
metal decreased in a range from 28% to 76%. From 1973 to 1977, the most
prevalent heavy metals in the waste, in order of decreasing mass load, were
chromium, zinc, lead, nickel, copper, cadmium, and mercury.
TABLE 3-8
ESTIMATED QUANTITIES OF TRACE METALS DUMPED ANNUALLY
AT THE DELAWARE BAY ACID WASTE DISPOSAL SITE
Me t~ al
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Metric Tons/Year
1973
0.1
54.4
5.8
10.6
0.035
8.0
34.2
1974
0.3
44.0
2.2
6.8
0.01
5.1
21.4
1975
0.001
38.6
1.6
7.5
0.001
2.8
15.6
1976
0.001
81.4
2.0
10.4
0.001
5.8
41.0
1977
0.001
9.8
0.3
3.3
0.001
0.7
4.0
EFFECT ON ORGANISMS
Routine 96-hr bioassays and special chronic toxicity studies were used to
investigate the toxic effects of Du Pont waste on diatoms, opossum shrimp,
grass shrimp, brine shrimp, copepods, sheepshead minnows, and hard clams (Falk
3-39
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and Phillips, 1977). The waste concentrations which caused significant
mortality, or other effects, were much higher than the concentrations occurred
at the site after initial dilution. Long-term tests produced reduced growth
and decreased hatching success in minnows and shrimp. However, these effects
were believed to be caused by the presence of a waste flocculate in the test
water which impeded feeding, rather than by toxic chemical constituents in the
waste (Falk and Phillips, 1977).
Field studies at the site did not detect any effect of the waste on water
column organisms or benthic communities. However, elevated vanadium values
were observed in scallops collected in the site and southwest of the site
(Pesch et al., 1977). Iron floe was believed to be observed overlying
sediments in the vicinity, although the floe did not appear to harm organisms.
CONCURRENT AND FUTURE STUDIES
Intensive monitoring work at the Delaware Bay Acid Waste Site was concluded
with cessation of dumping; however, EPA Region III still samples historical
stations at the site with NOAA's assistance as part of the study program at
the nearby Philadelphia Sewage Sludge Disposal Site.
OTHER ACTIVITIES IN THE SITE VICINITY
COMMERCIAL AND RECREATIONAL FISHERIES
The area of the north and middle Atlantic, from Georges Banks to Cape
Hatteras, represents "one large...fish-producing unit", with few species of
fish migrating into or out of this area (McHugh, 1978). Consequently, most of
the species of finfish harvested in the New York Bight are caught near the
Delaware Bay Acid Waste Disposal Site, although smaller domestic harvests are
reported for the latter (Table 3-9).
The narrowness of the Continental Shelf in this region enables more recrea-
tional fishermen to reach the rich Shelf/Slope fishing grounds than in areas
farther north. Fishermen in the Delaware region are known to travel great
3-40
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TABLE 3-9
COMMERCIAL LANDINGS OF THREE MAJOR SPECIES OF
FINFISH FOR THE DELAWARE REGION, 1974
Species
Menhaden
Striped Bass
Whiting
000 Lb
13
212
8
$000
0.5
65
1
Source: McHugh, 1978.
distances offshore in order to fish for large game fish, but no recreational
fishing has been reported at the Delaware Bay Acid Waste Site. In 1976, 1.8
million anglers landed more than 246 million pounds of fish in the mid-
Atlantic (Chenoweth, 1976a).
OIL AND GAS EXPLORATION AND DEVELOPMENT
Figure 3-12 shows the offshore oil and gas leases granted by OCS Sale
No. 49.
SHIPPING
Delaware Bay is a major seaport, receiving nearly as much traffic as New
York Harbor. Figure 3-10 shows the two major shipping lanes into Delaware
Bay. The axes of these lanes are directed well to the north and south of the
Delaware Bay Acid Waste Disposal Site, and neither shipping lane extends
offshore as far as the site. The Barnegat Navigational Lane passes to the
east of the site. Vessels sailing north or south along the mid-Atlantic coast
use either the Barnegat Navigational Lane, or a corresponding southern lane,
to either of the access routes into Delaware Bay, not normally entering the
waters of the Acid Site. Limited ship traffic crossing the Continental Shelf
is likely to enter the site waters.
3-41
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41*
75"
1. NEW YORK BIGHT ACID SITE
2. NORTHERN AREA
3. SOUTHERN AREA
4. DELAWARE BAY ACID SITE
5. 106-MILE SITE
74°
73°
72°
40°
39°
38°
41°
40°
39*
38°
75°
74°
73°
72°
Figure 3-12.
Oil and Gas Leases Near Delaware Bay
Source: BLM, 1978.
3-42
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OCEAN WASTE DISPOSAL
The Philadelphia Sewage Sludge Disposal Site is southeast of the Acid Waste
Site and is the only other disposal site in the vicinity. The Sewage Sludge
Site received an annual average of 604,000 metric tons of anaerobically
digested sewage sludge from 1973 to 1977.
3-43
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Chapter 4
ENVIRONMENTAL CONSEQUENCES
Use of the 106-Mile Site will have some environmental
consequences; however, most of these effects would occur at
any ocean location used for disposal of these wastes. The
extreme depth of water and low biological productivity of the
106-Mile Site preclude many effects that would be expected at
a shallower site. Adverse effects at the site are mitigated
by the rapid dilution and dispersion of the wastes. In all,
the potential environmental consequences of continuing to use
the 106-Mile Site for disposal of wastes are judged less
serious than the potential environmental consequences of
dumping at the alternative sites.
This chapter describes the scientific and analytic bases for evaluating
alternatives discussed in Chapter 2. The discussion includes potential
environmental impacts of the various alternative sites considered in
Chapter 2, together with any adverse environmental effects which cannot be
avoided should the proposed action be implemented. The relationship between
short-term uses of the environment and the maintenance and enhancement of
long-term productivity and any irreversible or irretrievable commitments of
resources which would be involved in the proposal are considered.
The chapter first addresses the effects on public health, specifically
by commercial or recreational fisheries and navigational hazards. Next, the
environmental consequences of chemical waste disposal at each alternative site
are assessed, including effects on the biota and on water and sediment
chemistry of the site. Effects of short-dumping in non-designated areas are
also addressed.
(
A large body of data was examined to evaluate the potential effects of
chemical waste disposal at these sites. The principal data sources for each
area are:
106-Mile Site: NOAA surveys, starting in 1974; waste dispersion
studies and monitoring of short-term disposal effects sponsored by
the permittees; and public hearings concerning relocation of sewage
sludge disposal sites and issuing of new permits.
4-1
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• New York Bight Acid Wastes Site: NOAA-MESA studies beginning in
1973; NMFS/Sandy Hook Laboratory study from 1968 to 1972;
site-specific studies sponsored by NL Industries, Inc., beginning in
1948; and routine monitoring surveys sponsored by the permittees.
• Delaware Bay Acid Waste Site: EPA surveys beginning in 1973, and
studies sponsored by Du Pont, beginning in 1968.
• Southern Area: NOAA survey in 1975, and public hearings concerning
the disposal of sewage sludge in the New York Bight.
• Northern Area: NOAA and Raytheon surveys in 1975, and hearings
concerning the disposal of sewage sludge in the New York Bight.
Data from these and other sources were collected and compiled into an
extensive data base dedicated to ocean environment data management and
evaluation. The following discussion is based on an evaluation of the
available data.
EFFECTS ON PUBLIC HEALTH AND SAFETY
The possible direct or indirect link between man and contaminants in the
waste is a primary concern in ocean waste disposal. A direct link may affect
man's health and safety. An indirect link may cause changes in the ecosystem
which, although they do not appear to affect man, could lead to degraded
quality of the human environment.
COMMERCIAL AND RECREATIONAL FISH AND SHELLFISH
The most direct link between man and waste contaminants released into the
marine environment is through the consumption of contaminated seafood.
Shell fishing, for example, is automatically prohibited by the Food and Drug
Administration around sewage sludge disposal sites, or in other areas where
wastes are dumped which may contain disease-producing (pathogenic) micro-
organisms. In this way, the consumption of uncooked shellfish which may be
contaminated with pathogens is either eliminated or minimized. Harmful
effects caused by eating fish containing high levels of mercury, lead, or
persistent organohalogen pesticides have been documented (Subcommittee on the
4-2
-------
Toxicology of Metals, 1976). Certain compounds (e.g., oil) have been shown to
make the flesh of fish and shellfish not only unhealthy, but unpalatable.
Therefore, ocean disposal of wastes containing heavy metals, organohalogens,
oil, or pathogens are carefully evaluated with respect to the possible
contamination of commercially or recreationally exploitable marine animals.
A foreign longline fishery exists on the Continental Slope, but most U.S.
fishing in the mid-Atlantic is restricted to waters over the Continental
Shelf. Commercial fishing and sportfishing on the Shelf are wide-ranging and
diverse; both finfish and shellfish (molluscs and crustaceans) are taken. The
New York Bight is one of the most productive coastal areas in the North
Atlantic, and the region may be capable of even greater production when new
fisheries develop.
Important spawning grounds and nursery areas exist within the Bight, but
critical assessments of the effects of man-induced contamination on fish and
shellfish populations are lacking. Many factors complicate the collection and
assessment of these data. For example, normal short-term and long-term
population cycles are not well understood, catch data are generally inadequate
for reliable assessments, and the complete life cycle and distribution of the
stock may be unknown. Natural population fluctuations, overfishing, and
unusual natural phenomena may have greater influences on the health and extent
of the fisheries resource than man-induced contamination. Therefore,
assessing the effects of ocean disposal includes uncertainties due to
inadequate existing fisheries information.
106-MILE SITE
Waste disposal at this site will not directly endanger human health. The
site is not in a commercially or recreationally important fishing or
shellfishing area. Infrequent domestic and foreign fishing occur at or near
the site; however, the usage is variable and dependent upon occurrence of
water masses or eddies that affect fish abundance and distribution. The fish
larvae occurring near the site are not well known, but the site is within the
range of commercially and recreationally valuable species (Casey and Hoenig,
1977). Disposal activities at the site will have an unknown but probably
4-3
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localized effect on the larval stages of these species. The NOAA resource
assessment surveys do not extend beyond the Shelf; however, the densities of
fish eggs and larvae are thought to be low. Bioassays to determine the
effects of waste disposal on these species or their prey have not been
conducted; however, the results of toxicity tests on EPA-approved organisms
suggest that disposal operations will have an insignificant effect on the
biota at the site.
A small commercial fishery for the deep sea red crab (Geryon quinquedens)
is concentrated in depths of 300 to 500 m, and does not presently exist at the
106-Mile Site or in water depths similar to those at the site (Wigley,
personal communication). Greatest densities and biomass of red crabs exist at
intermediate depths of 320 to 640 m (Wigley et al., 1975). The extent of
recruitment of red crabs used by the commercial industry is dependent on
individuals migrating from deeper water. Adequate abundance and size-class
data for the red crab are not presently available and additional studies are
needed (Wigley, personal communication). The effect of disposal operations on
the planktonic larvae of red crabs is unknown but is expected to be localized.
Lobsters (Homarus americanus) are found from the low intertidal to at least
700-m depths, with the potential commercial resource occurring from 90 to 450
m depth (Larsen and Chenoweth, 1976; Gusey, 1976). Lobster fishing does not
presently exist at the 106-Mile Site or in water depths similar to those at
the site.
As with finfish, the probability of the wastes affecting benthic animals
including red crabs or lobsters is extremely low. Therefore, disposal at this
site does not directly endanger human health by contaminating edible
organisms.
NEW YORK BIGHT ACID WASTES SITE
There is a real, albeit low, potential for endangering public health from
additional industrial waste disposal at this site. The site location was
chosen 30 years ago because it had no history as a point of concentration for
fish or productive fishing (Westman, 1958). Since that time, the site has
4-4
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apparently become a sportfishing area because the discoloration of the water
caused by acid-iron waste disposal either attracts fish or increases catches
of available fish, including bluefish, a prized sport fish.
During winter, a commercial whiting fishery exists near the Acid Site and
the site continues to be fished by recreational fishermen. There is a
potential health problem if additional wastes are released. Increased waste
disposal at the site could lead to accumulation of materials in toxic
concentrations within the tissues and organs of these fish, and subsequent
consumption of contaminated fish could pose a threat to the public health. No
health problems associated with sport fish caught at the site have been
reported. Although adverse effects have been observed in fish eggs exposed to
moderately high concentrations of acid waste (Longwell, 1976), tainting or
harmful accumulations of waste components in the flesh of fish taken from the
area have not been reported.
Lobsters are the only shellfish which can be exploited near the site.
Waste constituents could reach bottom at this shallow site and be incorporated
by the animals, but other sources of contamination (e.g., sewage sludge) are
probably more significant. The New York Bight Sewage Sludge Site is located
only 5 km from the Acid Site.
DELAWARE BAY ACID WASTE SITE
A potential exists for endangering public health from chemical waste
disposal at this site. Although the site and vicinity do not support a
finfishery, a potentially valuable ocean quahog resource exists to the
southwest. As a result of the decline in the surf clam (Spisula solidissima)
fishery, the National Marine Fisheries Service has encouraged development of a
market for the ocean quahog (Arctica islandica), another clam which is
abundant in the coastal area containing the disposal site (Breidenbach, 1977).
In addition, sea scallops (Placopecten magellanicus) are harvested. The
extent of past fishing from the immediate vicinity of the disposal site . is
unknown. The FDA has banned shellfishing in the area because of the presence
of the sewage sludge disposal site nearby.
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Effects due to acid waste disposal are difficult to discern from effects of
sludge disposal, but there are relative differences in the chemical
composition of these wastes (e.g., higher concentrations of iron and vanadium
in the acid waste) that may be useful as environmental tracers. There are
several indications that disposal of acid-iron wastes in shallow water may
result in some waste constituents reaching the seafloor: (1) reports of
acid-iron floe on the bottom at acid waste sites (Folger et al., 1979; Vaccaro
et al., 1972), (2) elevated iron concentrations in sediments (Lear et al.,
1974; Falk et al., 1974), and (3) elevated concentrations of vanadium in
scallops collected near the site (Pesch et al., 1977).
The site has been closed to some shellfishing for several years because of
concern for potential bacterial contamination resulting from nearby sewage
sludge disposal. Scallops are not included in the ban because the parts
consumed (muscle tissue) are not known to concentrate contaminants from sludge
disposal. Although there are no established links between elevated vanadium
concentrations such as those measured in scallops near the site and threats to
public health, renewed industrial waste dumping does not seem prudent in
shallow areas such as the Delaware Bay Site (40 m depth) which may be subject
to the accumulation of floe or other waste-generated particulates.
SOUTHERN AREA
There is a moderate potential for endangering public health from chemical
waste disposal at this site. Surf clams, ocean quahogs, and scallops are
abundant in the Southern Area, although most present commercial shellfishing
occurs far to the west, near the New Jersey coast. However, declining
harvests may cause the Southern Area to be exploited in the future (EPA,
1978). Recreational fishing is unlikely at this site due to its distance from
shore and the competition provided by equally attractive sportfishing areas
closer to shore. If this area were used as a disposal site for wastes similar
to those presently being disposed of at the 106-Mile Site, the potential for
an accumulation of waste constituents on the seafloor and in the flesh of
shellfish would be greater because of the shallow water depth at this site
(40 m).
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NORTHERN AREA
It is probable that disposal of aqueous chemical wastes in this area would
not directly endanger public health. This site is not in a known area of
commercially or recreationally important fishing or shell fishing, although
scallops may be present in commercially exploitable numbers. If this resource
is developed in the future, disposal operations could result in the
accumulation of some waste constituents in the organisms. Water depths at the
site are shallow (55 m) and disposal operations would be associated with the
same risk of floe accumulation as noted for the Delaware Bay Acid Site and the
Southern Area.
NAVIGATIONAL HAZARDS
Navigational hazards may be separated into two components: (1) hazards
caused by the movement of transport barges/vessels to and from a site, and (2)
hazards caused by barge maneuvering within the site.
If an accident caused chemical wastes to be released, the effects from the
dumped waste would probably be equivalent to a short dump. The effects of
colliding with another ship would depend upon its cargo, and could be severe
if the barge collided with an oil or liquefied natural gas (LNG) tanker.
There is a possibility of loss of life in any collision.
The following discussion concentrates on the barging operations from New
York Harbor, since most traffic to the 106-Mile Site originates in New York
and New Jersey. Du Font-Edge Moor is the only permittee transporting wastes
from other areas. The most serious hazard from any ocean dumping activity
would be an accident occurring close to shore where ship traffic is
concentrated. The ramifications of a spill from a waste barge or tanker are
most serious. This hazard is one that is associated with all ocean dumping,
no matter where the disposal site is located, since all trips to an ocean
disposal site begin in a coastal port. Accordingly, this section discusses
only the relative risks associated with transporting wastes beyond the coastal
ports to each of the alternative disposal sites, and the risks associated with
on-site disposal operations.
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The hazards associated with increased usage of the New York Bight Acid
Waste Site are the most severe, due to the heavy shipping traffic associated
with New York Harbor. Hazards could increase in the Southern Area as mineral
development proceeds in that area. The 106-Mile Site is the preferred choice,
because if any accident occurred at the site, wastes would not be released
into coastal waters (possibly threatening fishing or other activities), but
much farther offshore where shipping activity is limited.
106-MILE SITE
Barges in transit to the 106-Mile Site from New York Harbor use the
Ambrose-Hudson Canyon traffic lane for most of the journey. Compared to a
coastal site, there may be a slightly greater risk of collision during the
round-trip transit to the 106-Mile Site because of the additional distance
travelled. If danger to life results from a barging accident, the greater
distance offshore would result in longer search and rescue response time than
for accidents closer to shore.
Hazards resulting from maneuvers of vessels within the site are negligible.
The site is extremely large, and permittees are required to use different
quadrants. The frequency of all barging is low, averaging only 2 to 3 times
per week. A moderate increase in frequency of dumping at the site would not
significantly affect navigational difficulties.
NEW YORK BIGHT ACID WASTES SITE
The New York Bight Acid Wastes Site is situated across one of the outbound
traffic lanes from New York Harbor, but the current barging operations within
the site are designed to minimize interference with traffic. The permittees
using the site barge wastes on an average of once or twice a day. Additional
use of the site would increase the possibility of collisions either between
barges or the heavy shipping traffic into and from New York Harbor, since the
site is rather small. There is a risk that any accidents would be close to
New Jersey or Long Island beaches.
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DELAWARE BAY ACID WASTE SITE
Use of the Delaware Bay Acid Waste Site would not be expected to pose
significant navigational hazards, aside from accidents which might occur
during round-trip transit from New York Harbor. Any accidents could release
wastes in the coastal waters off New Jersey where fishing and swimming are
prevalent.
SOUTHERN AREA
The Southern Area lies outside the traffic lanes for New York Harbor,
therefore use of this site would pose few navigational hazards for shipping.
However, additional ship traffic resulting from offshore oil and gas
development would increase the hazard. The degree and extent of such hazards
would depend upon the rate and magnitude of the oil and gas development in the
area. Any accidents would probably take place in the heavily fished coastal
waters off New Jersey.
NORTHERN AREA
The Northern Area lies outside the traffic lanes for New York Harbor, thus
use of this site poses few navigational hazards. Mineral resources are not
located in the area, so there is no probability of increased hazards due to
future resource development. Any accidents would occur near coastal waters
off Long Island.
EFFECTS ON THE ECOSYSTEM
The adverse effects of ocean disposal on the ecosystem can be subtle, and
may not exhibit obvious direct effects on the quality of the human environ-
ment. These subtle adverse impacts can accumulate over the long term with
consequences as serious as any readily observed direct impacts. For example,
an organism may accumulate waste constituents in its tissues at concentrations
that do not cause its immediate death but, instead, act at the sublethal or
chronic level. Such adverse sublethal effects may reduce reproduction, reduce
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health of eggs and larvae, slow development of juveniles, or affect other
facets of the life cycles of individual organisms and may ultimately result in
adverse changes in the entire population of this organism. The population may
eventually be eliminated from an area, not because it was immediately killed
by a single waste discharge but because of the accumulation of sublethal
effects over time. If that population were a major human food source or part
of the food chain for an organism which was exploited commercially, man would
lose the resource. This scenario is vastly simplified, and is not a
projection of current events resulting from industrial waste disposal in the
ocean; however, it does illustrate that man, as an integral part of a complex
ecosystem, may ultimately feel the results of adverse impacts on other parts
of the ecosystem.
The magnitude of the effects of waste disposal on the marine ecosystem
depends upon several factors: (1) the type of waste constituents, (2) the
concentration of toxic waste materials in the water and sediments, (3) the
length of time that high concentrations are maintained in the water or in the
sediments, and (4) the length of time that marine organisms are exposed to
high concentrations of these materials. Present 106-Mile Site disposal
techniques for aqueous chemical wastes maximize the dilution and dispersion of
the wastes, thus minimizing the chances for wastes to remain in the water
column or to reach the bottom in high concentrations.
Dispersion studies (discussed further in Appendix B) have been conducted on
most of the wastes presently dumped at the site. In all cases, high initial
dilution occurs as the materials flow from the moving barge and are mixed in
the turbulent barge wake. After the period of initial mixing, a plateau
concentration is reached which persists for about a day (NOAA, 1978). Little
data exist for the dilution after this time period. Laboratory studies of the
effects of the wastes on organisms have shown that adverse effects occur only
at concentrations several times higher than those which persist for any length
of time at the site.
Each of the Du Pont wastes forms a particulate floe when mixed with
seawater. These particulates are believed to provide surfaces for adsorption
of some trace metals. For example, laboratory studies have shown that the
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floe which forms when Grasselli waste is added to seawater contains 20% of the
copper, approximately 40% of the cadmium, and most of the lead in the original
liquid (Kester et al., 1978). Particulates may be consumed by organisms at
the site, thus providing a mechanism for uptake of some metals.
Dispersion studies at the 106-Mile Site have successfully tracked these
floe-forming wastes by using acoustic devices to locate the particles. Upon
release from the barge, the wastes have been observed to form thin layers
along density gradients, such as those associated with thermoclines, rather
than mixing uniformly throughout the water column. Industrial waste was
observed to disperse above the seasonal thermocline in summer, and to descend
only as far as the permanent thermocline in winter. Because thermoclines are
characteristic areas of association for plankton and nekton, exposure of these
organisms to waste particulates may be increased over exposure in the waters
above the thermocline. Specific effects of this exposure on organisms are
unknown, but because the wastes are retained in the upper layers at the site,
the organisms most likely to be affected by the waste are those in the upper
waters.
Bisagni (1976) described the occurrence of Gulf Stream eddies at the
106-Mile Site, which form the bases of the following discussion.
Wastes dumped at the site when a Gulf Stream eddy is present may be
entrained by the eddy. However, the infrequent occurrence of eddies at the
site (approximately three per year), and their large size, suggest that eddies
will not act as significant waste-concentrating mechanisms. Residence times
of eddies reported at the site during 1974 and 1975 ranged from 2 to 55 days.
The mixing zone represented by an eddy is roughly 60 nmi (110 km) in diameter
and 1,000 m deep - a volume of about 1 x 10 liters for potential dilution,
or roughly 1,000 times the mixing volume provided by a quadrant of the site
under worst-case conditions.
A hypothetical worst-case situation can be constructed, based on the
following factors:
• A stationary eddy 60 nmi in diameter and 1,000 m deep (volume
1 x 1016 liters).
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• Normal waste dumping for 55 days (using projected 1979 values
from Table B-2 in Appendix B; approximately 1 x 10^ liters).
Based on these factors, the ratio of total dilution volume (1 x 10
Q
liters) to 55-day waste input (1 x 10 liters) is 100,000,000:1, a significant
dilution factor.
PLANKTON
The plankton consist of plants (phytoplankton) and animals (zooplankton)
which spend all or part of their lives in the water column. Aqueous wastes
primarily affect the water column, thus plankton represent the first level of
the ecosystem where the effects of waste disposal are likely to be observed.
Accordingly, numerous studies on planktonic organisms have been conducted at
ocean disposal sites.
106-MILE SITE
Numerous field investigations of plankton at the 106-Mile Site have shown
the normal assemblage to be highly variable, primarily due to the presence of
several water masses, each with somewhat different species (Austin, 1975;
Sherman et al., 1977; Hulburt and Jones, 1977). Because of this high natural
variability, long-term changes in plankton species composition, abundance, and
distribution, even if caused by waste disposal activities at the site, may
never be demonstrated. Future field studies of plankton will concentrate on
plankton present in the waste plume to determine the extent of localized
effects.
Some field work at the site has concentrated on specific plankton
population components rather than considering whole populations or
assemblages. Preliminary studies of fish eggs and embryos collected from the
site when sewage sludge and acid waste were present showed severe effects on
the chromosome and initotic apparatus of the dividing embryos and malformations
in the more developed embryos (Longwell, 1977). The field sampling routine
did not, however, result in the collection of samples large enough to permit
statistically valid conclusions.
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Field and laboratory studies have assessed the effects of waste on the
native bacteria populations from the site (Vaccaro and Dennett, 1977). These
investigators tested the hypothesis that bacterial species at the site would
be more tolerant of environmental changes than those outside the site. Field
collections showed no tolerance differences in bacteria taken from inside and
outside the disposal site; however, laboratory "exposure of mixed bacterial
populations to. . .Cyanamid waste resulted in...pure cultures showing an
increase in waste tolerance." Du Pont-Grasselli and American Cyanamid wastes
inhibited assimilation of organic carbon by bacteria. Additional work with Du
Font-Edge Moor and Du Pont-Grasselli waste indicated that "the principal toxic
components of Edge Moor waste are trace metals, whereas organic species appear
to dominate with regard to Grasselli waste" (Vaccaro and Dennett, 1978). The
investigators did not attempt to correlate the laboratory work with actual
conditons at the site.
Laboratory studies of the toxicity of 106-Mile Site wastes to plankton have
been performed by many investigators (Murphy et al., 1979; Capuzzo and
Lancaster, 1978; Lawson in Capuzzo and Lancaster, 1978). Studies have been
made on effects of acid-iron wastes which are similar to Edge Moor waste and
dumped at the New York Bight Acid Site (Grice et al., 1973; Vaccaro et al.,
1972). Additionally, 96-hr bioassays are routinely conducted using
EPA-approved species in accordance with the special conditions of each ocean
dumping permit. In all, a variety of planktonic species have been tested for
effects: Diatoms (e.g., Skeletonema costatum, Thalassiosira pseudonana, and
Emiliana huxleyi) and several copepods (e.g., Acartia clausi, Centropages
typicus, Calanus finmarchicus, Pseudocalanus sp., Pseudodiaptomus coronatus,
Temora longicornis, and Artemia salina).
In general, significant mortality occurs only at waste dilutions several
times higher than those observed to persist longer than a few minutes at the
site. Hulburt and Jones (1977) reported that at least half a dozen cells of
several species showed no effects after being kept in barge water for
approximately six hours. However, sublethal effects, such as decreased
feeding rates, have been observed at lower concentrations (Capuzzo and
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Lancaster, 1978), and require further investigation. Low concentrations of
Grasselli waste were observed to stimulate growth of diatoms; higher
concentrations of the same waste inhibited growth (Murphy et al., 1978).
In tests with clones of oceanic and neritic diatoms, variable sensitivities
to Grasselli waste have been observed (Murphy et al., 1979). None of the
clones were inhibited at the highest waste concentration which persists for
any length of time at the site. Clones of species taken from coastal waters
were more tolerant of higher concentrations of the waste than clones of the
same species taken from ocean water. Thus, phytoplankton at the 106-Mile Site
may be more sensitive to waste inputs than nearshore phytoplankton. Studies
on the subject will continue.
Results of routine bioassays of barge samples are discussed in Appendix B.
Most of the results show wide ranges of 96-hr LC50 values. The results of
these studies demonstrate that little is known about the interaction of
plankton and chemical wastes in marine waters. Furthermore, the comparability
of controlled laboratory experiments to the conditions existing at the
disposal site during waste release is unclear, as are the mitigating effects
of the rapid dilution and dispersion of the waste. It is difficult to make
unequivocal predictions of long-term consequences of waste discharge on
plankton at this site; however, the short-term effects are generally known and
limited to the waste plume. Future time series phytoplankton studies may
answer some of these questions.
NEW YORK BIGHT ACID WASTES SITE
The effects of past waste disposal on plankton at the New York Bight Acid
Wastes Site have been studied extensively. Field studies during waste
discharges have shown that NL Industries and Allied Chemical acid-iron wastes
do not have a significant adverse effect on zooplankton populations (Wiebe et
al., 1973; Redfield and Walford, 1951). Evidence of chromosomal damage in
mackerel eggs collected in the site vicinity has been reported (Longwell,
1976), but the cause of the damage could not be definitely linked to the
disposal of acid wastes. Interpretations of field results from this site are
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difficult; changes in plankton populations resulting from acid waste disposal
at the New York Acid Waste Site cannot generally be distinguished from changes
caused by pollutants introduced from other sources within the New York Bight.
Laboratory studies show that the acid wastes presently released at this
site can cause chronic effects in zooplankton after prolonged exposure to
waste concentrations greater than those encountered under field conditions
(Grice et al., 1973). Sublethal effects (e.g., failure to reproduce and
extended developmental times) have been demonstrated in the laboratory after
21 days of exposure to waste, in concentrations that persist for only minutes
after actual discharge of wastes at the site (Vaccaro et al., 1972).
As in the case of the 106-Mile Site, long-term effects on plankton caused
by dumping 106-Mile Site wastes at the nearshore site are difficult to predict
at this time. Excluding differences in sensitivity between plankton at this
nearshore location and plankton in the open ocean, the effects at the two
sites would be comparable. However, if the plankton inhabiting waters at the
Acid Site were less sensitive to contaminants, the effect of the waste input
on indigenous plankton could be less at this site than at the 106-Mile Site.
Even so, the number of organisms affected might be less at the 106-Mile Site
because of the reduced biomass at the offshore environment in comparison to
the nearshore environment.
DELAWARE BAY ACID WASTE SITE
No long-term effects of acid waste disposal on plankton at the Delaware Bay
Acid Site have been demonstrated. Elevated concentrations of certain trace
metals (nickel, mercury, and manganese) were observed in zooplankton collected
in the area (Lear et al., 1974), but the values were extremely variable. As
in other alternative sites, future chemical waste disposal at this site should
not have any demonstrable long-term effects on plankton species composition,
distribution, or abundance. The likelihood and magnitude of effects on other
plankton parameters would depend upon the disposal volumes and frequencies.
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SOUTHERN AND NORTHERN AREAS
Industrial waste disposal at either the Southern or Northern Areas would
not be expected to have significant long-term effects on plankton. These
areas are outside the highly stressed New York Bight Apex; therefore,
indigenous biota are less likely to be adapted to many man-induced environ-
mental factors. Specific effects would depend upon the nature and volume of
the waste and the frequency of disposal. Based on the existing wastes and
volumes, any effects would be difficult to demonstrate since plankton
populations are so variable.
NEKTON
The nekton include animals (e.g., fish and mammals) capable of swimming and
migrating considerable distances.
106-MILE SITE
Continued disposal of chemical wastes at this site should not significantly
affect nekton other than causing temporary avoidance of the area. The results
of field investigations of effects of dumping on fish populations at the
106-Mile Site have been inconclusive because the field work has been conducted
primarily during the infrequent presence of Gulf Stream eddies.
NOAA (1977) reported that total fish catches were comparable inside and
outside the disposal site; however, midwater fish were more abundant outside
the site boundaries. The lowest catch rate occurred on a night following a
dump, but it is not known where the tows were located relative to the waste
plume.
Investigations of histopathology in fish collected from the disposal site
have been inconclusive (NOAA Pathobiology Division, 1978). Although lesions
were observed in some fish, the sample sizes were too small to permit
statistically valid conclusions. High cadmium levels were found in the livers
of three swordfish from the site area, and high mercury levels were observed
in muscle of almost all fish that were analyzed (Greig and Wenzloff, 1977).
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However, the elevated concentrations were not attributed to disposal
operations at the 106-Mile Site because of the low amounts of these metals
added to the area by disposal and the wide-ranging movements of these fish.
The effects of waste disposal on the site micronekton are unknown. Since
micronekton constitute a food source for the large predators, it is
conceivable that micronekton could uptake contaminants and transfer them
through the food web. However, the trophic relationships within many
biological systems are not well understood, nor are the rates and mechanisms
of uptake and transfer of contaminants. Therefore, no reliable prediction of
long-range effects can be made, and future studies should address this
subject.
ALTERNATIVE SITES
None of the numerous studies on nekton at the New York Bight Acid Waste
Site have detected long-term effects attributable to acid waste disposal. As
a result of the many other contaminant inputs to the Bight Apex, in addition
to those at the Acid Site, it is unlikely that any deterioration of fish
health or populations could ever be demonstrated to be solely due to acid
waste disposal. Therefore, the effects of additional chemical waste disposal
on fish populations at this site are difficult to predict. However,
considering (1) the dilution and dispersion of wastes presently released,
(2) the absence of dead fish in the wake of disposal barges, and (3) the
ability of fish to move away from temporarily stressed areas, it is unlikely
that disposal of other chemical wastes (which comply with the impact criteria)
at the New York Bight Acid Waste Site would have any demonstrably adverse
effects. This same conclusion also applies to the other alternative sites.
The risks associated with the consumption of sportfish taken from the New York
Bight Acid Waste Site were previously discussed.
BENTHOS
The benthos consists of animals living on (epifauna) and in (infauna) the
sediments. Epifauna at the sites are represented primarily by echinoderms and
crustaceans, whereas the infauna primarily include small annelid worms and
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molluscs. Benthic organisms can be important indicators of waste-related
impacts because they are sedentary, and thus incapable of leaving a stressed
environment. Many are commercially valuable (e.g., shellfish), or serve as
food sources (e.g., worms) for valuable species.
106-MILE SITE
No effects of chemical waste disposal on the benthos at the 106-Mile Site
have been observed. The species composition and diversity at the site are
similar to those observed in nearby Continental Slope areas (Pearce et al.,
1975; Rowe et al., 1977). Analyses of trace metal contents in benthic
invertebrates indicate values within the range of background values (Pearce et
al., 1975). The results are expected since the low density liquid waste
should not reach bottom in measurable concentrations, because of the
tremendous dilution due to the depth and movement of water at the site.
Therefore, continued disposal of low-density aqueous wastes should not affect
benthic organisms at or near the site.
NEW YORK BIGHT ACID WASTE SITE
The New York Bight benthos exhibits natural temporal and spatial
variability which is substantially greater than any changes resulting from the
disposal of acid wastes (Pearce et al. , 1976a, 1976b). Any effects arising
from acid waste disposal are probably overshadowed by effects from the
numerous other contaminants introduced to the New York Bight, particularly
from the Sewage Sludge and Dredged Material Sites and water flowing into the
Bight from New York Harbor. Due to the complex relationship between natural
variability and contaminants introduced by other sources, it is extremely
difficult to isolate and quantify effects at the site caused solely by the
disposal of acid waste. Consequently, it is also difficult to predict the
consequences of releasing wastes from the 106-Mile Site at the New York Bight
Acid Waste Site. The ecosystem of the Bight Apex is already highly stressed,
and disposal of additional materials may increase that stress, perhaps causing
significant environmental consequences.
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DELAWARE BAY ACID WASTE SITE
Investigations of trace metals in organisms in and around the Delaware Bay
Acid Site showed elevated vanadium in the viscera of sea scallops south of the
site in the direction of the net current flow (Pesch et al., 1977; Reynolds,
1979). Du Font-Edge Moor wastes were still being released at the site when
these surveys were conducted. Because Edge Moor waste is high in vanadium,
and because there are no other known significant anthropogenic sources of
vanadium in this area, vanadium is felt to be a tracer of these acid wastes.
SOUTHERN AND NORTHERN AREAS
The benthic organisms at Southern and Northern Areas are similar to those
observed at the Delaware Bay Acid Waste Site. Since the sites are similar,
especially the shallow water depth, analogous effects are anticipated to occur
if industrial waste disposal is initiated there.
WATER AND SEDIMENT QUALITY
The Ocean Dumping Regulations address changes in the quality of water and
sediments in a disposal site and in adjacent areas. When these changes can be
attributed to materials dumped at a site, EPA must modify site use. This
section discusses field studies of water and sediment quality conducted at the
106-Mile Site. Field studies conducted at the New York Bight and Delaware Bay
Acid Sites are discussed as they pertain to predicting the effects expected if
106-Mile Site wastes were dumped at the shallow sites rather than the deep
oceanic site. Predictions of the environmental consequences of using either
the Northern or Southern Areas are based primarily on the studies of the two
other shallow sites.
106-MILE SITE
Water and sediments at the 106-Mile Site were sampled as part of NOAA's
baseline research program in an effort to define the natural variation of site
characteristics over space and time. NOAA has sponsored studies of the
behavior of the major wastes being discharged at the site, including dilution
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and dispersion of materials, and the effect of dumping on selected water
column parameters. Considerable experimentation and refinement of field and
laboratory techniques have been required, since normal concentrations of many
of the parameters are barely detectable, and little comparable historical work
has been done at similar locations so far from shore.
In addition to NOAA's studies, the permittees have contracted with
Hydroscience, Inc., to conduct quarterly monitoring surveys. This monitoring
program concentrates on the short-term fate of the dumped materials in order
to confirm compliance with the Ocean Dumping Regulations with respect to
dilution of wastes upon initial mixing.
Emphasis is placed on the NOAA and Hydroscience work at several places
within this EIS. Appendix A describes the environmental characteristics of
the site and details specific studies of the environmental effects of dumping.
Appendix B provides a detailed discussion of the major wastes being discharged
at the site, with descriptions of the chemical characteristics and behavior in
the water after release. Appendix C describes the monitoring program
sponsored by the dumpers.
Trace Metals
Trace metals are the most potentially harmful components of industrial
wastes. The wastes dumped at the 106-Mile Site contain metals in concen-
trations several times higher than background levels in the water at the site.
Past work at the site has focused on determining the normal ranges of
background concentrations and the effects of waste dumping on these
concentrations. Despite conflicting observations of background concentrations
of water column trace metals in the early site surveys (Hausknecht, 1977;
Brezenski, 1975), refinement of sampling techniques during later surveys
yielded background levels within the range of values reported in the
literature for similar regions (Hausknecht, 1977; Kester et al., 1978;
Hausknecht and Kester, 1976a,b).
Kester et al. (1978) discussed the accuracy and precision of values of
metal concentrations analyzed in samples taken at the 106-Mile Site (Table
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4-1). Detection limit was defined as twice the variability introduced by the
analytical instruments. Reference samples (blanks), which were determined by
re-extracting seawater samples, accounted for metals added with analytic
reagents and handling procedures. Extraction efficiency was determined using
radioactive tracers which were added to a series of seawater samples.
Precision was based on analyses of triplicate samples to provide a range of
concentrations.
Considerations of accuracy and precision are useful for interpreting
variations in metal concentration data, whether by several investigators, or
within data generated by an individual investigator. Examination of Table 4-1
shows that the zinc analyses are not as reliable as those of the other metals
because of the low extraction efficiency and relatively high variability in
blanks and samples. The reagents appear to affect the iron blank, causing it
to be high; however, values are reasonably consistent within a data set. In
reporting values for iron, lead and zinc, the investigators have not corrected
the measured values for the blank values because the sources of the blanks are
still under assessment; thus, the reported values for these metals represent
the oceanic concentration plus the analytical blank. The cadmium blank has
been ignored because it is so low. Copper values have been adjusted for the
blank.
TABLE 4-1
CHARACTERISTICS OF THE TOTAL METAL ANALYSES USED IN
STUDIES AT THE 106-MILE SITE
Metal
Cadmium
Copper
Lead
Iron
Zinc
Detection
(ng/kg)
1
5
5
30
8
Blank
(ng/kg)
1 +_ 1
16 +_ 10
15 + 19
230 +_ 36
400 +_ 230
Efficiency
(%)
90 +_ 1
99 +_ 3
97 +_ 2
92 +_ 1
48 +_ 2
Precision
for a range
(ng/kg)
+2 for 6-20
+_20 for 100-400
+20 for 50-200
^60 for 400-1,400
+_140 for 500
Source: Kester et al. (1978).
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Kester et al. (1978) reported the results of field studies of several waste
dumps. A Grasselli waste dump resulted in concentrations of dissolved copper
and cadmium, and particulate lead, which were elevated in comparison to values
from water outside of the site. However, these elevated values are within the
range of natural variability observed for the area. Monitoring of an Edge
Moor dump yielded elevated concentrations of iron throughout the 27-hour
period studied after the dump. Total and particulate copper, cadmium, and
lead concentrations were also altered. Hydroscience (1978 a-h, 1979 a-d)
reported no mercury or cadmium values exceeding the limited permissible
concentration after initial mixing upon discharge.
Disposal of Du Font-Edge Moor or Grasselli waste in seawater results in the
formation of a precipitate or floe composed primarily of ferric hydroxide or
magnesium hydroxide. Kester et al. (1978) concluded that dilution of the floe
would occur in the water column above the seasonal or permanent thermocline,
thereby restricting the impact, if any, to water column organisms since the
material would not settle to the seafloor in measurable quantities. Potential
consequences of floe formation are increased adsorption of toxic metals by the
waste particles, and increased turbidity in the water column.
Kester et al. (1978) concluded that the Edge Moor and Grasselli floes
provide adsorptive surfaces for some metals which can be toxic if taken up by
planktonic filter feeders and transferred through the food chain.
Water column samples analyzed following disposal operations indicated
significant increases in total particulate iron, copper, cadmium, and lead,
total suspended matter (TSM), and a high correlation of iron with lead,
cadmium, copper, and TSM (Kester et al., 1978). However, copper and cadmium
are primarily associated with the liquid phase thereby reducing availability
for uptake by organisms. Lead is associated with the particulate phase,
although it does not appear to be concentrated above the level contributed by
the waste. Cadmium persists for a longer period of time in the water column
than iron due to the association of cadmium with the soluble phase, whereas
particulate iron settles out at a faster rate.
4-22
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Laboratory analyses of Grasselli waste mixed with seawater indicate that
20% of the copper, 40% +_ 10% of the cadmium and most of the lead (80%) are
associated with the floe. Formation of these precipitates may be increased by
deposition of calcium carbonate (CaCO ). Near-surface waters are generally
supersaturated with CaCO-, which may cause the floe and associated metals to
be fairly persistent.
Total iron concentrations in the water column were determined to be a good
indication of the persistence of acid waste. Elevated concentrations of
particulate iron, copper, cadmium, and lead were measured up to 27 hours after
disposal operations were initiated (Kester et al., 1978). Orr (1977a) used
acoustic monitoring to determine that the particulate phase (floe) of
Grasselli waste persisted for 72 hours at one station. The effect of the floe
on marine organisms characteristic of the site has not been investigated
thoroughly; however, only low concentrations of contaminants are available for
uptake by organisms, and the results of bioassays with selected species
suggest that waste disposal operations do not significantly affect biota at
the site (Falk and Gibson, 1977; Grice et al., 1973; Wiebe et al., 1973).
Table 4-2 presents an estimate of the potential effects of disposal-related
metal input on the total metal concentrations in the water at the 106-Mile
Site. This estimate is based on "worst case" conditions of low average flow
rate (10 cm/sec) during a period of low mixing with a well-developed seasonal
thermocline at 15 m depth. For the five metals examined, the greatest
possible percentage increase in concentrations as a result of waste disposal
is less than 3.2%. Thus, even in a hypothetical worst-case condition, the
total input of metals from waste disposal is within the range of natural
variability at the site.
Metal concentrations in sediments of the 106-Mile Site were measured in
1974 by Pearce et al. (1975), and in 1976 by Greig and Wenzloff (1977). The
trace metal contents of sediments taken beyond the Continental Shelf appear to
be elevated relative to sediments on the Shelf/Slope break, but the elevated
metal concentrations are not attributed to present disposal practices at the
4-23.
-------
106-Mile Site, since they are not unique to the site vicinity. Therefore,
there is no evidence that the wastes released at the site have affected the
sediments (Pearce et al., 1975).
TABLE 4-2
WORST-CASE CONTRIBUTION OF WASTE METAL INPUT TO THE
TOTAL METAL LOADING AT THE 106-MILE SITE
Background ^
concentration (yg/1)
Average
Range
Total Amount (g) in
12 **
7.8 x 10 liters
Estimated 1978
106-Mile Site
industrial waste
input (g)
Estimated input
during 14 days
(g)
Percent of loading
due to dumping
during 14 days
Cadmium
0.37
0.05-0.60
2.9 x 106
1.7 x 105
6.5 x 103
0.2
Copper
0.9
0.2-1.7
7.0 x 106
1.9 x 106
7.3 x 104
1.0
Lead
2.9
0.8-6.1
2.3 x 107
1.3 x 107
5.0 x 105
2.2
Mercury
0.72
0.04-4.0
5.6 x 106
11.0 x 103
4.2 x 102
0.008
Zinc
8.0
1.6-21.4
6.2 x 10?
5.3 x 107
2.0 x 106
3.2
* From Hausknecht (1977)
** The total volume of one quadrant of the 106-Mile Site to 15 m depth.
t The maximum residence time for a water parcel at the site assuming a flow
rate of 10 cm/sec and a distance of 32 nmi in a diagonal across the site.
4-24
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Continued use of the site for industrial waste disposal will probably
produce similar results for measurements of the water and sediments. As NOAA
(1977) stated, background values of trace metals at the site are of the order
of parts per billion. Sample collection, storage, treatment, and analytical
procedures can introduce contamination, which affects the resultant values.
Consequently, slightly elevated values due to dumping may be masked by the
contamination introduced from sample handling or by the analytical detection
limits. Projections of disposal effects on the water column and sediments of
any disposal site are based on present technology, with allowances for
inherent weaknesses.
Turbidity
Following the disposal of Edge Moor waste, the 1% light level decreased
(turbidity increased) from a depth of 45 m (150 ft) to 15 m (50 ft) in the
visual center line of the plume (Falk et al., 1974). Turbidity caused by
acid-iron floe persisted up to 5 hours in the winter and up to 20 hours in the
summer, even though the concentration of iron had decreased significantly.
Falk and his co-workers suggest that light penetration may be reduced, even by
small amounts of floe, until iron concentrations return to near background
levels. The effect of temporary increases in turbidity at the site on marine
organisms such as visual predators and phytoplankton is unknown. Decreased
growth rates in Cyprinodon exposed to chronic levels of Edge Moor waste were
presumably related to decreased feeding efficiency caused by decreased
visibility (Falk and Phillips, 1977). Earlier observations (reviewed by NL
Industries, 1977) that disposal enhanced turbidity serves as a concentrating
mechanism for bluefish have not been thoroughly documented by conducting
abundance surveys. Some fish may be caught more often when decreased
visibility reduces their chance of sensing and avoiding fishing gear.
pH Changes
Short-term changes in pH occur at the site when acid or alkaline wastes are
discharged. The most drastic pH changes are confined to the immediate area
4-25
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around the discharge nozzle. As the waste mixes with seawater, the pH rapidly
returns to ambient levels. In tests with Edge Moor wastewater, the pH in
waters above the thermocline returned to normal about 3 hours after the dump,
while water below the thermocline remained unaffected (Falk and Phillips,
1977). Grasselli wastewater did not cause a measurable change in the pH of
water in the barge wake (Falk and Gibson, 1977), nor did American Cyanamid or
Merck waste (Hydroscience, 1978 e-h, 1979 c,d).
NEW YORK BIGHT ACID WASTES SITE
Investigations of the effects of waste disposal at the New York Bight Acid
Wastes Site have continued for more than 30 years, yet no changes in the water
or sediments at the site have been definitely linked to acid waste disposal.
The New York Bight Apex is a difficult region in which to assess impacts
because of the variety of anthropogenic inputs and the existing high levels of
many contaminants.
Most concentrations of water column parameters at the Acid Site are within
the range of values found within the Bight Apex. Reduced surface salinity at
the site, compared with a control area, has been reported (Vaccaro et al.,
1972). Turbidity is greater at the site because of the iron floe which forms
when acid-iron waste reacts with seawater (NOAA-MESA, 1975).
Most studies of trace metals (e.g. mercury, copper, lead, cadmium, and
zinc) in the Bight have analyzed the levels in the sediments. High sediment
metal concentrations in the Bight Apex occur near the Dredged Material and
Sewage Sludge Sites (Ali et al., 1975) and values at the Acid Site are much
lower compared with these disposal sites. Some workers have reported
concentrations of trace metals in Acid Site sediments which were elevated
when compared with sediments from supposedly uncontaminated areas (Vaccaro et
al., 1972; EG&G, 1978). However, these values have been generally within the
range of values from other locations in the Bight.
The effects of moving industrial wastes, which would otherwise be dumped at
the 106-Mile Site, to the New York Bight Acid Waste Site are difficult to
predict. Some wastes presently released at the 106-Mile Site, if relocated to
4-26
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the Acid Site, would deliver new contaminants to the Bight. Therefore, no
background information exists on which to base an estimate of the effects of
dumping these materials. Du Pont-Grasselli used the Acid Site to dump part of
its wastes from 1973 to 1975 with no known adverse effects. In addition to
new materials, the relocation of 106-Mile Site wastes would introduce greater
amounts of materials which presently enter the Bight Apex from other sources.
The New York Bight Apex is already a stressed environment, and increasing the
waste load could produce additional degradation of the ecosystem.
DELAWARE BAY ACID WASTE SITE
Most values of water chemistry parameters measured at this site during past
survey work were comparable to values measured in similar areas within the
mid-Atlantic region (Falk et al., 1974). All metals, except iron, have been
present at ambient seawater concentrations, with little seasonal or depth
variations. When acid-iron waste was released at the site, iron levels were
initially very high. In summer, when the seasonal thermocline reduced
vertical dispersion of the waste, iron levels remained elevated up to 20 hours
after disposal. In winter, with the thermocline absent, values returned to
ambient levels within four hours. Large amounts of waste metals are dumped at
the nearby sewage sludge site, thus water column effects of industrial waste
disposal could be difficult to distinguish from effects of sewage sludge
disposal.
Concentrations of several metals have been reported in sediments at the
site and its vicinity (Johnson and Lear, 1974; Lear and Pesch, 1975; Lear,
1976; Lear et al., 1977). The range of natural variations in metal
concentrations for this area is still undetermined, although high sediment
concentrations have been observed at several stations in and near the .site
(Lear, 1976; Lear et al., 1977). Sea scallops were observed to have elevated
concentrations of vanadium (Pesch et al., 1977). Thus, it appears that past
acid waste disposal at this site may have affected the sediments and benthos
by elevating concentrations of some metals. The ecological effect of
accumulating trace metals other than mercury and cadmium is generally unknown.
4-27
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Relocation of industrial waste dumping from the 106-Mile Site to the
presently inactive Delaware Bay Acid Waste Site could cause additional
accumulations of metals in the sediments and organisms. In addition, other
effects could occur after such a move because some of the 106-Mile Site wastes
have never been released into a nearshore marine environment. Thus, shallow
water dumping of these wastes is not recommended.
NORTHERN AND SOUTHERN AREAS
The Northern and Southern Areas are in shallow water like the Delaware Bay
Acid Waste Site. Therefore, relocation of 106-Mile Site wastes to the
Northern or Southern Areas would probably cause effects like those observed at
the Delaware Bay Site when industrial waste was dumped there, with potentially
serious consequences for nearby shellfisheries.
SHORT DUMPING
The Ocean Dumping Regulations specify that, in emergency situations, the
master of a transport vessel may discharge the vessel's waste load in any
location and in any manner in order to safeguard life at sea. Emergency
situations may result from severe weather conditions typical of the North
Atlantic in late fall, winter, and early spring, from vessel breakdowns,
equipment failure, or collisions with other vessels or stationary objects.
The potential for illegal short dumping exists, although the USCG ocean
disposal surveillance program is designed to discourage such illegal
activities through use of shipriders, patrol vessels, aircraft overflights,
and vessel log checks. Twelve violations of permit provisions for alleged
short dumping, sufficient to cause subsequent actions, were reported by the
Coast Guard to EPA Region II between 1973 and 1977 (EPA, 1978). Seven
violations were due to disposals outside of an authorized disposal site. Two
other violations were referred to EPA Region II (from NASA and the Army Corps
of Engineers) for disposal outside authorized sites. Of the nine charges, one
was upheld and a civil penalty assessed, two were pending in late 1978, and
the charges were withdrawn for six others.
4-28
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The probability of an emergency situation increases in proportion to the
round-trip transit time. (See Table 4-3 for estimated transit times.) Thus,
the decision to locate a site far from shore entails an increased risk of
emergencies and resultant short dumping. The severity of effects caused by a
short dump of toxic waste materials would depend upon the location of the
dump, and in particular, the water depth. Industrial wastes are liquid and
are rapidly diluted upon discharge, therefore a single pulse of waste input to
an area might cause local acute effects, but should not cause any long-term
adverse effects. Effects of emergency dumping during inclement weather would
be mitigated by the rapid dilution caused by storm activity.
TABLE 4-3
ROUND-TRIP TRANSIT TIMES TO ALTERNATIVE SITES (IN HOURS)
BASED ON VARIED VESSEL SPEEDS
Site
106-Mile Site
NYB Acid Wastes Site
Delaware Bay Acid
Waste Site
Southern Area
Northern Area
New York Harbor
5 kn
(9 km/hr)
46
7
48
22
21
7 kn
(13 km/hr)
32
3
36
16
16
Delaware Bay
5 kn
(9 km/hr)
48
45
14
36
51
7 kn
(13 km/hr)
34
32
10
26
36
* Does not include time in transit from the loading dock to the
Rockaway-Sandy Hook transect (New York Harbor) or from ports in Delaware
Bay to the Cape May-Cape Henlopen transect (Mouth of Delaware Bay).
Use of any of the alternative sites introduces the possibility of legal or
illegal short dumping. Based upon distance of a site from port, the
probability of a short dump is highest for the 106-Mile Site or the Delaware
Bay Acid Waste Site and lowest for the New York Bight Acid Wastes Site;
intermediate probabilities are associated with the Northern and Southern
Areas. Except for the nearshore sites, the effects of a short dump should be
temporary, with rapid recovery of the ecosystem. Short dumping at the New
4-29
-------
York Bight Acid Wastes Site or the Delaware Bay Acid Waste Site would cause
more concern because of the close proximity to shore, and the possibility of
waste materials reaching the New Jersey or the Long Island shoreline.
UNAVOIDABLE ADVERSE ENVIRONMENTAL EFFECTS AND MITIGATING MEASURES
Some unavoidable adverse environmental effects would occur upon disposal of
aqueous industrial wastes in any oceanic site designated for use. These
effects occur immediately upon release of the wastes, and are mitigated by
rapid dilution of the wastes after release. Based on field and laboratory
observations, the most significant short-term impacts of waste disposal at the
106-Mile Site are:
• Acute mortality in plankton
• Rise in the concentrations of some waste constituents in the upper
water column
• Increased turbidity
0 Changes in pH
• Possible avoidance of the area by some fish
Other effects have been observed, but their extent and significance are not
yet known. These include:
• Possible occurrence of abnormal fish eggs and embryos in the waste
plume
• Ingestion of waste particulates by zooplankton
• Inhibition of organic carbon assimilation by bacteria
• Sublethal responses, e.g., reduced feeding rates in copepods
• Stimulation of diatom growth in low waste concentrations and
inhibition of growth in elevated concentrations
• Possible transport of waste materials by vertically migrating
zooplankton
4-30
-------
These effects, and others, will be subjects for future research on effects
of waste disposal at the site. It must be noted that most of these effects
would be expected to occur at any ocean site where industrial waste is dumped.
The only unique factor of a location like the 106-Mile Site is that individual
organisms in such a relatively unstressed oceanic area may be more sensitive
to wastes than organisms from a stressed coastal area.
Mitigating measures beyond enhanced dilution are not presented here because
most of the waste effects which are documented persist only for a short period
(e.g., pH changes in the water). Because this site has been in use for many
years, EPA has already incorporated mitigating measures into its permit
requirements for individual dumpers. As less-understood waste effects become
better identified in future research, additional controls will be adopted when
appropriate.
RELATIONSHIP BETWEEN USE OF THE SITE AND LONG-TERM PRODUCTIVITY
Continued use of the 106-Mile Site is not expected to have a significant
adverse impact on the long-term productivity of the area. The site is outside
the range of most commercial and recreational U.S. fishing and significant
mineral resource development. To date, no studies have been conducted on the
long-term effects of waste disposal on biological productivity of the area.
Effects are probably limited to the waste plume, and are mitigated by the
rapid dispersion and subsequent dilution of the plume.
IRREVERSIBLE OR IRRETRIEVABLE COMMITMENTS OF RESOURCES
Several resources will be irreversibly or irretrievably committed upon
implementation of the proposed action:
• Losses of energy in the form of fuel required to transport barges to
and from the site. Transport to distant sites requires more fuel
than to nearshore sites.
4-31
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Losses of valuable constituents in the waste, (e.g., metals), some
of which are available in the U.S. only in short supply. However,
present technology is not adequate for metal recovery before
dumping.
Losses of economic resources due to the high costs of ocean disposal
at sites far from land. Some ocean disposal costs, however, may be
lower than alternative land-based disposal costs, resulting in a net
economic gain.
4-32
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Chapter 5
SEWAGE SLUDGE DISPOSAL AT THE 106-MILE SITE
While it is acknowledged that the only reasonable
long-term solution for disposal of harmful sewage sludge is
by land-based processes, adverse conditions at the existing
New York Bight Sewage Sludge Site (12-Mile Site) could
require relocation of the disposal operation to another site.
Use of the 106-Mile Site for sewage sludge disposal would be
technically feasible, but economically unrealistic for
large-scale disposal. However, under suitable conditions,
the 106-Mile Site could provide an alternative location for
short-term disposal of sewage sludge.
Disposal of sewage sludge, a product of wastewater treatment, is
accomplished by two broad classes of methods: (1) ocean disposal by barge or
outfall, and (2) land-based treatment and disposal. Barged ocean disposal of
sewage sludge in the New York Bight has existed since 1924. It is acknow-
ledged that the only reasonable solution for long-term disposal of environ-
mentally harmful sludge is by land-based processes (addressed in a previous
EIS [EPA 1978]). However, there is an immediate need for ocean disposal while
land-based alternatives are being developed and field-tested. This need will
last at least until December 31, 1981, when ocean disposal of sewage sludge
which does not comply with EPA's environmental impact criteria will cease as
mandated by law (PL 95-153).
The question of where to dispose of sewage sludge (either on land or in the
ocean) from the New York-New Jersey metropolitan area or from Philadelphia,
pending implementation of land-based alternatives, has received much attention
at scientific meetings, court hearings, Congressional committee meetings, and
in the press. One EIS (EPA, 1978) has been prepared on the subject and has
resulted in designation (F.R., May 18, 1979) of an area 60 nmi (111 km) from
New York Harbor as an alternative sludge disposal site, for use only if
environmental conditions at the 12-Mile Site are sufficiently adverse to
require relocation of the disposal operation (Figure 5-1). EPA (1978) also
addresses the feasibility of using the 106-Mile Site as an alternative sludge
disposal site.
5-1
-------
41°
75°
1. NEW YORK BIGHT
SLUDGE SITE
2. NEW YORK BIGHT
ALTERNATE SLUDGE
SITE
3. 106-MILE SITE
74°
73°
72°
40°
39°
38°
LONG ISLAND SOUND ^,
41"
40*
39°
KILOMETERS
50
NAUTICAL MILES
100
50
38'
75°
74°
73°
72°
Figure 5-1. Alternative Sewage Sludge Disposal Sites
5-2
-------
The 106-Mile Site would be used primarily for disposing of industrial
chemical wastes in the foreseeable future, but it is conceivable that severely
degraded environmental conditions in the Bight, or threats to public health,
could require sewage sludge disposal at an alternative site beyond the
Continental Shelf. The 106-Mile Site is the only off-Shelf location in the
mid-Atlantic used historically to dispose of sewage sludge, thus it would be
a logical choice for an alternate location. Table 5-1 summarizes the history
of the proposal to relocate sludge disposal from the New York Bight to the
106-Mile Site.
The 106-Mile Site has been used in the past for limited disposal of the
City of Camden sewage sludge, under Interim and Emergency dumping permits. In
addition, small amounts of sludge digester cleanout residues from treatment
plants in the New York City area have been dumped at the site since 1973. No
adverse effects of this sludge disposal have been demonstrated; however,
studies of effects of sludge dumping at the 106-Mile Site have been limited.
"Sewage sludge" is a generic term for the dark, humus-like waste material
produced by municipal wastewater treatment processes which treat wastes from
domestic and industrial sources. It is a mixture of sewage and settled solids
removed from raw wastewater during treatment. Sludge dumped at the 12-Mile
Site is primarily a combination of digested products of primary and secondary
wastewater treatment. The degree of treatment that the material receives
determines its ultimate composition. Primary treatment removes 50% to 60% of
the suspended solids from raw wastewater. Secondary treatment removes
approximately 85% of the suspended solids. Sludges produced by primary or
secondary treatment can be subjected to anaerobic digestion to decompose the
organic materials.
5-3
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TABLE 5-1
HISTORY OF THE PROPOSAL TO RELOCATE
SEWAGE SLUDGE DISPOSAL TO THE 106-MILE SITE
February 1976: The draft EIS on the ocean disposal of sewage sludge in the
New York Bight was released for public review and comment.
July, August 1976: Long Island beaches bordering the New York Bight were
contaminated with sewage-related material and other wastes propelled onshore
by unusual summer winds. Waters off the New Jersey coast experienced a
massive algal bloom and depletion of oxygen in bottom waters which severely
affected benthic marine organisms, especially surf clams. Blame for these
events was directed at sewage sludge disposal operations in the New York Bight
Apex, although later investigations revealed that sewage sludge was not the
cause of the incidents. Nonetheless, consideration of moving sludge disposal
operations farther offshore was advanced by adverse public comment directed at
the nearshore disposal site.
May, June 1977: EPA Headquarters held a public hearing in Toms River, New
Jersey, to consider the possibility of relocating sewage sludge disposal
operations from the existing disposal site in the New York Bight Apex and the
existing disposal site off the coast of Maryland (the Philadelphia Sewage
Sludge Disposal Site) to a site farther offshore, possibly the 106-Mile Site.
Many government, public, and academic critics and supporters of the prop-
osition presented arguments, data, and opinions (EPA, 1976).
July 1977: EPA Headquarters awarded a 3-year contract to Interstate
Electronics Corporation to perform environmental assessments and prepare EIS's
on the designation of ocean disposal sites for different types of wastes. The
106-Mile Site EIS was assigned high priority.
September 1977: The hearing officer for the Toms River public hearing issued
his report, recommending that neither the New York area nor the Philadelphia
sewage sludge disposal operations be moved from the existing disposal sites.
With respect to the 106-Mile Site, the hearing officer stated that "sludge
dumping at the 106-Mile Site is not feasible because of the unknown but
potentially adverse environmental consequences and the inability to monitor
the site effectively." However, the same report recommended that "Preparation
of an environmental impact statement on the issue of relocating the
sludge...to the 106-Mile Site should begin immediately" (Breidenbach, 1977).
5-4
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TABLE 5-1. (Continued)
November 1977: Congress amended the MPRSA to require that ocean disposal of
harmful sewage sludge be phased out by December 31, 1981 (PL 95-153).
March 1978: EPA Assistant Administrator Jorling issued a decision on the Toms
River public hearing, stating that the New York Bight and Philadelphia Sewage
Sludge Disposal Sites should continue in use, pending the phase-out of harmful
sewage sludge disposal in 1981. The decision directed that an assessment of
sewage sludge disposal be included in the EIS on the 106-Mile Site (Jorling,
1978).
September 1978: EPA issued the final draft of the EIS (EPA, 1978) on ocean
disposal of sewage sludge in the New York Bight, including an assessment of
the feasibility of using the 106-Mile Site. The site was not judged favorable
for sludge disposal based on an evaluation of several factors. The major
limitations cited in the use of the 106-Mile Site were the unknown environ-
mental effects of disposal and the greater associated costs of using the site
as compared to other sites. The EIS recommended the designation of a site
farther offshore on the Shelf for use if conditions at the existing site
required it. This EIS drew heavily on the material presented at the Toms
River public hearing. No new data on sludge disposal effects at the 106-Mile
Site were presented.
May 1979: EPA published notice of the final designation of the existing New
York Bight Sewage Sludge Disposal Site and the Alternate Sewage Sludge
Disposal Site for use if the existing site cannot safely accommodate any more
sewage sludge.
June 1979: The draft EIS designating the 106-Mile Site for continued use was
issued for public review and comment. The site was judged acceptable for
industrial waste disposal and short-term sewage sludge disposal.
August 1979: EPA Headquarters held a public hearing in New Jersey to discuss
the proposed designation of the 106-Mile Site and the draft EIS supporting
designation. The hearing notice received a limited response.
5-5
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By 1981, most of the waste treatment plants which serve the New York
metropolitan area and currently practice ocean disposal and are expected to
provide secondary treatment. New Jersey plants will provide primary
treatment. Thus, the character of dumped sewage sludge will gradually change
over the next few years as present wastewater treatment plants are upgraded
and new facilities are constructed to provide secondary treatment. Table 5-2
compares the physical and chemical characteristics of present New York
metropolitan area sewage sludge with the industrial chemical wastes presently
dumped at the 106-Mile Site.
AMOUNTS OF SLUDGE DUMPED
From 1960 to 1978, the amount of sewage sludge dumped annually in the New
York Bight ranged between 2.5 and 6.4 million metric tons. By 1981, the amount
of sludge dumped in the Bight is expected to be about 10 million metric tons,
or one and a half times greater than the 1978 amount. Table 5-3 presents the
estimated amounts from the individual waste generators expected to dump in the
Bight between 1979 and 1981. Projections of the effects of sludge disposal at
the 106-Mile Site are based on anticipated 1981 New York-New Jersey sludge
volumes.
ENVIRONMENTAL ACEPTABILITY
The City of Camden's relatively brief use of the 106-Mile Site provided
little opportunity to study the impacts of sewage sludge disposal. In lieu of
adequate experimental data on the site, projections of the effects of
potential future sludge disposal must be based on data from studies of other
wastes at the site, and on data obtained from studies at other sewage sludge
ocean disposal sites.
5-6
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TABLE 5-2
COMPARISON OF TYPICAL PHYSICAL, CHEMICAL, AND TOXICOLOGICAL
CHARACTERISTICS OF SEWAGE SLUDGE AND INDUSTRIAL WASTE
DUMPED AT THE 106-MILE SITE
Characteristic
Specific gravity
pH
Suspended Solids
dug/liter)
Oil and Grease
(mg/liter)
Arsenic (ug/ liter)
Cadmium (ug/ liter)
Chromium (ug/ liter)
Copper (ug/ liter)
Iron (mg/liter)
Lead (ug/Hter)-
Mercury (ug/liter)
Nickel (ug/liter)
Vanadium (ug/liter)
Zinc (ug/liter)
96-hr LC50:
Atlantic silversides
(M. menidia)
(ul/liter)
96-hr EC50:
Diatom
(S. costatum)
(ul/liter)
New York City
Sludge*
1.009
NO
25,000
4,900
1,000
2,700
59,000
82,000
NO
66,000
800
17,000
2,000
160,000
7,200 - 16,000
39 - 1,000
American
Cyanamid
1.028
2.7 - 8.3
300
(60 - 21,000)
900
(10 - 6,214)
600
(20 - 2,600)
4
(1-50)
600
(45 - 4,900)
400
(1 - 4,100)
no
100
30
(1 - 200)
1,000
(145 - 6,400)
ND
600
(7 - 5.160)
0.24 - 2,900
10 - 1,900
Uu Pont
Edge Moor
1.135
(1.085 - 1.218)
0.1 - 1.0
2,000
4
(1-24)
"0
300
(20 - 900)
270,000
(52,600 - 900,000)
3,000
33,000
114,500 - 54,800)
41,000
(2,700 - 76,000)
30
(1 - 200)
29,000
(200 - 65,000)
120,000
(80,000 - 250,000)
101,000
5,000t
712 - 3,450
uu Pont
Crasselli
1.109
(1.036 - 1.222)
12.4 - 13.6
800
(5 - 15,090)
17
(0.8 - 108)
NO
200
(3 - 700)
300
(10 - 3,500)
330
(25 - 1,470)
NU
900
(10 - 4.90U)
7
(1-20)
700
(30 - 2.00U)
ND
500
(30 - 2,700)
560 - 6,950t
16U - 8,600
Merck
1.2o
5 - 7
1,000
80
200
50
500
400
ND
1,500
50
2,600
1,000
400
o5u - lOO.OOOt
u5 - 12,uoO
* Data from Mueller et al., 1976.
f Aerated
ND > Not determined
5-7
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TABLE 5-3
ESTIMATED QUANTITIES.OF SEWAGE SLUDGE TO BE DUMPED
IN THE NEW YORK BIGHT 1979 TO 1981
Waste
Generator
Middletown Sewerage Authority
Passaic Valley Sewerage
Commissioners
City of Long Beach
Middlesex County Sewerage
Authority
City of New York
Modern Transportation Co.
Bergen County Utilities
Authority
Linden-Roselle & Rahway
Valley Sewerage Authorities
Joint Meeting of Essex and
Union Counties
Nassau County
Westchester County
City of Glen Cove
General Marine Transport Corp.
TOTALS
Amount in Thousands of Metric
and (Thousands of Tons)
1979
36
767
9
767
4,364
108
230
252
334
418
533
13
11
7,842
(40)
(844)
(10)
(844)
(4,800)
(119)
(253)
(277)
(367)
(460)
(586)
(14)
(12)
(8,626)
1980
42 (46)
1,007 (1,108)
9 (10)
915 (1,007)
4,634 (5,097)
234 (257)
261 (287)
334 (367)
435 (479)
683 (751)
13 (14)
8,567 (9,423)
Tons
1981
48
1,007
9
926
5,904
239
270
334
453
703
13
9,906
(53)
(1,108)
(10)
(1,019)
(6,494)
(263)
(297)
(367)
(498)
(773)
(14)
(10,896)
'Use of an off-Shelf site for sludge disposal can have several environmental
advantages over disposal at a Shelf site:
(1) Except in an area of upwelling, biological productivity is generally
much lower in off-Shelf waters than in Shelf waters.
(2) In a site located far from shore, wastes are diluted before they can
impact coastal fisheries or shorelines.
(3) Bottom impacts are less likely at a site located in sufficiently
deep water because sinking particles undergo rapid horizontal
dispersion as they descend slowly, ensuring that very little
material sinks directly to the bottom.
(4) Any material that eventually reaches bottom will be so widely
dispersed that a substantial build-up of elevated concentrations is
highly unlikely.
5-8
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Several concerns about potential effects of 106-Mile Site sludge disposal
were raised at the Toms River Hearing:
• Accumulation of undecayed materials which could ultimately float up
to contaminate seas and beaches
• Development of deep-sea anaerobic environments
• Damage to organisms which are adapted to the stable conditions of
the deep ocean environment
• Long-range adverse effects on marine biota which remain undetectable
until the impact becomes irreversible
• Persistence of pathogens for long periods of time
The above issues and others are addressed in this section. Based upon the
present knowledge of the physical characteristics at the 106-Mile Site, and
the characteristics of the sludge proposed for disposal at the site, no
significant adverse impacts are anticipated.
FATE OF SEWAGE SLUDGE
The fate of dumped sludge in the water column at the site is important in
order to understand the potential chemical and biological effects of sludge
disposal.
DILUTION AND DISPERSION
The nature of impact from dumped material is determined in large part by
the behavior of the waste in the water mass. The material may sink directly
to the bottom, as do coarse construction materials and dense dredged
materials, or it may remain in the water mass for a long time, dispersing
slowly or rapidly throughout all or part of the water column. Shallow water
makes the likelihood of bottom contact in a relatively short time more
probable. Deep water offers a lower probability of rapid bottom deposition
due, in part, to complex changes in the environmental conditions vertically
throughout the water column.
5-9
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The 106-Mile Site is a dynamic region, therefore, its natural complexity
limits the predictability of events which may ensue from waste disposal.
Attention must be focused on the interaction of the ocean environment with
the dumped sludge. The best evidence of the mechanical settling and
dispersion is from direct observation of the sludge after it is released from
a barge. Orr (1977b) had the opportunity to track the early stages of a
Camden sludge dump at the 106-Mile Site, via acoustic means. From these
observations, the points most cogent to the influence of environment on the
dumped material are the movement of material to about 60 m depth and the
evidence of a strong vertical shear at about 28 m which rapidly spread the
upper and lower portions of the dumped material over large horizontal areas.
It should be noted that Camden sludge received only primary treatment, thus
particles were heavier than those in sludge from secondary treatment.
Secondary sludge may disperse differently, but it is probable that the
difference will not be significant.
The depth of the seasonal pycnocline in the offshore area ranges between 10
and 60 m, forming a density surface which acts to restrict settling of near
neutrally buoyant material such as sludge. The depth and intensity of this
pycnocline varies with seasons and storm activity, but is quite pervasive,
extending over the several water masses (although perhaps not well developed
in Gulf Stream eddies). A permanent pycnocline, between 100 and 150 m (on
average), will act as another barrier to settling material. While neither
density surface is impenetrable, the retardation of settling will keep the
dumped material in the upper surface waters for longer periods of time. The
dynamic activity of surface waves, internal waves, shears, and small-scale
turbulence enhance this suspended state. Where a variety of water masses
interact, fronts and shear lines are commonplace and represent regions of
spatially varying speeds and increased turbulence. These conditions increase
dispersion of the material in both the vertical and horizontal, thus further
reducing the settling rate. This is an anisotropic dispersion (Ichiye, 1965),
where horizontal dispersion rates exceed those of the vertical by as much as
two orders of magnitude.
5-10
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With increased residence time in surface waters, the material is subject to
transport by near-surface currents which normally move at higher speeds than
currents at1 greater depths. Woods Hole Oceanographic Institution records of
currents measured at Site D, about 110 nmi (204 km) east-northeast of the
site, represent an approximate description of conditions at the site. Records
collected during a 261-day period in the surface waters to depths of 150 m
show an average current movement to the west and north of 6 to 11 cm/sec. On
a larger scale, this means an average of about 3 to 5 nmi (5 to 10 km) per day
of translational movement, with brief periods of faster and slower speeds.
Warsh (1975b) suggests that currents follow the bathymetry, and move to the
south and west at the 106-Mile Site. In contrast, Bisagni (1976) reported a
mean residence time of 22 days for anticyclonic eddies passing through the
site.
In oceanic conditions, a typical sludge settling rate was determined by
Callaway et al. (1976) who monitored dispersion of sludge dumped in the shoal
waters of the New York Bight Apex. Nonflocculated particles, comprising most
of the dumped material, had settling velocities of 0.01 to 0.30 cm/sec or
less. If the material is dispersed throughout the upper 60 m of the water
column, this settling rate provides a mean time to the 60-meter depth of 0.2
hour to 7 days, in which time the material could be transported a maximum of
21 to 35 nmi (40 to 65 km). In that time, this waste fraction is assumed to
have reached the density interface at 60 m where it may accumulate for an
unknown time. The waste fraction should eventually pass through, settling to
the next interface at approximately 100 to 150 m depth. Assuming a linear
descent to 100 m depth, the range of time is about 0.33 hour to 12 days. In
the longer period, at a mean speed of 3 to 5 nmi (5 to 10 km) per day, the
finer fractions could travel a total of 36 to 60 nmi (70 to 110 km) from the
site.
Values used here for the purpose of discussion may vary significantly
without detracting from the observation that waste material will spend long
times in the water column undergoing dispersion, transport, and degradation by
chemical and biological processes. Orr (1977b) is presently analyzing data on
the horizontal dispersion of the sludge during a 32-hour experiment in which
the sludge had, at the end of the experiment, dispersed along several density
5-11
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interfaces within 45 m of the surface but did not penetrate the 60-meter
depth. This experiment adds credibility to the use of a time interval greater
than three days for settling to 60 m depth and to a long residency in surface
waters.
A worst-case estimate for bottom areas where particles may fall is based
upon approximation techniques of Callaway et al. (1976). Assuming a point
source dump (with no associated turbulent diffusion as from a discharge in the
wake of a moving barge), a 6 cm/sec horizontal current (U), and a particle
settling velocity (W ) of 0.1 cm/sec, the size of the settling area at the
a
106-Mile Site will be proportional to the depth change of the existing
disposal site (depth = H = 22 m) to the 106-Mile Site. Particles will settle
over the length L = UH/W . The 106-Mile Site has an average depth of about
s
2,000 meters. Solving the equation for L yields 120 km. If a circular
2
settling patch is assumed, the 106-Mile Site yields 45,216 km . Assuming an
even distribution of solids within the computed area, the accompanying
decrease in solids per unit area relative to the New York Bight Sludge Site is
of the order of 3,000. Based on current sludge volumes, this results in a
bottom accumulation of 0.6 micron - an infinitesimal amount. Therefore,
disallowing horizontal and vertical dispersion, density gradients, or
degradative processes normal to the 106-Mile Site, and assuming an
unrestricted fall of sludge particles from surface to bottom, insignificant
amounts of sludge would be deposited on the bottom under the worst conditions.
EFFECTS UPON WATER CHEMISTRY
Sewage sludge produced by secondary treatment contains low concentrations
of organic matter. Anaerobic digestion reduces these concentrations even
further, but detention time is generally insufficient to remove the
slower-degrading constituents: lipids, lignins, celluloses, and industrial
wastes (e.g., PCB's, phenols, and pesticides). These materials will most
likely not accumulate at the site but will disperse rapidly in the surface
waters above the pycnocline where they may be subjected to various degradative
processes, including microbial degradation.
5-12
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Recent in situ studies conducted by Woods Hole Oceanographic Institution
(Wirsen and Jannasch, 1976; Jannasch and Wirsen, 1973, 1977), suggest that
bacterial activity decreases significantly with lower temperatures and the
greater pressures characteristic of the deep-sea environment. Although the
depth range of the 106-Mile Site (1,400 to 2,800 m) falls generally within the
depth range of the degradation studies (1,800 to 5,300 m) conducted by
Jannasch and Wirsen (1973, 1977) and Wirsen and Jannasch (1976), the
thermocline/pycnocline barrier at the site is expected to encourage horizontal
dispersion of the sludge above 100 to 150 m depth. Actual rates of
decomposition at this depth are not known and can, at best, only be
extrapolated from some of the above referenced studies.
Chemostat studies, conducted under atmospheric pressure, have demonstrated
reduced rates of microbial degradation when substrates are diluted beyond a
critical point (Jannasch and Mateles, 1974). Such experimental evidence has
been proposed for explaining the ubiquity of certain pollutants in the oceans
(Jannasch, 1979). Preliminary studies of organic wastes in the deep sea,
however, have implicated a combined role of micro-organisms and higher animals
in removing organic wastes (Jannasch, 1979). Metabolic processes in higher
animals are instrumental in transforming and degrading some organic
pollutants. The combined microbial activity in the intestinal tracts of some
higher animals and fish have been implicated in similar transformations
(Jannasch, 1979).
Based on the initially low concentrations of slowly degrading organic
material associated with the sludge and given the highly dispersive
environment at the 106-Mile Site (previously discussed), accumulations of
large amounts of undecayed organic matter and the subsequent creation of an
anaerobic environment are highly unlikely. Only insignificant amounts of
material requiring oxidation will sink to depths of limited dissolved oxygen.
Sludge disposal at the 106-Mile Site will introduce metals, inorganic
nutrients, suspended solids, and chlorinated hydrocarbons to the water column.
However, since the waste will be introduced into the barge wake, rapid initial
dilution will occur. Further dilution and dispersion will occur as the
material sinks and the water mass acts upon it.
5-13
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The following discussion is based in part on the projections made by
Raytheon (1976) on the effects of sludge disposal at the Alternate Sewage
Sludge Site in the New York Bight. The potential effects on water chemistry
at the 106-Mile Site and the Alternate Sludge Site are comparable. Bottom
chemistry effects are not discussed since, as indicated earlier, the sludge is
not expected to reach the bottom in significant proportions.
Most of the heavy metals introduced by sludge will occur in the particulate
fraction. In Table 5-4 the present metal content of sewage sludge has been
applied to a worst-case model of nondispersive, nondiluting physical
conditions at the site, with sludge dumped in the water column contained
within an areal quadrant to a depth of 15 m in a 14-day period. Under such
strict conditions, the accumulative concentrations of some metals will be
double the low background levels. However, in observed typical conditions,
with the pycnocline near 60 m depth and water flushing through the quadrant .in
3 days at the rate of 10 cm/sec, the percent metal loading within the quadrant
due to sludge dumping is a small fraction of the worst-case value. This
suggests that any future sludge disposal at the site should occur under the
most dispersive conditions, to avoid elevated concentrations in the water
column. Amounts of sludge dumped at a time can be regulated, to permit
adequate dilution and dispersion so that concentrations within the site do not
remain elevated.
Chlorinated hydrocarbons (e.g., PCB's) and other toxic organic materials in
sludge will be introduced to the site in association with particulates in the
sludge. However, the concentrations of these materials in the sludge are
relatively low and are not expected to increase levels significantly at the
site as long as inputs to the sludge are controlled.
Nutrients in the form of inorganic nitrogen (NO, , N0_ , and NH- ) and
inorganic phosphorus (PO, ) would be introduced to the site by sludge
disposal. Table 5-5 presents an evaluation of worst-case conditions. Only
phosphate is added in significant proportions. Most primary production in the
ocean is limited by the amount of inorganic nitrogen in the water, and even in
the worst case, sludge would introduce insignificant amounts of nitrogen.
Dumping sludge at the site would neither significantly increase productivity
nor support plankton blooms.
5-14
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TABLE 5-4
WORST-CASE PROJECTIONS OF METAL LOADING DUE TO SEWAGE SLUDGE
DISPOSAL IN A QUADRANT OF THE 106-MILE SITE
Metal Load
Background
concentration
(ug/ liter) Average
Range
Total amount
(g) in
7.7 x 1012literst
Estimated metal
input (g)
**
in 1981
Estimated input
in 14 days
Percent of loading
due to sludge
dumping during
14 days
Cadmium
0.37
0.05 - 0.6
2.8 x 106
3 x 107
1.1 x 106
39
Copper
0.9
0.2 - 1.7
6.9 x 106
8.9 x 108
3.4 x 107
49
Lead
2.9
0.8 - 6.1
2.2 x 107
6.6 x 108
2.5 x 107
113
Mercury
0.72
0.04 - 4.0
5.5 x 106
8 x 106
3.1 x 105
6
Zinc
8.0
1.6 - 21.4
6.2 x 107
1.6 x 109
6.1 x 107
98
* From Hausknecht (1977)
t Volume based on one-fourth of the total area of the site and a minimum seasonal
thermocline of 15 m
** Based on sludge metal concentrations from Mueller et al. (1976) and EPA (1978) volume
estimates
ft Based on the length of time taken for a water parcel to cross the site at 10 cm/sec.
5-15
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TABLE 5-5
WORST-CASE PROJECTIONS OF INORGANIC NUTRIENT LOADING DUE TO
SEWAGE SLUDGE DISPOSAL, IN A QUADRANT OF THE 106-MILE SITE
Background
concentration (ug/1)
Total amount in
7.7 x 1012liters
Estimated input during
1981 (g)
Estimated input in
14 days (g)
% total nutrient load
due to sludge
Nitrite and Nitrate
19.2
1.5 x 10
4.0 x 10
1.5 x 10
8
Phosphate
114
8
9 x 10
4.0 x 10'
1.5 x 10
14
8
* From Peterson (1975). Concentrations at 15 m depth.
t Volume of a quadrant of the site to 15 m depth.
The heavier particles in the suspended solid fraction are quite inert,
mainly silt and sand washed into sewage treatment plants. Such particles
can provide sites for biological growth and will sink fairly rapidly. Finer
particles, e.g., clays, will remain in the water column for long periods of
time and will provide charged sites for bonding with ionic materials (e.g.,
heavy metals) in solution, and for bacterial growth, which can remove ionic
matter from solution.
INTERACTIONS WITH INDUSTRIAL WASTE
Whenever chemically diverse materials are mixed, potential interactions
exist. For example, combining sludge with strong acids can cause heavy metals
to desorb from sludge particles. Conversely, the particles in sludge can
provide nuclei for adsorption of contaminants in chemical wastes.
5-16
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The potential for interaction of chemical wastes with sludge dumped at the
106-Mile Site is slight. EPA imposes that simultaneous dumps be in separate
_ 2
quadrants of the site, with each quadrant large enough (150 nmi ) to dilute
significantly the material within its boundaries. Sludge and industrial
wastes at the site would thus be separated by a sufficient distance to prevent
the materials from mixing. Sludge at the 12-Mile Site is presently dumped
only 2.7 nmi (5 km) from the New York Bight Acid Site. No interactions
between sludge and acid waste have ever been recorded.
EFFECTS UPON ORGANISMS
Many components of sewage sludge can adversely affect organisms. Some of
these constituents (e.g., nutrients and heavy metals) are necessary to sustain
marine life, but become toxic at the high concentrations found in undiluted
sludge. However, rapid dilution and dispersion of the sludge at the site will
mitigate all but short-term acute effects on organisms inhabiting the upper
water column. Due to the rapid vertical dilution of waste throughout the
water column, benthic organisms in the vicinity should not be affected.
Limited biological studies (Longwell, 1977) have been conducted during
sludge disposal operations at the 106-Mile Site. Fish eggs were collected
inside and outside the sewage sludge plume to study effects upon developing
fish embryos. The fish embryos were examined for cell and chromosome damage.
Too few fish eggs were collected to permit quantitative comparisons. However,
sewage sludge appears to be toxic o fish eggs in the early developmental
stages, as indicated by adverse effects on the chromosome and mitotic
apparatus of embryos undergoing cell division. No effects of any waste,
either industrial or municipal, have been demonstrated on fish populations
because of the high natural variability of such populations. Most populations
of fish taken commercially in the mid-Atlantic spawn over the Continental
Shelf, rather than in off-Shelf water such as the 106-Mile Site. Therefore,
although sewage sludge may cause short-term effects on early stages of fish
embryos, measurable long-term effects on fish populations are unlikely.
5-17
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SURVIVAL OF PATHOGENS
Sewage sludge contains many types of pathogenic (disease-causing)
organisms, reflecting both the infection and carrier status of a particular
population. Sludge pathogens may be classified into four general groups:
bacteria, viruses, protozoans, and helminths (Table 5-6).
Of all pathogenic organisms associated with sewage sludge, the greatest
public health concern is for viruses, particularly the enteroviruses. This
concern is justified by a number of observations:
(1) Most enteric viruses are more resistant to sewage treatment and
disinfection processes than enteric bacteria (Akin et al., 1975).
(2) Response to the most common disinfectant (chlorine) varies greatly
among the enteroviruses - some types exhibiting much greater
resistance than other viral types (Liu et al., 1971).
(3) Enteric viruses, along with enteric bacteria, can become
concentrated in shellfish tissues (Mitchell et al., 1966; Liu et
al., 1966; Metcalf, 1974).
(4) The lack of adequate viral isolation techniques and low recovery
efficiencies of existing methods have produced data with only
relative value. Reported densities are most likely underestimates
of actual populations in the environment.
Secondary treatment of sewage is highly variable in effectively reducing or
inactivating many of these organisms (Akin et al., 1977). Depending on
factors such as treatment facility conditions, resistance of organisms, and
waste composition and degree of degradation, the microbial content of sewage
is reduced anywhere from 25% to 99% (Geldreich, 1978). Sewage treatment
processes are generally most effective in providing effluents of acceptable
quality. Sludges, on the other hand, are reservoirs for many sewage
pathogens.
Most sewage coliforms (50% to 75%) are associated with particulates having
sizeable settling velocities (Mitchell and Chamberlin, 1978), resulting in a
"die-off" due to sedimentation rather than an actual loss of cell viability.
Viruses rarely occur as free individuals and are generally adsorbed to, or
embedded in particulate matter. This phenomenon only increases the weight and
5-18
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bulk of the infectious unit (Akin et al., 1977). Persistent bacterial spores,
parasite cysts, and eggs ultimately become sludge constituents because of
their relative densities.
TABLE 5-6
IMPORTANT SLUDGE-ASSOCIATED HUMAN PATHOGENS
ORGANISMS
DISEASE
1. ENTERIC BACTERIA
Salmonellae species
Shigellae species
Escherichia coli
2. ENTERIC VIRUSES
Enteroviruses (67 types)
Hepatitis A virus
Adenoviruses (31 types)
Rotavirus
Parvovirus-types
3. PROTOZOANS
Entamoeba histolytica
Giardia lamblia
Balantidium coli
4. HELMINTHS (Worms)
a. Nematodes (Roundworms)
Ascaris lumbricoides
Ancyclostoma duodenale
Necator americanus
Enterobius vermicularis
Strongyloides stercoralis
Trichuris trichiura
b. Cestodes (Tapeworms)
Taenia saginata
Taenia solium
Hymenolepis nana
Typhoid Fever
Salmonellosis
Shigellosis
Gastroenteritis
Gastroenteritis
Meningitis
Others
Infectious hepatitis
Respiratory disease
Conjunctivitis
Others
Gastroenteritis
Gastroenteritis
Amoebiasis
Giardiasis
Balantidiasis
Ascariasis
Ancyclostomiasis
Necatoriasis
Enterobiasis (pinworms)
Strongyloidiasis (threadworms)
Trichuriasis (whipworms)
Taeniasis (beef tapeworm)
Taeniasis (pork tapeworm)
Taeniasis
Source: Akin et al., 1977.
5-19
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A number of factors responsible for the decline of sewage pathogens have
been identified and studied. Table 5-7 lists the mechanisms most often
implicated in "die-off" observations. Although any one of these factors may
be effective under particular circumstances or conditions, solar radiation and
the adsorption and sedimentation of contaminating micro-organisms with
particles in suspension have frequently been suggested as the most effective
means of natural pathogen reduction in the ocean (Mitchell and Chamberlin,
1978). Synergistic effects, particularly with physical-chemical parameters,
have also been shown to limit the existence of micro-organisms in the marine
environment (Brock and Darland, 1970; Cooper and Morita, 1972; Jannasch and
Wirsen, 1973).
As part of the monitoring program in the New York Bight, EPA Region II, in
response to public concern for sludge disposal and transport of contaminants,
initiated a bacteriological monitoring program which included total and fecal
coliforms, pathogenic bacteria, and enteric viruses (EPA, 1977a). This
twelve-month study emphasized the need to establish standard permissible viral
levels for water and shellfish and the necessity for including enteric virus
testing in monitoring programs. Results of this investigation showed the
presence of human pathogenic viruses (coxsackie, ECHO, poliovirus) and
bacterial pathogens (Salmonella enteritidis, Pseudomonas aeruginosa) in New
York Bight waters. The data strongly suggest that the sources of these
contaminants are Hudson-Raritan Bay discharges, rather than dumping at the
sewage sludge disposal site.
There is little information on the survival of sludge pathogens at the
106-Mile Site. In one study, conducted during a Camden sludge disposal
operation, surface and subsurface water samples were collected from a
stationary ship and analyzed for total and fecal coliform bacteria (Vaccaro
and Dennett, 1977). Within the first hour of sampling inside the waste plume,
surface water samples produced positive results for total and fecal coliforms.
All of the subsurface samples yielded negative results for both tests.
5-20
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TABLE 5-7
FACTORS IDENTIFIED AS CONTRIBUTING TO THE
"DIE-OFF" OR DECLINE OF SEWAGE PATHOGENS
Cause
Adsorption and Sedimentation
Solar Radiation
Predation and Bacterial
Parasites
Bacteriophage
Nutrient Deficiencies and
Competition
Toxins and Antibiosis
Heavy Metal Ion Toxicity
Seasonal Temperature
Variations
Physical and Chemical
Characteristics
Reference
Orlob, 1956
Rittenberg et al., 1958
Gameson and Gould, 1975
Harrison, 1967
Reynolds, 1965
Mitchell, 1972
Mitchell et al., 1967
Carlucci and Pramer, 1960
Carlucci and Pramer, 1960
Jannasch, 1967
Jannasch, 1968
Moebus, 1972a
Won and Ross, 1973
Aubert et al., 1974
Mitchell, 1971
Moebus, 1972b
Sieburth, 1968
Jones, 1964
Jones, 1967
Jones and Cobet, 1974
Moebus, 1972a
Carlucci and Pramer, 1959
Jannasch and Wirsen, 1973
Jones, 1971
MacLeod, 1968
Accumulation of sludge on the ocean bottom at the 106-Mile Site is highly
unlikely (see previous discussion on dilution and dispersion). The depth of
the site and the thermocline/pycnocline barriers will restrict the settling of
sludge and encourage horizontal dispersion throughout the water column. The
chance of contamination of bottom sediments by pathogenic organisms is fairly
remote and not a primary issue. Pathogens attached to particulate sludge
material suspended in the water column will be vulnerable to predators,
toxins, solar radiation, and a number of other factors contributing to
5-21
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inactivation of disease-causing organisms. The potential for causing disease
along coastal waters is seemingly remote; however, the actual survival of
sludge-associated human pathogens dumped at an oceanic site so far from shore
is still relatively unknown. If the 106-Mile Site is used for future sewage
sludge disposal, the monitoring program accompanying the disposal must address
these questions.
ENVIRONMENTAL MONITORING
The feasibility of monitoring for impacts of sewage sludge disposal at the
106-Mile Site was addressed at the Toms River Hearing. Opinions expressed at
the hearing varied on monitoring feasibility, but all agreed that monitoring
the 106-Mile Site, to detect and control short- and long-range impacts of
sludge dumping, would be most difficult (some felt it would be impossible).
NOAA stated that such a program would be technically possible, but very
expensive:
The techniques required for a monitoring program are
available. It is, however, more time-consuming and thus more
expensive to monitor a site which is 100 miles from shore and
2,000 meters deep than one which is nearshore and shallow.
An effective monitoring program would be built upon our
existing knowledge. Initial work directed specifically at
sewage sludge would be to define the volume of water through
which the sludge settles, the area of the bottom accepting
the waste, the rate of water renewal, and rates of deep-sea
sludge oxidation. The effects of sludge on deep-sea biota
would be addressed through field sampling and by application
of specialized techniques for observation at low temperature
and high pressure. It is estimated that such a program would
require about $2.5 million for each of its first two years
and, thereafter, about $1.0 million per annum (Martineau,
1977). [All of the New York Bight monitoring currently costs
about $1 million.]
Considering the dispersion data from the site, which indicate that the
major potential effects of sludge dumping would occur in the water column
above the thermoclines (seasonal or permanent), monitoring could be simpler
than originally estimated because extremely deep sampling would be
unnecessary. However, the wider dispersion of materials in the upper water
column, would necessitate monitoring over a larger area.
5-22
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SURVEILLANCE
Surveillance of sludge disposal operations at the 106-Mile Site is feasible
although it would place an additional burden on the Coast Guard, requiring
allocation of additional personnel (Mullen, 1977).
ECONOMICS
EPA (1978) presents a thorough overview of the economic issues imposed by
using the 106-Mile Site for sewage sludge disposal. The salient points of
that discussion are presented below.
The most severe economic hindrance in transferring all sludge disposal
operations from the existing New York Bight Sludge Site to the 106-Mile Site
is the size of the existing fleet of sludge dump vessels. The increased costs
of using the 106-Mile Site rather than a nearshore site are caused by two
factors: (1) transport to the 106-Mile Site takes so much longer that
additional vessels are necessary to carry the same amount of material since
existing vessels are fully engaged in transit and disposal operations at
present sites, and (2) the time required for discharge will increase because
the rate will be based on the limiting permissible concentration rather than
the present average dumping rate of 5 hours.
Assuming equal discharge rates, the cost of using the 106-Mile Site would
be about twice the cost of using the Alternate Sewage Sludge Site, and six to
eight times the cost of continuing to use the 12-Mile Site. By 1981, the
estimated annual cost to municipal permittees for transporting sludge to the
106-Mile Site is estimated to be within a range of $124 million to $154
million. Many present at the Toms River Hearing felt that such a prohibitive
expense to the municipal dumpers would divert funds into ocean disposal which
could be used to provide land-based disposal alternatives,, thus perpetuating
ocean disposal (NOAA, 1977; Forsythe, 1977; Kamlet, 1977).
5-23
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The projected cost of monitoring sludge disposal is discussed above. A
portion of the monitoring cost would be passed on to the permittees, further
increasing their economic burden. Similarly, the cost to Federal agencies
monitoring the site would be substantial.
Surveillance costs would be high if the 106-Mile Site were used for sludge
disposal. The USCG monitors sludge disposal operations at the New York Bight
Sludge Site with helicopters and patrol vessels. The 106-Mile Site is beyond
the normal range of this equipment, thus shipriders would be required, at an
additional expense to the USCG.
LOGISTICS
Use of the 106-Mile Site for sludge disposal would be logistically feasible
although initial delays of several months (primarily for obtaining suitable
vessels), would probably be necessary before implementation. Increased
traffic at the site would present additional navigational hazards; however,
dumping in quadrants of the site would tend to mitigate many of the hazards.
The Third Coast Guard District strongly recommended that the total amount
of dumping time per day be restricted to the 5-hour rate to avoid vessel
congestion at the dumpsite. Because of the increased transit time to the
106-Mile Site over the time to the existing site, the 12 vessels which now
comprise the fleet would be inadequate to handle the sludge volumes;
therefore, additional vessels would be necessary. These additional vessels
would cause further traffic congestion in the 106-Mile Site area, thus posing
a greater risk of collision.
SUMMARY
Use of the 106-Mile Site for sewage sludge disposal would be environmentally
acceptable under carefully controlled conditions (outlined below), and
accompanied by a comprehensive monitoring program. However, substitution of
5-24
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the 106-Mile Site for existing Shelf sites would impose severe economic
burdens, surveillance and monitoring difficulties, and logistics problems.
Therefore, the following conclusions are made.
CONCLUSIONS
It is proposed that use of the 106-Mile Site for sewage sludge disposal be
decided case-by-case by EPA, on the basis of severity of need. Any permit
issued should include provisions for adequate monitoring and surveillance, to
prevent significant adverse impacts resulting from disposal. Sludge disposal
should be allowed at the site only under the following conditions:
• The 12-Mile Site or any other site cannot safely accommodate more
sludge disposal without endangering public health, severely
degrading the marine environment, or degrading coastal water
quality.
• Independent surveillance by the U.S. Coast Guard or by an unbiased
observer (the latter at the permittee's expense) should be
conducted.
• Monitoring for short- and long-term impacts should be accomplished
by federal agencies and environmental contractors (the latter at the
permittee's expense). This monitoring must include studies of the
fate of solids and sludge micro-organisms, inside and outside the
site, and a comprehensive analysis of environmental effects.
• Vessels should discharge the sludge into the wakes so that maximum
turbulent dispersion occurs.
• Vessels discharging sludge should be separated from vessels
discharging chemical wastes, so that the two types of wastes do not
mix.
• Key constituents of the sludge should be routinely analyzed in barge
samples at a frequency to be determined by EPA on a case-by-case
basis, but sufficient to evaluate mass loading accurately at the
site.
• Routine bioassays should be performed on sludge samples using
appropriate sensitive marine organisms.
5-25
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Chapter 6
LIST OF PREPARERS
Preparation of this EIS was a joint effort employing many members of the
Interstate Electronics Corporation scientific and technical staff and EPA
Region II. This chapter summarizes the background and qualifications of the
primary preparers of the document.
KATHLEEN M. KING
Ms. King is the principal author of the EIS. She is a marine biologist and
Manager of the Biological Sciences Branch within the contractor's Oceanic
Engineering Division. She holds a B.S. in Biological Sciences from the
University of California and an M.A. in Biology (with emphasis on marine
biology) from California State University, Long Beach.
Ms. King prepared Chapters 1, 2, 4, and 5 of this EIS. As the Coordinator
of the entire document, she directed writing efforts on other sections of the
EIS, edited all chapters, and maintained liaison with EPA Headquarters and
Region II.
JOHN R. DONAT
Mr. Donat, an Associate Oceanographer at Interstate Electronics, holds a
B.S. in Chemical Oceanography from Humboldt State University and is presently
continuing study in preparation for an advanced degree in chemical ocean-
ography.
Mr. Donat prepared Appendix B and several sections in Appendix A of the
106-Mile Site EIS.
6-1
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WILLIAM DUNSTAN
Dr. Dunstan, the Program Manager for the EPA program on Ocean Disposal Site
Designation, holds a B.S. in Engineering from Yale University, an M.S. in
Marine Biology from Florida State University, and a Ph.D. in Biology from
Florida State.
Dr. Dunstan prepared Appendix C and conducted extensive initial editing of
the other Chapters and Appendices.
MARSHALL HOLSTROM
Mr. Holstrom is a marine biologist and staff EIS coordinator at Interstate
Electronics. He holds a B.A. and M.A. in Biology from Stanford University.
He has completed several years of graduate work in Marine Biology at the
University of Southern California.
Mr. Holstrom authored sections in Chapters 2 and 4 of the EIS.
RANDY McGLADE
Mr. McGlade, a marine biologist at Interstate Electronics, received his
B.S. and M.A. in Marine Biology from California State University, Long Beach.
Mr. McGlade prepared Chapters 3 and 6 of this EIS, and participated in the
preparation of Appendix A.
STEPHEN M. SULLIVAN
Mr. Sullivan, a Biological Oceanographer at Interstate Electronics,
obtained his B.S. in Oceanography from Humboldt State University in 1977 and
has since completed graduate courses at Scripps Institute of Oceanography and
California State University, Fullerton.
Mr. Sullivan prepared the biology sections of Appendix A.
6-2
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Chapter 7
GLOSSARY, UNITS OF MEASURE, AND REFERENCES
GLOSSARY
Abundance
Abyssal
Accuracy
Acute Effect
Adsorb
Alkalinity
Ambient
Amphipods
The number of individuals of a species
or taxon inhabiting a given area.
Pertaining to the great depths of the
ocean beyond the limits of the
Continental Slope, generally from 2,000
to 5,000 m depth.
The extent to which the results of a
calculation or the readings of an
instrument approach the true values of
the calculated or measured quantities,
and are free from error. When applied
to methods of analysis, accuracy is a
measure of the error of a method and may
be expressed as a comparison of the
amount of an element or compound
determined or recovered by the test
method and the amount actually present.
The death or incapacitation of an
organism caused by a substance within a
short time (normally 96 hours).
To adhere in an extremely thin layer of
molecules to the surface of solid
bodies.
The sum of anions of weak acids in
seawater plus hydroxide ion (OH ) minus
hydrogen ion (H ) concentrations.
Alkalinity can usually be calculated by
the empirical equation of alkalinity
[milliequivalent/kg = 0.061 x salinity
(g/kg)].
Pertaining to the normal or unaffected
conditions of the surrounding
environment.
A large order of predominantly marine
crustaceans ranging from free-living
planktonic and benthic forms to
parasitic groups. Body shape in
free-living forms is usually laterally
compressed or shrimplike.
7-1
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Anaerobic digestion
Anthropogenic
Antibiosis
AnticycIonic
Anticyclonic eddies
Apex
Appropriate sensitive
benthic marine
organisms
Appropriate sensitive
marine organisms
Aqueous
Assemblage
Background level
Bacteriophage
Baseline data
Digestion of organic matter by bacterial
action in the absence of oxygen.
Relating to the effects or impacts of
man on nature.
Antagonistic association between two
organisms whereby one is adversely
affected.
Clockwise rotation around a high
pressure zone (winds) or around a cold
core (ocean currents) in the northern
hemisphere.
Mesoscale (50 to 100 km) features of
oceanic circulation in which water flows
in a circular (clockwise) pattern around
warm core waters.
See New York Bight Apex.
Species representing a range of bottom-
feeding types (filter-feeding, deposit-
feeding, burrowing) chosen' from a list
of the most sensitive species recognized
by EPA as being reliable test organisms
to determine the anticipated impact on
the site.
Species representative of phytoplankton
or zooplankton, crustacean or mollusc,
and fish chosen from a list of the most
sensitive species documented in
scientific literature or recognized by
EPA as being reliable test organisms to
determine the anticipated impact on the
site.
Similar to, containing, or dissolved in
water.
A recurring group of organisms having a
common habitat.
The naturally occurring level of a
measurable parameter within an
environment.
Virus affecting specific bacteria.
Data collected prior to the initiation
of actions which have the potential of
altering an existing environment.
7-2
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Baseline surveys
Benthos
Bight
Bioaccumulate
Bioassay
Biochemical Oxygen
Demand (BOD)
Biomass
Biota
Biotic groups
BLM
Bloom
Boreal
°C
C/N
Surveys conducted to collect information
prior to the initiation of actions which
have the potential of altering an
existing environment.
All marine organisms (plant or animal)
living on or in the bottom; also, the
floor or deepest part of the ocean.
A slight indentation in the shore line
of an open coast or of a bay, usually
crescent-shaped.
The uptake and assimilation of
materials (e.g., heavy metals) leading
to an elevated concentration of the
substance within an organism's tissue,
blood, or body fluid.
Determination of the toxicity of a
substance by its effect on the growth or
survival of an organism; usually
calculated as LC50 or EC50.
The amount of oxygen consumed by micro-
biological organisms while assimilating
and oxidizing organic (and some
nitrogenous) materials in water or
wastewater under specified environmental
conditions and time periods.
The amount (weight) of living organisms
inhabiting a given area or volume.
Collectively, plants and animals of a
region.
Organisms which are ecologically,
structurally, or taxonomically similar.
Bureau of Land Management.
Relatively high concentrations of
plankton in an area resulting from their
rapid growth and reproduction.
Pertaining to the higher northern
latitudes, as opposed to tropical.
Degrees Celsius.
Carbon/Nitrogen Ratio.
7-3
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Carcinogen
CE
Cephalopods
CFR
Chaetognaths
Chemostat
Chlorophyll
Chlorophyll £
Chronic effect
cm
cm/sec
Coccolithophorid
Coelenterate
Coliforms
Compensation depth
A substance or agent producing cancer.
U.S. Army Corps of Engineers.
Members of the phylum Mollusca,
including squid, octopus, or cuttlefish.
Code of Federal Regulations.
A phylum of small, elongate, trans-
parent, wormlike invertebrates, also
known as arrow-worms, which are
important carnivores in the zooplankton
community.
An apparatus for the continuous culture
of bacterial populations in a steady
state; rate of growth is governed by the
rate at which fresh nutrients flow into
the system.
A group of green plant pigments which
receives and transforms the light energy
used in photosynthesis and primary
production.
A specific green plant pigment used in
photosynthesis and used as an indication
of phytoplankton biomass.
The sublethal effect of a substance on
an organism which over a long period of
time alters the normal processes and
functions of the organism.
Centimeter(s).
Centimeter(s) per second.
Ultra-microscopic planktonic algae, the
cells of which are surrounded by an
envelope of small calcareous discs.
A animal phylum which includes hydroids,
sea anemones, jellyfish, and corals.
Bacteria residing in the colon of man
and animals; indicators of fecal
pollution.
The depth at which photosynthetic oxygen
production equals oxygen consumed during
respiration in a 24-hour period.
7-4
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Continental Margin
Continental Rise
Continental Shelf
Continental Slope
Contour line
Copepods
Coriolis effect
Crustaceans
Ctenopbores
Current meter
Current shear
The zone between the shoreline and the
deep ocean floor; generally consists of
the Continental Shelf, Continental
Slope, and the Continental Rise.
A transitional zone b.etween the
Continental Slope and the ocean floor
which is less steeply sloped than the
Continental Slope.
Part of the Continental Margin extending
seaward from the coast to a variable
depth, generally 200 m.
The steeply descending slope lying
between the Continental Shelf and the
Continental Rise.
A chart line connecting points of equal
elevation above or below a reference
plane, such as sea level.
A large group of usually small,
planktonic crustaceans that are an
important link in the oceanic food
chain.
An apparent force resulting from the
earth's rotation which deflects moving
particles in the northern hemisphere to
the right, and in the southern
hemisphere to the left.
Invertebrates with jointed appendages
and a segmented exoskeleton. The group
includes barnacles, crabs, shrimps,
lobsters, copepods, and amphipods.
Predominantly planktonic marine
invertebrates, commonly referred to as
comb jellies or sea walnuts.
Any device for measuring and indicating
speed, flow, volume, or direction of
flowing water.
The measure of the spatial rate of
change of current velocity with units of
cm-sec"'- m"^- .
Decapods
The largest order of crustaceans in
which the animals have five sets of
locomotory appendages, each joined to a
7-5
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Demersal
Density
Diatoms
Diffusion
Dinoflagellates
Discharge plume
Dispersion
Dissolved oxygen
Dissolved solids
Diversity
Dominant
organisms
Dry weight
segment of the thorax. Includes crabs,
lobsters, and shrimp.
Living at or near the sea bottom.
The mass per unit volume of a substance.
Single-celled, primarily planktonic
plants with a cell wall made of silica.
They are abundant world wide and are
important elements in many food chains.
Spontaneous mixing of particles in a
liquid under influence of a concentra-
tion gradient, with net movement from an
area of higher to lower concentration.
Single-celled, planktonic organisms with
flagella, which are an important part of
marine food chains.
The region affected by a discharge of
waste such that it can be distinguished
from the surrounding water.
The movement of discharged material over
large areas by the natural processes of
mixing.
The quantity of oxygen dissolved in a
unit volume of water; usually expressed
in ml/liter.
The dissipation of solid matter in
solution, such as salt dissolved in
water.
A measure that usually takes into
account the number of species and the
number of individuals of each species
present in a given area.
A species or group of species which
strongly affect a community because of
their abundance, size, or control of
energy flow.
The weight of a sample of organisms
after all water has been removed; a
measure of biomass.
7-6
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EC50 (Effective
concentration 50)
Echinoderms
Ecosystem
Eddy
Effluent
EIS
Endemic
Enteric
EPA
EPA Headquarters
EPA Region II
Epifauna
Epipelagic
Estuary
In bioassay studies, the concentration
of a substance which causes a defined
effect in 50 percent of the test
organisms during a given time (usually
96 hours).
A phylum of benthic marine invertebrates
having rigid calcareous plates and
spines or calcareous plates embedded in
the skin. This group includes starfish,
sea urchins, sea lilies and sea-
cucumbers .
The organisms of a community together
with their physical and chemical
environment.
A water current moving contrary to the
direction of the main current,
especially in a circular motion.
Liquid waste from sewage and industrial
processing.
Environmental impact statement.
Restricted or peculiar to a locality or
region.
Referring to the intestinal tract of man
and animals.
U.S. Environmental Protection Agency.
U.S. Environmental Protection Agency
Headquarters, Washington, D.C.
U.S. Environmental Protection Agency,
Region II, New York, N.Y.
Animals which live on the surface of the
sea bottom.
Ocean zone extending from the surface to
200 m in depth.
A semienclosed coastal body of water
which has a free connection to the sea
and within which the sea water is
measurably diluted with fresh water.
7-7
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Euphausiids
°F
Fauna
FDA
Flocculate
Flora
FWPCA
g/cm
Gastropods
Geostrophic current
Gulf Stream
Heavy metals or
elements
Helminths
High-level radioactive
waste
Histopathology
Hydrography
Shrimp-like, planktonic crustaceans
which are widely distributed in oceanic
waters. These organisms, also known as
krill, may grow to 8 cm in length and
are an important link in the oceanic
food chain.
Degrees Fahrenheit.
The animal life of a particular
location, region, or period.
Food and Drug Administration.
The process of aggregating a number of
small, suspended particles into small
masses.
The plant life of a particular location,
region, or period.
Federal Water Pollution Control Act.
Grams per cubic centimeter.
Molluscs that possess a distinct head
(generally with eyes and tentacles) and
a broad, flat foot, and which usually
have a spiral shell.
A current resulting from the balance
between gravitational forces and the
Coriolis effect.
A relatively warm, swift, northward
flowing ocean current which flows
through the Caribbean, Gulf of Mexico
and up the North American east coast.
Elements which posseses a specific
gravity of 5.0 or greater.
Parasitic worms.
The aqueous or solid waste resulting
from the reprocessing of irradiated fuel
from nuclear power reactors.
The study of tissue changes associated
with disease.
The measurement and description of the
physical features of bodies of water.
7-8
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Ichthyoplankton
IEC
Indigenous
Infauna
In situ
Insolation
Invertebrates
ISC
Isobath
kg
kg/day
km
LC50 (Lethal
concentration 50)
Limiting permissible
concentration (LPC)
LORAN-C
m
m
m/sec
u
ug/kg
Planktonic fish eggs and weakly motile
fish larvae.
Interstate Electronics Corporation.
Having originated, or naturally
occurring, in a particular region or
environment.
Animals which live in or burrow beneath
the surface of the sea bottom.
(Latin) = in the original or natural
setting.
Solar radiation received at the earth's
surface.
Animals without backbones.
Interstate Sanitation Commission.
A line on a marine chart joining points
of equal depth below sea level.
Kilogram(s).
Kilogram(s) per day.
Kilometer(s).
In bioassays the concentration
of a substance which causes 50%
mortality in the population of the test
organisms during a given time (usually
96 hours).
A concentration of a waste substance
which, after initial mixing, does not
exceed marine water quality criteria or
cause acute or chronic toxicity.
Long Range Aid to Navigation.
Meter(s).
Cubic meter(s).
Meter(s) per second.
Micron(s); 10 meter.
Microgram(s) per kilogram, or millionth
gram per kilogram.
7-9
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ug/1
Macrozooplankton
Marine
MARMAP
Mesopelagic
mg
mg/1
mi
Micro-organisms
Mid-Atlantic Bight
Mixed layer
ml
ml/m /hr
tltl^f!
Monitoring
mph
MPRSA
Mutagen
Microgram(s) per liter, or millionth
gram per liter.
Planktonic animals with sizes between
200 and 2,000 microns (10~6m), usually
composed of copepods, chaetognaths, and
larval forms.
Pertaining to the sea.
Marine Resources Monitoring, Assessment,
and Prediction Program.
Relating to depths of 200 to 1,000 m
below the ocean surface.
Milligram(s), or thousandth gram.
Milligram(s) per liter
Mile(s).
Microscopic organisms including bac-
teria, protozoans, and some algae.
The Continental Shelf extending from
Cape Cod, Massachusetts to Cape
Hatteras, North Carolina.
The upper layer of the ocean which is
well mixed by wind and wave activity.
Milliliter(s), or thousandth liter.
Milliliter(s) per square meter per hour.
Millimeter(s), or thousandth meter.
As used here, to observe environmental
effects of disposal operations through
biological, physical and chemical data
collection and analysis.
Mile(s) per hour.
Marine Protection, Research, and
Sanctuaries Act.
A substance which increases the
frequency or extent of mutations.
7-10
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Myctophids
Nannoplankton
NAS
NASA
Nekton
NEPA
Neritic
Neuston
New York Bight
New York Bight Apex
NJDEP
nmi
NOAA
NOAA-MESA
A group of small mesopelagic fish which
possess light-emitting organs and
undergo daily large-scale vertical (deep
to near-surface) migrations.
Minute planktonic plants and animals
which are 50 microns or less in size.
Individuals of this size will pass
through most plankton nets and are
therefore usually collected by
centrifuging water samples.
National Academy of Science.
National Aeronautics and Space
Administration.
Free-swimming animals which
independently of water currents.
move
National Environmental Policy Act of
1969.
Pertaining to the region of shallow
water adjoining the seacoast and
extending from low-tide mark to 200 m
depth.
A community of planktonic organisms
which are associated with the surface
layer of water; mainly composed of
certain copepods and the eggs and larvae
of fish.
The Continental Shelf which extends from
Montauk Point, Long Island to Cape May,
New Jersey.
A portion of the New York Bight bounded
by 40°10'N latitude and 73°30'W
longitude.
New Jersey Department of Environmental
Protection.
Nautical mile(s).
National Oceanic and Atmospheric Admini-
stration.
National Oceanic and Atmospheric Admini-
stration-Marine Ecosystems Analysis.
7-11
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NOAA-NMFS
NSF
Nuisance species
Nutrient
OCS
ODSS
Organophosphate
pesticides
Ortho-phosphate
Oxygen minimum layer
Parameters
Particulates
Pathogen
PCB
Pelagic
Perturbation
pH
National Oceanic and Atmospheric Admini-
stration-National Marine Fisheries
Service.
National Science Foundation.
Organisms without commercial value which
out-compete or harm commercially
important species.
Any substance which promotes growth or
provides energy for biological
processes.
Outer Continental Shelf.
Ocean Dumping Surveillance System.
A phosphorus-containing organic pesti-
cide, such as parathion or malathion.
One of the possible salts of ortho-
phosphoric acid; an essential nutrient
for marine plant growth.
The depth in the water column where the
lowest concentration of dissolved oxygen
naturally occurs.
Values or properties which describe the
characteristics or behavior of a set of
variables.
Fine solid particles individually
dispersed in water.
Producing or capable of producing
disease.
Polychlorinated biphenyl.
Pertaining to water of the open ocean
or organisms inhabiting this region
including plankton, nekton and neuston.
A disturbance of a natural or regular
system.
A term used to describe the negative
logarithm of the hydrogen ion.
Conventionally, pH 7 is considered
neutral, less than 7 is acidic,and
greater than 7 is alkaline. Range 1 to
14.
7-12
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Photic Zone
Phytoplankton
Plankton
Polychaetes
ppb
ppm
ppt (o/oo)
Precipitate
Precision
Predator
The layer in the ocean from the surface
to the depth where light is reduced to
1% of its surface value.
Planktonic plants; the base of most
oceanic food chains.
Usually small passively floating or
weakly motile animal or plant life
occurring in a body of water.
The largest class of the phylum Annelida
(segmented worms), distinguished by
paired, lateral, fleshy appendages
provided with bristles (setae) on most
segments.
Parts per billion. A unit of
concentration of a mixture indicating
the number of parts of a constituent per
billion parts of the entire mixture.
Parts per million. A unit of
concentration of a mixture indicating
the number of parts of a constituent per
million parts of the entire mixture.
Parts per thousand. A unit of
concentration of a mixture indicating
the number of parts of a constituent per
thousand parts of the entire mixture.
A solid separating from a solution or
suspension by chemical or physical
change.
When applied to methods of analysis,
precision is a measure of the
reproducibility of a method when
repeated- in a homogeneous sample under
controlled conditions, regardless of
whether or not the observed values are
widely displaced from the true values as
a result of a systematic or constant
errors present throughout the
measurements. Precision can be
expressed by the standard deviation.
An animal which eats other animals.
7-13
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Primary production
Protozoa
Pycnocline
Quantitative
Recruitment
Release zone
Runoff
Salinity
Sea state
sec
Shelf Water
Shellfish
Shiprider
The amount of organic matter photo-
synthesized by plants from inorganic
substances per unit time per unit area
or volume.
Microscopic, single-celled organisms
which include the most primitive forms
of animal life.
A vertical density gradient in some
layer of a body of water, positive with
respect to depth and much greater than
the gradients above and below it.
Pertaining to the numerical measurement
of a parameter.
Addition to a population of organisms by
reproduction or immigration of new
individuals.
An area 100 m on either side of the
disposal vessel extending from the point
of first waste release to the end of the
release.
The portion of precipitation on the land
that ultimately reaches streams
oceans.
or
The amount of dissolved salts in
seawater measured in parts per thousand.
The numerical or written description of
ocean roughness.
Second(s).
Water which originates on or can be
traced to the Continental Shelf. It has
characteristic temperature and salinity
values which make it identifiable.
Any aquatic invertebrate having a shell
or exoskeleton, esp cially any edible
mollusc or crustacean.
An observer aboard ship assigned by the
Coast Guard to assure that ocean
disposal operations are conducted
according to the permit specifications.
7-14
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Short dumping
Significant wave
height
Slope Water
Sludge
Species
Specific gravity
SPM
sq
SS
Standing stock
Stress
Surfactants
Surveillance
Suspended solids
The discharge of waste from a vessel
prior to reaching a designated disposal
site. This may occur legally under
emergency conditions, or illegally if
done under normal conditions.
The average height of the one-third
highest waves in a given wave group.
Water which originates on or can be
traced to the Continental Slope. It has
characteristic temperature and salinity
values which make it identifiable.
A precipitated solid matter produced by
sewage and chemical waste treatment
processes.
A group of morphologically similar
organisms capable of interbreeding and
producing viable offspring.
The ratio of the density of a substance
relative to the density of pure water at
4°C.
Suspended particulate matter.
Square.
Suspended solids.
The biomass or abundance of living
material per unit volume or area.
A effect or series of effects which
disrupt the normal ecological
functioning of an area.
An agent which lowers surface tension
(e.g., soap, bile and certain
detergents).
Systematic observation of an area by
visual, electronic, photographic, or
other means for the purpose of ensuring
compliance with applicable laws,
regulations, and permits.
Finely divided particles of a solid
temporarily suspended in a liquid (e.g.,
soil particles in water).
7-15
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Synergistic
Taxon (pi. Taxa)
TCH
Temporal distribution
Teratogen
Terrigenous sediments
Thermocline
TKN
TOG
Trace metal or
element
Trend Assessment
Surveys
Trophic level
Turbidity
Describing an ecological association in
which a process or behavior of an
organism is enhanced by the presence of
another organism; describing an action
where the total effect of two or more
active components is greater than the
sum of their individual effects.
A taxonomic group or entity sufficiently
distinct to be distinguished by name and
to be ranked in a definite category.
Total carbohydrate content.
The distribution of a parameter over
time.
A chemical agent which causes
developmental malformations and
monstrosities.
Shallow marine sedimentary deposits
composed of eroded terrestrial material.
A sharp temperature gradient which
separates a warmer surface water layer
from a cooler subsurface layer, and is
most pronounced during summer months.
Total Kjeldahl nitrogen.
Total organic carbon.
An element found in the environment in
extremely small quantities.
Non-seasonal surveys conducted over
long periods to detect shifts in
environmental conditions within a
region.
Feeding levels in the food chain of a
community which determine the flow of
energy and materials from plants to
herbivores to carnivores and
decomposers.
Cloudy or hazy appearance in seawater
caused by a suspension of colloidal
liquid droplets, fine solids, or small
organisms.
7-16
-------
Turnover rate
USCG
Virus
Water mass
Water type
Wet weight
yd3
Zooplankton
The time necessary to replace the entire
standing stock of a population;
generation time.
U.S. Coast Guard.
An agent capable of infecting animals,
plants and bacteria which is totally
dependent on living cells for its
reproduction.
A body of water usually identified by
its temperature, salinity and chemical
characteristics and normally . consisting
of a mixture of water types.
Water defined by a narrow range of
temperature and salinity.
The weight of organisms before drying
them to remove the internal water.
Cubic yard(s).
Usually small, passively floating or
weakly swimming animals which are
important in many marine and freshwater
food chains.
7-17
-------
UNITS OF MEASURE (ENGLISH EQUIVALENTS OF METRIC UNITS)
Metric
English
centimeter (cm)
meter (m)
kilometer (km)
2
square meter (sq m; m )
2
square kilometer (sq km; km )
gram (g)
kilogram (kg)
metric ton (tonne)
liter (1)
3
cubic meter (cu m; m )
centimeters/second (cm/sec)
kilometers/hour (km/hr)
Celsius (°C)
.2,
0.4 inches (in)
1.1 yards (yds)
0.6 statute miles (mi)
0.54 nautical miles (nmi)
3
1.2 square yards (sq yd; yd )
0.29 square nautical miles (sq nmi; nmi*)
0.035 ounces (oz)
2.2 pounds (Ib)
1.1 short tons (2,000 Ibs)
0.26 gallons (gal)
3
1.3 cubic yards (cu yd; yd )
0.39 inches/second (in/sec)
0.54 knots (kn), nautical miles/hour
9/5 °C + 32 Fahrenheit (°F)
7-18
-------
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7-39
-------
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7-40
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7-42
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APPENDICES
-------
APPENDIX A
ENVIRONMENTAL CHARACTERISTICS OF THE
106-MILE OCEAN WASTE DISPOSAL SITE
-------
CONTENTS
Title Page
METEOROLOGY A-l
Air Temperature A-l
Wind and Storms A-2
PHYSICAL CHARACTERISTICS A-4
Water Masses A-4
Current Regimes A-ll
Waves A-13
Temperature Structure A-l5
Salinity Structure A-l9
GEOLOGICAL CHARACTERISTICS A-24
CHEMICAL CHARACTERISTICS A-26
Water Column Chemistry A-26
Sediment Chemistry A-37
Biological Chemistry A-39
BIOLOGICAL CHARACTERISTICS A-42
Phytoplankton A-42
Zooplankton A-49
Nekton A-58
Benthos A-67
A-iii
-------
CONTENTS (continued)
ILLUSTRATIONS
Title Page
A-l Temperature-Salinity Lines of Water Masses and
Boundaries between Surface Water Categories in the
Area of the 106-Mile Site A-6
A-2 NOAA National Environmental Satellite Service Observations
of Shelf, Slope, and Gulf Stream Waters Surrounding the
106-Mile Site in May 1974 A-9
A-3 Stylized Section from the Continental Shelf through the Dumpsite
Eddy, Showing Surface Water Categories and Deeper Water Masses . . A-10
A-4 Marsden Square 116, Subsquares 81, 82, and 91, and the
106-Mile Site A-16
A-5 Average Monthly Sea-Surface Temperatures for
Subsquares 81, 82, and 91 in Marsden Square 116 A-17
A-6 Monthly Averages for Temperature versus Depth
Marsden Square 116, Subsquare 81 A-18
A-7 Monthly Averages for Temperature versus Depth
Marsden Square 116, Subsquare 82 A-18
A-8 Monthly Averages for Temperature versus Depth
Marsden Square 116, Subsquare 91 A-19
A-9 Average Monthly Sea-Surface Salinities for
Subsquares 81, 82, and 91 in Marsden Square 116 A-20
A-10 Monthly Averages for Salinity versus Depth
Marsden Square 116, Subsquare 81 A-21
A-ll Monthly Averages for Salinity versus Depth
Marsden Square 116, Subsquare 82 A-22
A-12 Monthly Averages for Salinity versus Depth
Marsden Square 116, Subsquare 91 A-23
A-13 Bathymetry in the Vicinity of the 106-Mile Site A-25
A-14 Monthly Averages of Oxygen Concentration versus Depth
at the 106-Mile Site A-28
A-15 Station Locations of Major Phytoplankton Studies
in the Northeastern Atlantic A-44
A-16 Vertical Distribution of Chlorophyll £ A-46
A-17 Summary of the Average Chlorophyll a Concentrations
at Inshore ,(less than 50 m) and Offshore (greater
than 1,000 m depth) in the Mid-Atlantic Bight A-46
A-18 Summary of Mean Daily Primary Production per Square
Meter of Sea Surface at Inshore (less than 50 m),
Intermediate (100 to 200 m), and Offshore (greater
than 1,000 m) Sites in the Mid-Atlantic Bight A-47
A-19 Station Locations of Major Zooplankton Studies in the
Northeastern Atlantic A-53
A-iv
-------
CONTENTS (continued)
TABLES
Number Title Page
A-l Air Temperature and Wind Data for the 106-Mile
Ocean Waste Disposal Site A-3
A-2 Return Period of Maximum Sustained Winds at the 106-Mile
Ocean Waste Site A-4
A-3 Monthly Wave Height Frequency for the 106-Mile Site A-14
A-4 Return Periods for High Waves at the 106-Mile Site A-14
A-5 Average Surface Temperature Ranges and Months of Minimum
and Maximum Temperatures for Subsquares 81, 82,
and 91 in Marsden Square 116 A-16
A-6 Average Temperature Ranges Between 100 and 500 M for
Subsquares 81, 82, and 91 in Marsden Square 116 A-17
A-7 Average Surface Salinity Ranges and Month of Minimum and Maximum
Salinity for Subsquares 81, 82, and 91 in Marsden Square 116 . . . A-20
A-8 Average Concentrations of Five Trace Metals in Waters
of the Northeast Atlantic Ocean A-32
A-9 Average Concentrations of Nutrients at Various Depths
in the 106-Mile Site A-35
A-10 Average Concentrations of Six Trace Metals in the
Top 4 Centimeters of Sediments A-38
A-ll Dominant Zooplankton Species in the Vicinity of the 106-Mile Site
(Number of Samples in Which the Species Comprised
50% or More of the Individuals of that
Group/Number of Stations Sampled) A-50
A-12 Dominant Neuston Species in the Vicinity of the 106-Mile Site
(Number of Samples in Which the Species Comprised 50% or
More of the Individuals of that Group/Number of Stations Sampled) . A-52
A-13 Zooplankton Biomass in the Mid-Atlantic A-57
A-14 Western Atlantic Cetaceans A-63
A-15 Threatened and Endangered Turtles Found in Mid-Atlantic
Slope Waters A-66
A-16 Average Number and Weight Per Tow of Demersal
Fish Taken At Shelf Edge and Slope During Fall
and Spring Trawl Surveys, 1969 - 1974 A-68
A-17 Benthic Infauna Collected at or near the 106-Mile Site A-73
A-v
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APPENDIX A
ENVIRONMENTAL CHARACTERISTICS OF THE
106-MILE OCEAN WASTE DISPOSAL SITE
METEOROLOGY
The New York Bight receives air from several regions, but air from the
tropical Atlantic or Gulf of Mexico predominates during most of the year. The
Bight often receives storms which are pushed eastward by the "prevailing
westerlies" from midwest areas where polar and tropical air masses meet.
However, due to the influence of several physical factors, the Bight possesses
a more uniform climate than continental areas in the same latitude.
The seasonal location of the Bermuda High is a primary determinant of
general weather conditions in the Bight. When the Bermuda High is centered
over the eastern seaboard, as in summer and early autumn, the Bight
experiences its longest periods of stable weather conditions. During winter,
spring, and late autumn the absence of this high pressure zone allows storms
from northeastern and southern regions to move into the Bight, causing extreme
weather conditions. However, even in the presence of the Bermuda High,
tropical storms and hurricanes move northwards through the Bight during late
summer and early autumn.
Warm air from the Gulf Stream region is advected towards coastal regions
throughout the year. In the Bight, the air is quickly cooled by Shelf Water,
which causes humid summer conditions and persistent fog during warm and cold
months.
AIR TEMPERATURE
Marine surface air temperatures in the area of the Bight are buffered
throughout the year by the influence of the underlying Atlantic waters.
Summer temperatures are lower and winter temperatures are higher in the Bight
than on adjacent coastal land masses.
A-l
-------
At the 106-Mile Site, air temperature data from 1949 to 1973 (Brower, 1977)
show that the mean maximum temperature ranged between 16.2°C in February to
29.9°C in July (Table A-l). The annual mean maximum temperature was 22.6°C.
The mean minimum temperatures for the same period ranged between -4.0°C in
February to 18.6°C in August. The annual mean minimum temperature was 5.7°C.
WINDS AM) STORMS
Northwesterly winds prevail over the 106-Mile Site from October to March,
with average speeds approaching 19 kn. From April to September the prevailing
winds are southwesterly and reach an average speed of 11 kn. The percentage
of winds greater than 33 kn increases seaward throughout the year. At the
dumpsite, there is a maximum frequency greater than 5% from November through
April, with a peak of 8.5% in February; it is less than 1% from May through
August, with a minimum of 0.2% in June. These infrequent summer winds are due
to disturbances by tropical cyclones and severe thunderstorms. Return values
of maximum sustained winds are presented in Table A-2.
The storms sweeping over the New York Bight and the 106-Mile Site are of
two general classifications: extratropical cyclones, which form outside the
tropic regions in marine or continental areas, and tropical cyclones, which
form in tropical waters, such as the Gulf of Mexico and the Caribbean Sea.
Prevailing winds and weather in the area of the New York Bight are quickly
altered by invading extratropical cyclones. Strong winds accompanying storms
often bring heavy rain or snow (Brower, 1977). Exceptionally cold north-
westerly winds are also characteristic of these storms. Nearly 600 such
storms were observed within the Bight region from May 1965 to April 1974.
Although tropical cyclones are infrequent in comparison with extratropical
cyclones, they are more destructive than any other type of storm (Brower,
1977). Wind speeds of tropical cyclones range from less than 34 kn to greater
than 63 kn. From 1871 to 1976, 114 tropical cyclones entered the New York
Bight, although the force of several of these storms had been reduced to the
level of an extratropical storm by the time they reached the Bight. The
A-2
-------
TABLE A-l
AIR TEMPERATURE AND WIND DATA FOR THE 106-MILE
OCEAN WASTE DISPOSAL SITE
Parameter
Air Temperature
No. of observations
Maximum Temp (°C)
Minimum Temp (°C)
Mean Temp (°C)
Surface Winds
No. of observations
Percent Frequency
^ 10 Knots
Percent Frequency
:=> 34 Knots
Mean Wind Speed
From All Directions
(knots)
Prevailing Direction
Mean Wind Speed
From Prevailing
Direction (knots)
Jan
436
17.3
-3.5
7.0
440
23.5
7.9
18.3
NW
20.9
Feb
308
16.2
-4.0
6.4
309
22.3
8.5
18.9
NW
21.7
Mar
403
16.6
-1.6
7.5
409
25.7
5.0
18.0
NW
19.2
Apr
516
20.1
3.3
10.5
514
34.3
4.3
14.6
SW
13.0
May
426
21.9
7.2
14.1
427
50.6
0.9
12.0
SW
12.5
Jun
520
26.8
12.2
19.6
521
54.9
0.2
11.2
SW
12.2
Jul
410
29.9
18.2
23.5
410
54.1
0.5
10.9
SW
12.6
Aug
421
29.4
18.6
24.0
423
51.3
1.2
11.2
SW
12.4
bep
526
27.9
14.7
21.6
528
46.4
2.0
12.4
NE
15.7
Oct
427
25.8
10.1
18.3
430
39.4
2.9
14.7
NW
17.1
Nov
529
21.6
3.7
13.5
529
28.8
5.9
16.9
NW
19.5
Dec
438
18.2
-0.3
9.2
444
26.1
6.5
17.8
NW
20.1
I
CO
Source: Adapted from Brower, 1977.
-------
TABLE A-2
RETURN PERIOD OF MAXIMUM SUSTAINED WINDS
AT THE 106-MILE OCEAN WASTE DISPOSAL SITE
Return Period
(Years)
5
10
25
50
100
Maximum Sustained
Winds (Knots)
72
79
90
99
111
*Period of Record: 1949-1973
Source: Brower, 1977.
greatest frequency of tropical cyclones in the New York Bight occurs during
late summer and early autumn. On the average, one tropical cyclone per year
has occurred in the Bight area over the past 106 years (Brower, 1977).
PHYSICAL CHARACTERISTICS
WATER MASSES
A water mass may be defined as a seawater parcel having unique properties
(temperature, salinity, oxygen content) or a unique relationship between these
properties. Each water mass thus defined is given a name which qualitatively
describes its location or place of origin. Water masses are produced in their
source areas by either or both of two methods: (1) alteration of temperature
and/or salinity through air-sea interchange, and (2) mixing of two or more
water types. After formation, the water masses spread at a depth determined
by their density relative to the vertical density gradient of the surrounding
water.
A water mass possesses unique properties, therefore physical oceanographers
have found it possible to represent any water mass by plotting data consisting
of two of three parameters (temperature, salinity, oxygen content) as
coordinates. In most cases, a temperature-salinity (T-S) diagram is
sufficient for the identification of a water mass. To construct such a
A-4
-------
diagram, water samples are generally taken from several depths at an
oceanographic station, and the temperature and salinity values for each sample
are determined. The values are plotted and a smooth curve is drawn through
each point, in order of depth. The water mass may appear as the entire curve
or as an area of the T-S diagram (Figure A-l). In cases of exceptionally
homogeneous water, a single point on the plot identifies the parcel, which is
then termed a "water type".
NOAA has characterized the physical oceanographic environment at the
106-Mile Site as extremely complex and variable in all but near-bottom water
(NOAA, 1977). Normally, the surface layer of the site is Slope Water, which
lies between fresher Shelf Water to the west and more saline Gulf Stream Water
to the east. However, conditions often change, periodically allowing Shelf
Water to enter the site from the west, or permitting Gulf Stream Water, in the
form of southward moving Gulf Stream eddies, to be present about 20% of the
time.
SHELF WATERS
The waters lying over the mid-Atlantic Continental Shelf are of three
general types: Hudson River Plume Water, surface Shelf Water, and bottom Shelf
Water (Hollman, 1971; Bowman and Wunderlich, 1977). Hudson River Plume Water
results from the combined discharge of the Hudson, Raritan, and various other
rivers into the northwest corner of the Bight Apex. This low-density water
floats over the Shelf waters as it moves into the Bight. During episodes of
high runoff, the plume may spread over large areas of the Bight and produce
large vertical and horizontal gradients of salinity. This water type persists
throughout the year, but its extent and depth are highly dependent on flow
rates of the Hudson and Raritan Rivers (McLaughlin et al., 1975). Generally,
the plume flows southward between the New Jersey coastline and the axis of the
Hudson Shelf Valley. Bowman and Wunderlich (1976) have found that the plume
direction is sensitive to wind stress and reversals in the residual flow.
Consequently, the plume may flow eastward between the New Jersey coastline and
the axis of the Hudson Shelf Valley, or may occasionally split and flow
eastward and southward.
A-5
-------
SALINITY (0/00)
33.0 33.5
34.0 34.5 35.0 35.5 36.0 36.5
i i i i
26-
24-
22-
20-
18-
16-
Lkl
ee
D
< 14 -
BC
LU
a.
LU
H 12 -
10 -
8 -
6 J
4 -
SLW
EDW
GSW
SHW
WATER MASSES
NADW North Atlantic Deep Water
WNAW Western North Atlantic Water
NACW North Atlantic Central Water
DSLW Deep Slope Water
WATER CATEGORIES
V'
'
7//
SHW Shelf Water
SSW Summer Shelf Water
SLW Slope Water
EDW Eddy Water
GSW Gulf Stream Water
'!
i
I/
Figure A-l. Temperature-Salinity Lines of Water Masses (dashed lines)
and Boundaries (solid lines) between Surface Water
Categories in the Area of the 106-Mile Site
Source: Goulet and Hausknecht, 1977.
A-6
-------
With the onset of heavy river discharges in the spring, surface salinities
in the Bight decrease, and, initially, a moderate, haline-maintained (i.e.,
maintained by salinity differences) stratification occurs, separating the
coastal waters into upper and lower layers - surface Shelf Water and bottom
Shelf Water. Decreasing winds and increasing insolation increase the strength
of the stratification and cause it to undergo a rapid transition (usually
within a month) from a haline-maintained to a thermal-maintained (i.e.,
maintained by temperature differences) condition (Charnell and Hansen, 1974).
This two-layer system becomes fully developed and reaches maximum strength by
August.
Surface Shelf Water is characterized by moderate salinity and high tempera-
tures in summer and low temperatures in winter. During the winter the water
column is vertically homogeneous over most of the Bight Shelf. With the rapid
formation of the surface Shelf Water layer during the spring, the bottom
waters become isolated until sufficient mixing takes place the next winter.
Bigelow (1933) found that the "cool cell" (having temperature typically less
than 10°C) of the bottom Shelf Water layer extended from south of Long Island
to the opening of Chesapeake Bay and seaward, nearly to the Shelf edge. This
cold water persists even after the surface layers have reached the summer
temperature maximum. Bigelow (1933) observed that this "cool cell" was
surrounded on all sides by warmer water.
The upper layer of the bottom Shelf Water is usually found between 30 and
100 m depth during the summer (Bowman and Wunderlich, 1977). Seaward, near
the Shelf edge, strong temperature, salinity, and density gradients occur
which limit large-scale mixing between the Shelf Waters and the waters found
over the Continental Slope, The mechanism by which bottom Shelf Water is
replenished is currently under study.
SLOPE WATERS
The Slope Water mass is a highly complex, dynamic body of water which
represents an area of mixing between Shelf Waters, which bound it on the north
A-7
-------
and west, and the Gulf Stream, which forms its southern boundary (Figure A-2).
These boundaries (frontal zones) are not stationary, but migrate seaward and
landward.
The Gulf Stream frequently migrates in such a way that anticyclonic
(clockwise) current loops are formed. Occasionally, these loops detach and
form separate entities known as eddies. The eddies are rings of Gulf Stream
Water surrounding a core of warm Sargasso Sea Water which originates to the
east of the Gulf Stream. Great amounts of this water may be advected to
depths as great as 800 to 1,000 m (NOAA, 1977). After detachment, the eddies
may migrate into the Slope Water region, usually in a southwesterly direction.
The eddies may interact with Shelf Water, causing considerable disturbance in
the water column within the 106-Mile Site (Figure A-2). While there appears
to be no seasonal pattern in the occurrence of the eddies, Bisagni (1976)
found that, based upon the trajectories of 13 eddies between 1975 and 1976,
the 106-Mile Site was wholly or partially occupied 20% of the time by eddies.
The eddies either dissipate or are reabsorbed by the Gulf Stream, usually in
the region of Cape Hatteras.
Periodically, a seaward migration of the Shelf/Slope Water boundary brings
highly variable Shelf Water into the upper waters of the disposal site,
thereby producing a complex vertical structure consisting of thin layers of
cool, low-salinity Shelf Water interspersed with warm, high-salinity Slope
Water.
Marcus (1973) found the Shelf/Slope front to be over the 200-m isobath
during summer, and north and west of this isobath during fall. Warsh (1975b)
reported winter and spring positions of this front ranging from the Shelf
break to 70 mmi (130 km) south and east of the Shelf break. The surface
waters of the Shelf are cooler than those of the Slope except during the
summer months, when the well-defined thermal front disappears. Fisher (1972)
has observed Shelf Water overlying Slope Water as far as 54 nmi (100 km)
seaward of the 200-m isobath. It was suggested that wind-driven advection may
be responsible for these migrations (Boicourt, 1973; Boicourt and Hacker,
1976). The onshore movement at lower depths of more saline Slope Water is
frequently associated with the offshore movement of low-salinity Shelf Water.
A-8
-------
SHF
I I
SHF
SLOPE
GULF STREAM
WARM EDDY
42
41
40
39
76"
75'
74"
73'
72'
7V
70'
69°
Figure A-2. NOAA National Environmental Satellite Service Observations
of Shelf, Slope, and Gulf Stream Waters Surrounding the
106-Mile Site in May 1974
Source: Warsh, 1975a.
The combined effects of mixing, boundary migration, and the usual seasonal
distribution of river runoff and rain produce a multitude of different water
types which cause a confused, interlayered water column. Figure A-3 displays
a stylized representation of this complex arrangement.
As in many other deep-water sites, the water column of the Slope Water mass
can be divided into three general layers: the upper or surface layer where
variability is great, the thermocline region where temperature changes rapidly
with depth, and the deep water where seasonal variability is small.
In Slope Water, generally, stratification forms in the upper water column
early in May and persists until mid or late fall when cooling and storm
activity destroy the strata. The permanent thermocline is at a depth of 100
to 200 m. During the period when the surface layers are stratified, a
seasonal thermocline forms which reduces the mixed layer to surface waters
A-9
-------
* FRESHER THAN
DSLW
WATER MASSES
North Atlantic Deep Water
Western North Atlantic Water
North Atlantic Central
Deep Slope Water
NADW
WNAW
NACW
DSLW
WATER CATEGORIES
Shelf Water
Summer Shelf Water
Slope Water
Eddy Water
Gulf Stream Water
SHW
SSW
SLW
EDW
GSW
Figure A-3. Stylized Section from the Continental Shelf through the
Dumpsite Eddy, Showing Surface Water Categories and Deeper
Water Masses
Source: Goulet and Uausknecht, 1977.
A-10
-------
above 30 to 40 m depth. From fall through early spring, the water column is
isothermal from the surface to depths between 100 and 200 m. At that point,
inversions are observed where low-salinity, cool Shelf Water flows under
warmer, high-salinity Slope Water.
The upper layer of the Slope Water mass is termed surface Slope Water. It
extends from the sea surface to a depth of about 200 m. The Shelf Water
extends seaward to the 200-m isobath, thus the vertical extent at the
Shelf/Slope interface is the same as that of the surface Slope Water mass.
Consequently, the seaward boundary of the Shelf Water mass borders only the
surface Slope Water mass; direct mixing between Shelf Water and the waters of
the permanent thermocline, below the surface Slope Water mass, does not
usually occur. However, mixing of waters across the Shelf Water/Slope Water
front may be caused by the strong circulation of eddies or meanders from the
Gulf Stream (NOAA, 1977).
.The spillage of cooler Shelf Water into the relatively warm surface Slope
Water has been documented by numerous researchers (Bowman and Weyl, 1972;
Wright, 1976b; Bigelow, 1933). Wright (1976a) suggests that significant
interchange of Shelf and Slope Waters may occur by this method. Beardsley et
al. (1976) report that this process of cool water spillage, or "calving," may
be related to the occurrence of anticyclonic Gulf Stream eddies and subsequent
migration of eddies along the Shelf edge. Based upon an aerial survey of the
formation and subsequent behavior of an anticyclonic eddy, Saunders (1971)
found that bottom Shelf Water may have been pulled off the Shelf and displaced
at least 81 nmi (150 km) southward to the eastern edge of the eddy. The
amount of Shelf/Slope Water mixing promoted by this process and the frequency
of occurrence of this type of induced mixing is unknown (Beardsley et al.,
3 3
1976). However, estimates range from 300 km /year to 8,000 km /year (Stommel,
1960; Fisher, 1972; Beardsley et al., 1975).
CURRENT REGIMES
There are no major, well-defined circulation patterns in the surface layers
of the Slope Water region (Wright, 1976a). Large natural variability and lack
of many long-term current records limit the usefulness of any estimates of the
A-ll
-------
mean current for this region. The westward-flowing Labrador Current loses its
distinctiveness somewhere west of the Grand Banks. Current measurements have
been made by several researchers using neutrally buoyant floats, parachute
drogues, and moored current meters in the region of the Shelf break and Slope
south of New England (Webster, 1969; Voorhis et al., 1976; Beardsley and
Flagg, 1976). The mean currents in this area flow westerly, generally of the
order of 0.2 to 0.4 kn (10 to 20 cm/sec), following the bottom contours. This
direction is similar to the direction taken by currents over the Continental
Shelf.
Wright (1976a) indicates that along the northern boundary, Slope Waters
flow slowly to the southwest, following the bathymetry to Cape Hatteras, where
they turn and flow seaward into the Gulf Stream. Evidence of a slow
northeastward flow along the Gulf Stream, in the southern part of the Slope
Water region, was also found. Wright (1976a) suggests that the Gulf Stream
and the Shelf Water form a cul-de-sac near Cape Hatteras, and, while some
interchange of water occurs across these boundaries, most of the water
entering the Slope Water region from the east probably exists along the same
path.
Beardsley et al. (1976) have studied the kinetic energy spectrum from
several sites over the Continental Shelf and Continental Slope. They found
that the considerable variance of kinetic energy in the Slope Water currents
was due to inertial periods of motion. This fraction of the variance in the
kinetic energy increased significantly towards the Shelf. From the long-term
records obtained at a site 204 km northeast (39°20'N, 70°W) of the dumpsite,
Beardsley et al. (1976) found that at 100 m depth much of the observed
variance in kinetic energy is due to motions recurring at 30-day intervals.
Anticyclonic or warm water eddies form north of the Gulf Stream, and
entrain Sargasso Sea water during formation. Movement of the eddies is
generally to the west or southwest, but may be interrupted for extended
periods, during which the eddies appear to remain stationary (Bisagni, 1976).
The mean speed calculated for five eddies was 3.8 nmi/day, and a mean
residence time of 22 days was found. A mean eddy radius of 30 nmi has been
estimated.
A-12
-------
The Oceanographer of the Navy (1972) reported a mean surface current speed
of about 25 cm/sec for a region near the 106-Mile Site. The direction of the
flow was either east-northeast or south-southwest. No other current estimates
for the 106-Mile Site have been reported in the literature.
WAVES
Brower (1977) has compiled wave data for the New York Bight coastal region,
the disposal site, and adjacent waters. The data are taken from the MESA New
York Bight Atlas Monograph 7, Marine Climatology (December 1976) and from
published and unpublished data for the New York and mid-Atlantic Bights.
Observations for the period from 1949 to 1974 are discussed below.
Wave heights increase with distance from shore throughout the year.
Differences in height are smaller during summer. The average frequency of
observations reporting hazardous waves (wave heights greater than or equal to
3.5 m) is 5% to 6% from December through March. The frequency of hazardous
waves at two stations near the New Jersey coast varies from less than 0.5% in
summer, to approximately 1% to 2% in winter, and the frequency seaward at the
dumpsite area varies from about 1% in summer to more than 10% from November
until March, with a peak of 13% in January and February (Table A-3). The
frequency tends to increase northwest to southeast across the Bight throughout
the year.
The frequency of waves less than 1.5 m in height follows the same pattern.
Near shore, the frequency ranges from 70% in winter to 90% in summer.
Offshore, at the dumpsite, the frequency of occurrence ranges from 35% to 40%
in winter, to nearly 80% in early summer.
Table A-4 lists the mean return periods (recurrence intervals) for maximum
significant wave height and the extreme wave height in the dumpsite. The
maximum significant wave height is the average height of the highest one-third
of the waves in a given wave group. Thus, Table A-4 shows that, for example,
there will be a maximum significant wave height of 21 m (69 ft) within the
site area at least once in every 100 years. Similarly, an extreme wave height
of 38 m (124 ft) will occur at the site at least once every 100 years.
A-13
-------
TABLE A-3
MONTHLY WAVE HEIGHT FREQUENCY FOR THE 106-MILE SITE
Wave Height
WH< 1.5 m
WH<2.5 m
WHa 3. 5 m
Number of Observations/Month
Jan
355
33.5
70.7
12.7
Feb
243
36.2
68.1
13.1
Mar
329
38.8
75.3
11.0
Apr
392
48.7
82.7
6.6
May
314
68.2
90.1
1.9
June
382
75.9
95.3
1.0
July
274
78.6
95.0
0.9
Aug
290
66.3
97.6
0.7
Sept
401
60.0
89.5
3.5
Oct
337
50.2
80.2
5.3
Nov
409
39.8
79.2
10.1
Dec
377
38.5
78.5
10.3
WH<1.5 M Percent frequency of wave height < 1.5 m
WH<2.5 M Percent frequency of wave height < 2.5 m
WH^3.5 M Percent frequency of wave, height a 3. 5 m
Mean return periods (recurrence intervals) for maximum significant and
extreme waves; i.e., the wave value is that height which will be equalled or
exceeded, on the average at least once during the period.
Source: Brower, 1977.
TABLE A-4
RETURN PERIODS FOR HIGH WAVES AT THE 106-MILE SITE
Return Period
(Years)
5
10
25
50
100
Maximum Significant
Wave in Meters
(Feet)
12.4 (41)
14.2 (47)
16.7 (55)
18.8 (62)
21.0 (69)
Extreme Wave
in Meters
(Feet)
22.4 (74)
25.5 (84)
29.7 (98)
33.6 (111)
37.6 (124)
Source: Brower, 1977,
A-14
-------
TEMPERATURE STRUCTURE
The waters in and around the 106-Mile Site are subject to the sudden
changes in temperature that may occur between Shelf and Slope Waters. Shelf
Water is always much colder than Slope Water during the winter months;
however, during the warmer months of the year, peak surface temperatures of
Shelf Water exceed those of Slope Water. The horizontal temperature gradient
between the two water masses becomes less marked only during periods of
warming and cooling. The water masses are then best distinguished by salinity
differences (Warsh, 1975b).
Warsh (1975b) summarized hydrographic data collected by the USCG and the
NOAA Marine Resources Monitoring, Assessment, and Prediction (MARMAP) program.
These data were taken during all seasons over an area encompassing the
mid-Atlantic Shelf and the Slope, including the disposal site region. Monthly
summaries from Marsden Square 116, subsquares 81, 82, and 91 (Figure A-4) are
discussed below. Table A-5 gives the ranges of temperatures for each
subsquare. These areas, while differing in the month of minimum temperature,
had the same month of maximum temperature. Surface temperatures ranged
between 5.1"C (February, subsquare 82) and 25.0°C (August, subsquare 82).
Figure A-5 illustrates the average monthly sea surface temperatures for each
subsquare.
In the upper 50 m of the water column, a seasonal thermocline develops in
late spring (May) and is usually present through mid-autumn (October).
However, remnants of the thermocline may be present as late as November. By
December, the water is generally isothermal to a depth of 100 m, but
temperature inversions have been observed near 30 m. These inversions may
persist through April or May. The permanent thermocline is usually found
between 100 and 500 m. The temperature ranges between 100 and 500 m for each
subsquare are listed in Table A-6.
From 500 to 1,000 m, temperature decreases to a range of 4°C to 6°C. At
depths below 1,000 m, the temperature ranges from 2°C to 4°C. Figures A-6,
A-7 and A-8 display the monthly temperature profiles for each subsquare.
A-15
-------
80°
40°
35
i-
80°
75°
75
82
91
81
70°
35°N
70°W
Figure A-4. Marsden Square 116, Subsquares 81, 82, and 91,
and the 106-Mile Site (Diagonal Lines in
Subsquare 82)
Source: Warsh, 1975b.
TABLE A-5
AVERAGE SURFACE TEMPERATURE RANGES AND MONTHS OF MINIMUM AND MAXIMUM
TEMPERATURES FOR SUBSQUARES 81, 82, AND 91 IN MARSDEN SQUARE 116
Sub square
81
82
91
Month of
Minimum
Temperature
January
February
March
Average Surface
Temperature
Range (°C)
7.8 - 24.9
5.2 - 25.0
5.4 - 24.5
Month of
Maximum
Temperature
August
Augus t
August
Source: Warsh, 1975b
A-16
-------
30
£ 25
UJ
§20
£ 15
Q.
i 10
M
M
N
Figure A-5. Average Monthly Sea-Surface Temperatures for
Subsquares 81, 82, and 91 in Marsden Square 116
Source: Warsh, 1975b.
TABLE A-6
AVERAGE TEMPERATURE RANGES BETWEEN 100 AND 500 M FOR
SUBSQUARES 81, 82, AND 91 IN MARSDEN SQUARE 116
Subsquare
81
82
91
Average Temperature
Ranges (°C) From 100 to 500 m
5.0 - 14.4
4.8 - 15.8
5.0 - 14.6
Source: Warsh, 1975b.
A-17
-------
.2 4
TEMPERATURE (°C)
6 8 10 12 14 16 18 20 22
24
TEMPERATURE ("CI
6 8 10 12 14 16 18 20 22 24 26
JUL-DEC
i i i i i
Figure A-6. Monthly Averages for Temperature versus Depth
in Marsden Square 116, Subsquare 81
Source: Warsh, 1975b.
TEMPERATUREPC)
6 8 10 12 14 16 18 20 22
246
TEMPERATURE(°C)
8 10 12 14 16 18 20 22 24 26
JUL-DEC
Figure A-7. Monthly Averages for Temperature versus Depth
Marsden Square 116, Subsquare 82
Source: Warsh, 1975b.
A-18
-------
TEMPERATURE I°C)
6 8 10 12 14 16 18 20 22
246
TEMPERATURE (°C)
8 10 12 14 16 18 CO 22 24
Figure A-8. Monthly Averages for Temperature versus Depth
Marsden Square 116, Subsquare 91
Source: Warah, 1975b.
SALINITY STRUCTURE
The waters in and surrounding the 106-Mile Site are subject to the sudden
changes in salinity which may occur between Shelf and Slope Waters. Shelf
Water is always fresher than Slope Water during the winter months. During the
warmer months of the year, the two water masses are best distinguished by
temperature differences. During periods of warming and cooling, the water
masses are best distinguished by salinity differences (Warsh, 1975b).
Table A-7 provides ranges of salinity for each subsquare. The ranges of
surface salinity are quite variable, and are dependent upon the water mass
present (Shelf, Slope, or Gulf Stream) within each square. The values range
from 32.70 ppt in June (subsquare 82) to 35.75 ppt in April (subsquare 81).
Figure A-9 illustrates the average monthly sea-surface salinities for each
area.
A-19
-------
Salinity generally increases to depths of 100 to 150 m, where the maximum
salinities are encountered. Values at these depths average approximately
35.75 ppt. Salinity then decreases with depth to about 400 m where the
minimum average salinity of 34.95 ppt exists. Below 400 m depth , the water
column is nearly isohaline, and salinity values may range between 34.90 ppt
and 35.05 ppt. Figures A-10, A-ll, and A-12 display the monthly salinity
profiles for each subsquare.
TABLE A-7
AVERAGE SURFACE SALINITY RANGES AND MONTH OF MINIMUM
AND MAXIMUM SALINITY FOR SUBSQUARES 81, 82, AND 91 IN MARSDEN SQUARE 116
Subsquare
81
82
91
Month of
Minimum
Salinity
January
June
May
Average Surface
Salinity Range
(ppt)
33.05 - 35.75
32.70 - 35.45
32.85 - 34.90
Month of
Maximum
Salinity
April
November
November
Source: Warsh, 1975b
36
3 35
e
^34
S33
32
I
I
M
M
0 N
Figure A-9. Average Monthly Sea-Surface Salinities for
Subsquares 81, 82, and 91 in Marsden Square 116
Source: Warsh, 1975b.
A-20
-------
32
SALINITYCVoo)
33 34 35
36
33
u
10
20
30
40
50
60
70
80
90
^? 1 00
t
f 200-
Q.
UJ
Q 300
400
500
600
700
800
900
1000
•<
2000'
3000
1 IX 1 II
H^ FEB-H
| | \APR-
mmm- • • • •
JAN-*| MAR-\-\\
\y MAY "A \
\ \ V
\ \\
\ \J
\ \
\ ^
\
H"
i-
1 _
—
—
1-
1-
J\
"" •>, iv; —
^» . . • .
; N» •- ;
i 8P
1 // //
i Vi
I I -
1
•» •• ^"
• —
- f '-
f
JAN - JUN l
i i i
SALINITY(°/oo)
34 35
36
u
10
20
30
40
50
60
70
80
90
•§ 100
fE 200
UJ
Q 300
400
500
600
700
800
900
1000
2000'
3000
B— fm\\^\J • « •« o — «•
^ 1 \ t _ O C D
IHrOCT~
ttf \
1 \ -
11 \\
\\ \i
11 -
M -
NOV~iM ~
DEC \\1 "
: \l' "
Or
w
'. ! ~
1
j
1
: i :
f
i
i
i
L "l ~1
JUL- DECf
i i i
Figure A-10.
Monthly Averages for Salinity versus Depth
in Marsden Square 116, Subsquare 81
Source: Warsh, 1975b.
A-21
-------
0
10
30
40
50
60
70
80
90
_ 100
E ' :
x 200
u3 300
Q
400
500
600
700
800
900
1000
2000
3000
32
SALINITY (°/oo)
33 34 35 36
33
SALINITY (°/00)
34 35
36
V
\\ MAY--^
IVJUN t\
APR
FEB-JUN
i i
10
20
30
40
50
60
70
80
90
_ 100
E :
I 200
&300
400
500
600
700
800
900
1000
*
2000
3000
\ /A f/
tnrs
\\tfl
JUL-DEC
j i 1
Figure A-ll.
Monthly Averages for Salinity versus Depth
Marsden Square 116, Subsquare 82
Source: Warsh, 1975b.
A-22
-------
0
10
20
30
40
50
60
70
80
90
j.100
E 20°
Q.
Q 300
400
500
600
700
800
900
1000
2COO'
3000
SALINITY(°/oo)
32 33 34 35
36
33
SALINITY (°/00)
34 35
. w
MAYA\ \\ \
T
JUIM
MAR \V-T JAN
K\\
JAN - JUIM
Figure A-12. Monthly Averages for Salinity versus Depth
in Marsden Square 116, Subsquare 91
Source: Warsh, 1975b.
A-23
-------
GEOLOGICAL CHARACTERISTICS
The 106-Mile Site covers portions of the Continental Slope and Continental
Rise (Figure A-13). Water depths within the site range from 1,440 m in the
northwest corner to approximately 2,750 m in the southeast corner. The
Continental Slope portion of the site experiences a 4% grade, whereas the
grade of the Continental Rise portion is 1% (Bisagni, 1977a).
Four submarine canyons incise the Continental Slope within the site: Mey,
Hendrickson, Toms, and Toms Middle Canyon. Numerous smaller canyons exist in
the Slope region west of the site. The massive Hudson Canyon is 32 nmi
(60 km) north of the site, and extends from the New York Bight Apex to the
edge of the Continental Slope.
The mid-Atlantic Continental Shelf is one of the best studied continental
margins in the world, yet few studies have concentrated on the Continental
Slope. Emery and Uchupi (1972) suggest that marine geologists may have found
the numerous submarine canyons which incise the Slope to be geologically more
interesting than the more featureless region of the Slope.
Based upon interpretation of bottom photographs, seismic reflection
profiling, and data from the Deep Sea Drilling Project, Heezen (1975)
concluded that the upper Continental Rise is a tranquil area of nearly uniform
sedimentation that has existed for at least 1,000 years. The sediments are
characterized as a wedge of Mesozoic and Cenozoic sediment, which is up to
13 km thick near the Baltimore Canyon (Shenton, 1976).
A narrow transition zone of recent high erosion separates the upper Conti-
nental Rise from the lower Slope area. Sediment cores and seismic reflection
profiling in this area of the Continental Slope have shown that recent
sediments along with Pliocene or Holocene deposits were totally absent in the
area, apparently removed by current action since 1975 (Bisagni, 1977a).
Before that time, photographs showed that the bottom was covered by a soft
sediment of hemipelagic ooze and that significant currents were absent
(Heezen, 1975).
A-24
-------
72*50' W
39°30' N
38-30' N
72'00' W
39830' N
38°30' N
72°50' W
72°00' W
Figure A-13.
Bathymetry in the Vicinity of the 106-Mile Site
Source: Bisagni, 1977a.
A-25
-------
The lower Slope and Rise, which lies below 3,500 m depth, exhibits numerous
current-induced bedforms, formed by the southwestward-flowing Western Atlantic
Undercurrent (Heezen, 1975). The lower Slope and Rise may be thick prisms of
deep sea turbidites, clays, and slump deposits (Drake et al., 1968).
The recent sediments deposited on the Continental Slope and Rise are
primarily silt and clay (Milliman, 1973). Most of the sand in this region is
biogenic in origin, although patches of terrigenous sand occur in the axes of
some canyons (Hathaway, 1971; Keller et al., 1973). Sediments on the Slope
tend to be olive or brown in color (Milliman, 1973), which may be a function
of the high oxygen content of the Slope water and iron staining. Calcium
carbonate is a major component of Slope sediments, contributing as much as 75%
of the sediments in some areas. The carbonate grains are chiefly the tests of
planktonic foraminifera, benthonic foraminifera, and echinoid plates.
Coccoliths are often common components, but are seldom abundant (Milliman,
1973).
Heavy minerals in the sand-sized fraction average less than 2% in Slope
sediments. Amphiboles represent 31% to 45% of the heavy mineral fraction;
epidote represents less than 10% (Milliman, 1973). The light minerals are
mostly quartz, feldspar and glauconite. The clay minerals, which are more
prevalent on the Slope than across the Shelf, are chiefly illite and
montmorillonite (Emery and Uchupi, 1972). Milliman (1973) reports illite
fractions which range from 30 to 40%, chlorite fractions of 10% to 20% and
kaolinite fractions ranging from 20% to 30%.
CHEMICAL CHARACTERISTICS
WATER COLUMN CHEMISTRY
DISSOLVED OXYGEN
Oxygen is a fundamental requirement for aerobic marine life. It is
produced by photosynthesis in the photic (i.e., sunlit) zone, usually less
than 100 m in depth, and is used by animals in respiration and in the
decomposition of organic matter.
A-26
-------
The contrasting processes of photosynthesis and respiration are the main
causes of in situ changes in the concentrations of dissolved oxygen. In the
photic zone, photosynthesis by phytoplankton may predominate and lead to the
liberation of oxygen. Under optimal conditions, development of an "oxygen
maximum layer" in the surface waters will occur. Below this layer,
respiration and decomposition predominate and oxygen values diminish steadily
with depth. Another layer, where dissolved oxygen concentrations are at a
minimum, will form at depths varying between 150 and 1,000 m.
The ability of a water parcel to maintain certain minimal concentrations of
oxygen determines the survival of life in that parcel. The saturation level
of dissolved oxygen with respect to the atmospheric oxygen level in seawater
is dependent on the temperature, salinity, and barometric pressure of the wet
atmosphere at sea surface. The oxygen level at great ocean depths, where no
atmospheric phase exists, is determined by the temperature, salinity, and
barometric pressure before that water left the sea surface. Subsequent mixing
among different water masses and types, and in situ biochemical alteration
from phytosynthesis and respiration, modify the oxygen content of the water
under study.
At all depths, seawater is saturated with atmospheric gases with the
exception of those, such as oxygen, which are involved in life processes.
Oxygen concentrations below the saturation level suggest that biochemical
oxidation, including respiration and bacterial activity, is removing oxygen
faster than it is being replenished by mixing or other processes.
Dissolved oxygen concentrations are generally higher during the winter
months because of increased mixing in the water column. Increased plankton
populations during the spring result in a high fallout of dead organisms;
consequently, a higher oxygen demand exists in deeper water, due to microbial
decomposition of organic matter. As a result, bottom waters tend to have
lower dissolved oxygen levels at this time of year.
Warsh (1975b) summarized historical data for the water column within and
adjacent to the 106-Mile Site. Within the site, monthly average oxygen values
A-27
-------
at the surface range from 4.9 ml/liter in August to 7.5 ml/liter in April
(Figure A-14). The oxygen minimum zone is between 200 and 300 m depth where
the oxygen values range between 3.0 ml/liter in February and 3.5 ml/liter in
September. The historical data for the site show the development of a
subsurface oxygen maximum zone during several months. Values varied from
approximately 7.0 ml/liter at 30 m depth during August to 8.2 ml/liter at 10 m
depth during February.
Monthly average oxygen values for surface waters adjacent to the 106-Mile
Site range from 4.6 ml/liter in October to 7.5 ml/liter in March. The oxygen
minimum zone in waters adjacent to the site occurs between 200 and 300 m
depth. Oxygen values in this zone show approximately the same range as the
waters within the 106-Mile Site.
Oi
10
20
30!
40
50
60
70
80
90
1 100
| 200
S300
400
500
600
700
800
900
1000,
2000'
3000
OXYGEN (ml/1)
3 4 56 7 8
OXYGEN (ml/1)
4 5 6' 7
. FEB-MAY
10
20
30
40
50
60
70
: 200
_ 90
.§ 100.
I
S300
400
500
600
700
800
900
1000
2000
3000
Figure A-14. Monthly Averages of Oxygen Concentration versus
Depth at the 106-Mile Site
Source: Warsh, 1975b.
A-28
-------
Baseline investigation of the 106-Mile Site during May 1974 (NOAA, 1975)
found concentrations of dissolved oxygen at the surface ranging from
4.4 ml/liter to 6.9 ml/liter. The highest values occurred in areas over the
Continental Shelf and generally decreased seaward. An oxygen minimum layer
occurred between 200 and 400 m depth. Most of the values recorded for this
layer were about 3.2 ml/liter. The lowest value recorded for the minimum
layer was 3.1 ml/liter at approximately 300 m depth. At depths below the
oxygen minimum layer, values increased to slightly above 6 ml/liter. From
1,200 m depth to the bottom, the amount of dissolved oxygen fluctuated between
6.2 and 5.3 ml/liter. Hausknecht and Rester (1976a) reported oxygen values at
the 106-Mile Site taken during July 1976. Surface values averaged
5.3 ml/liter whereas concentrations at the oxygen minimum layer (300 m depth)
averaged approximately 3.5 ml/liter.
pH AND ALKALINITY
The expression pH is used conventionally to measure the acidity or
H+
alkalinity of an aqueous solution. The scientific definition is -log A , the
negative logarithm of hydrogen ion activity. A neutral solution normally has
a pH value of 7 at 25°C, while acidic solutions are lower than 7, and alkaline
solutions are higher than 7. The advantage of the pH scale is that its range
is only from 0 to 14, from 1-molar HC1 to 1-molar NaOH, where hydrogen
-14
activity varies from 1 to 10 . The pH scale can be smaller than 0 and
greater than 14 when HC1 concentration exceeds 1 mole (Du Font-Edge Moor
wastes contain 2- to 4-molar HC1), and NaOH exceeds a 1-mole concentration,
respectively.
Surface seawater pH is generally 8.2 +_ 0.4, thus slightly alkaline. This
narrow range is maintained by the global and geochemical silicate and
carbonate mineral equilibria. At sea surface, the air-sea exchange of carbon
dioxide tends to restore any perturbation of pH value back to approximately
8.2.
Hausknecht and Kester (1976a, 1976b) reported pH values for samples taken
during the summer at the 106-Mile Site. At the surface, the average pH was
7.9, while below 300 m depth, the'pH decreased to an average of 7.6.
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The alkalinity of seawater is defined as the sum of anions of weak acids
present in seawater plus hydroxide ion (OH ) minus hydrogen ion (H )
concentrations. Alkalinity is important for fish and other aquatic life
because it buffers pH changes which occur in nature, induced by photosynthesis
and respiration, or by ocean dumping of acid and alkaline solutions. Carbonic
and boric acids are two major weak acids in seawater near the sea surface.
Alkalinity is increased by the dissolution of carbonate minerals, such as
limestones, and decreased by the precipitation of carbonate minerals, such as
oolite deposition over the Bahama Bank. Most of the time, alkalinity of
seawater can be calculated by the empirical equation of alkalinity
(milliequivalent/kg = 0.061 x salinity (g/kg).
TRACE METALS
Trace metals are present in seawater in minute quantities. The signi-
ficance of a trace metal introduced by ocean disposal depends upon its
relationship to the biota; i.e., the concentration of the metal, the form in
which it exists, and how these two factors affect an organism. It is common
practice to use the term "heavy metal" and "light metal" in discussions of
trace metals. The terms originated from systems used to subclassify the known
3 . .
metals. Heavy metals have densities greater than 5 g/cm , i.e., 5 times the
density of water at 4"C. Metals with densities less than 5 are properly
classified light metals.
The heavy metals (e.g., vanadium, chromium, manganese, iron, and copper)
are usually incorporated into proteins, some of which serve as enzymes, or
biological catalysts. The light metals (e.g., sodium, maganesium, potassium,
and calcium) readily form ions in solution, and, in this form, help to
maintain the electrical neutrality of body fluids and cells and the proper
liquid volume of the blood and other fluid systems (Stoker and Segar, 1976).
Environmental persistence of some metals is a serious problem. As
elements, metals cannot be biologically or chemically degraded in nature,
unlike organic compounds. The toxicity of metal-containing compounds can be
altered by chemical reaction and/or complex formation with other compounds,
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but the undesirable metals are still present. In some cases, such reactions
produce more toxic forms of the metal. The stability of metals permits
transportation for considerable distances in the ocean.
One of the most serious results of metal persistence is the potential for
biomagnification of metal concentrations in food webs. Biomagnification of
metals occurs as small organisms containing metals in tissues are eaten by
larger organisms which in turn are eaten by still larger animals. As a result
of this process, the metals in the higher levels of the food web can reach
concentrations many tim s higher than those found in air or water. Thus,
biomagnification can cause some fish and shellfish to become health hazards
when used as food for human beings.
Metal pollution is complicated by the fact that some toxic metals are
needed in trace amounts by all plants and animals, thus a balance must be
reached between too little and too much of essential metals. However, in
seawater, insufficient amounts of these micronutrients are not normal
problems. Certain trace metals (e.g., arsenic, beryllium, cadmium, chromium,
copper, iron, lead, manganese, mercury, nickel, selenium, silver, vanadium,
and zinc) are important because of their potential toxicity and/or carcino-
genic properties. The chemical behavior and the toxicity of a metal in the
aquatic environment depends upon the form (complex, absorbed, or ionized) in
which it exists, and whether the metal is present in solution or in colloidal
or particulate phases. For example, the toxicity of copper to some marine
organisms is controlled by the formation of copper-organic complexes.
Mercury, which is toxic in sufficient amounts of any of its forms (except the
metallic), is especially toxic when methylated by organisms.
Hausknecht (1977) reported metal concentrations from studies conducted at
the 106-Mile Site during May 1974 and February and August 1976. The average
metal concentrations for all samples taken during these cruises are presented
in Table A-8. For comparison, average metal concentrations for the New York
Bight Apex and Northwest Atlantic Ocean are included in the table.
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TABLE A-8
AVERAGE CONCENTRATIONS OF FIVE TRACE METALS IN WATERS
OF THE NORTHEAST ATLANTIC OCEAN
AREA
106-Mile Site:
May 1974*
February 1976*
August 1976*
New York Bight Apex:
Summer t
Fall**
Open Oceantt
Continental Slopett
Continental Shelf tt
CADMIUM
(/*g/l)
0.30
0.46
0.035
3.1
0.1
0.044
0.034
0.036
COPPER
(Mg/D
0.70
0.40
0.23
80.0
5.6
0.39
0.24
0.56
LEAD
(|*g/l)
3.10
0.70
0.07
140.0
3.0
-
-
-
MERCURY
(|ig/l)
0.63
0.17
0.008
0.008
0.041
0.122
ZINC
(fig/D
6.8
6.9
11.0
19.0
1.07
0.72
1.11
Sources: * Hausknecht (1977)
t Klein et al. (1974)
** Alexander et al. (1974)
tt Bewers et al. (1975)
The cadmium concentrations in samples taken during May 1974 and February,
1976 cruises were comparable; hwever, these cadmium values were an order of
magnitude greater than those found during the August 1976 cruise and the
cadmium values listed for the Shelf, Slope, and open waters of the Northwest
Atlantic. In comparison to the New York Bight Apex values for summer, the
106-Mile Site values for cadmium were as much as two orders of magnitude
lower.
The copper values for the three studies at the disposal site varied little,
and all fell within the same order of magnitude. These values were comparable
to the values found by Bewers et al. (1975) for the Northwest Atlantic. The
106-Mile Site copper concentrations are one or two orders of magnitude less
than those given for the New York Bight Apex.
Lead concentrations at the site showed a range of as much as two orders of
magnitude for the 1974 and 1976 values. As with cadmium and copper, lead
values at the site were much lower than the concentrations found in the New
York Bight Apex.
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Mercury concentrations at the site varied slightly between 1974 and 1976
and were significantly higher than mercury values listed for the Slope and
open waters of the Northwest Atlantic. Concentrations of the metal were,
however, comparable to those reported for the Continental Shelf.
Zinc concentrations for the 106-Mile Site showed remarkable consistency
between 1974 and 1976. The values were higher than the Northwest Atlantic
values but an order of magnitude less than zinc concentrations in the New York
Bight Apex.
After undertaking an analytical program to produce highly reliable metal
analyses of seawater samples collected from the site, Kester et al. (1978)
concluded that the natural levels of cadmium, copper, and lead at the site are
comparable to other oceanic regions. Earlier samples were believed to be
contaminated and thus yielded high concentrations of these metals.
NUTRIENTS
In addition to the conservative elements (not involved in biological
processes; e.g., sodium, chlorine, bromine, strontium, and fluorine) and the
trace metals, nutrients in seawater are important for the growth of marine
phytoplankton. The major nutrients are inorganic phosphate, nitrate, nitrite,
ammonium, and hydrated silicate. Nutrients are consumed by phytoplankton only
in the upper layers of the ocean where light conditions permit photosynthesis
and growth. Inorganic phosphorus and nitrogen are generated primarily by
bacterial decomposition of organic debris and soluble organics. Silicate is
generated by the dissolution of the siliceous shells of diatoms, radiolaria,
and silicoflagellates.
Nitrogen exists in the sea in combination with other elements: in ammonia
(NH-), as urea [(NH^^CO], and as oxides of nitrogen in the nitrite ion (N02 )
and nitrate ion (NO, ). Nitrogen enters into the composition of all living
things and is one of the nutrients used by plants to form the complex protein
A-33
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molecules from which animals derive nitrogen. The complex nitrogenous
compounds found in plants and animals are decomposed by bacteria into
chemically simpler compounds after the organism dies.
Phosphorus has a biologically activated cycle involving alternation of
organic and inorganic phases. This cycle is similar to that of nitrogen,
except that only one inorganic form, phosphate, is known to occur. Phosphorus
can be found in organisms, particulate and dissolved organic compounds, and as
phosphate. Phosphate is probably the only form used by plants.
The nitrogen-phosphorus ratio near the sea surface varies greatly.
Nitrogen and phosphorus are extracted from seawater by phytoplankton, but
phosphorus is regenerated more rapidly than nitrogen, thus causing nitrogen to
be the nutrient which limits phytoplankton growth. A phytoplankton population
will cease to grow when nitrogen is depleted. However, in coastal waters,
land run-off and sewage effluents may provide excess nitrogen to the system.
When this situation occurs, phosphate becomes the growth-limiting factor.
The phosphate and nitrate contents of mid-Atlantic Continental Shelf and
Slope waters vary seasonally. Shelf and Slope waters are vertically mixed
during the winter. Consequently, phosphate and nitrate concentrations are
fairly uniform from the surface to the bottom. In spring, mixing is reduced
and the water column stratifies. Phosphate and nitrate concentrations
decrease in the surface layers due to increased biological activity and lack
of replenishment by mixing with nutrient-rich deeper layers. By the end of
summer, nitrate in the upper waters is depleted and phosphate is present in
low concentrations. Vertical mixing of the water column begins in the fall
and nutrients are transferred from subsurface to the surface layer (Kester and
Courant, 1973).
Peterson (1975) reported vertical profiles for phosphate, nitrate,
silicate, and ammonia, compiled for samples taken during May 1974 at the
106-Mile Site (Table A-9). Average concentrations of phosphate generally
increased with depth ranging from 0.1 mg/liter in the upper 15 m to
0.2 mg/liter at 500 m depth. Average nitrate concentrations increased with
A-34
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depth, ranging from 0.01 mg/liter in the upper 15 m to 1.22 mg/liter at 500 m
depth. Silicate was observed to follow the same profile as phosphate and
nitrate. Concentrations ranged from 0.09 mg/liter at the surface to 1.28
mg/liter at 500 m depth. Ammonia concentrations were quite uniform throughout
the water column, ranging only from 0.0071 mg/liter at the surface to 0.0068
mg/liter at 500 m depth.
TABLE A-9
AVERAGE CONCENTRATIONS OF NUTRIENTS AT VARIOUS DEPTHS
IN THE 106-MILE SITE
Depth
(meters)
Upper 15
100
500
Below 1,000
(mg/liter)
Phosphate
0.10
0.13
0.20
0.19
Nitrate
0.01
0.60
1.22
1.09
Silicate
0.09
0.39
1.28
1.28
Ammonia
0.0071
0.0066
0.0063
0.0070
Source: Adapted from Peterson, 1975.
ORGANIC COMPOUNDS
Organic compounds are numerous and diverse, with varying physical,
chemical, and toxological properties. Organics occur naturally in the marine
environment, resulting either from chemical/biological processes or oil seeps.
However, anthropogenic sources (e.g., oil spills, urban run-off, or disposal
operations) provide the major oceanic inputs. Field work and laboratory
experiments have demonstrated acutely lethal and chronic (sublethal) effects
of organics on marine organisms.
One of the .largest groups of organic compounds is the hydrocarbons, which
contain only the elements hydrogen and carbon. Tens of thousands of such
compounds are known to exist. They are found in all 3 physical states (gas,
liquid, solid) at room temperatures. The physical state characteristic of
each is related to the molecular structure, and particularly to the number of
carbon atoms making up the molecule. Generally, within this group, the
tendency to exist as a solid increases with increasing number of carbon atoms.
Hydrocarbons may be classified as "aliphatic" or "aromatic" on the bases of
A-35
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their molecular structures. An aromatic hydrocarbon contains, as a structural
unit, one or more 6-membered carbon rings. Aliphatic hydrocarbons lack this
characteristic ring structure.
Smith et al. (1977) reported levels of dissolved and particulate aliphatic
hydrocarbons in the waters of the outer mid-Atlantic Bight just northwest of
the 106-Mile Site. The mean concentration was highest during winter with a
value of 7.6 fig/1, whereas in summer, the mean hydrocarbon concentration was
at a low of 0.22 /ig/1. The mean concentration reported for spring was
0.53 jig/1.
Chlorinated hydrocarbons are basically composed of carbon-hydrogen
skeletons to which chlorine atoms are attached. The polychlorinated biphenyls
(PCB's) are one type of chlorinated hydrocarbon compounds and have properties
similar to chlorinated hydrocarbon pesticides. Theoretically, 210 different
PCB compounds can be formed by varying the number and position of the chlorine
constituents. Some of the compounds are more common than others. Commercial
mixtures, which generally contain many types of PCB's are usually in the form
of liquids or resins.
The PCB's are stable at high temperatures (up to 800°C), resistant to
acids, bases, and oxidation, and are only slightly soluble in water. These
properties make them quite adaptable to various uses, e.g., (1) heat transfer
fluids in industrial heat exchangers, (2) insulators in large capacitors and
transformers required by electrical power companies, (3) hydraulic fluids, and
(4) plasticizers in polymer films. PCB's have also been used as a constituent
of brake linings, paints, gasket sealers, adhesives, carbonless carbon paper,
and fluorescent lamp ballasts.
PCB's were first identified in 1881, and have been widely used since the
1930's. The first environmental contamination was found in 1966, when PCB
residues were identified in fish. It is now apparent that PCB's are
distributed throughout the environment.
Most PCB's are introduced into the environment accidentally. Available
evidence indicates that the physiological effects of the PCB's are similar to
A-36
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those of DDT. As with DDT, long-term chronic effects appear to create more of
a problem than acute toxicity. The PCB's appear to be more effective enzyme
inhibitors than DDT. It is now believed that some eggshell thinning
previously blamed upon DDT may be caused by PCB's or synergistic PCB-DDT
combinations.
Harvey et al. (1974) measured PCB's in North Atlantic waters over the
Continental Shelf and Slope off the northeastern United States. The data show
widespread distribution in the North Atlantic, with an average PCB concen-
trations of 35 parts per trillion in the surface waters and 10 parts per
trillion at 200 m depth. A wide range of concentrations (1 to 150 parts per
trillion) was found, with extreme concentrations occurring only several
kilometers apart. No apparent relationship between PCB concentrations and the
proximity to land was observed, and it was suggested that the high variation
may be due to localized slicks, rainfall, or ship discharge.
SEDIMENT CHEMISTRY
Most of the sediment data collected at the site are derived from
photographs and a few grab samples (Pearce et al., 1975). Sediments within
the disposal site are mainly sand and silt, with silt predominating. Heezen
(1977) reported that the Continental Slope around the 106-Mile Site may have a
transitory blanket of hemipelagic ooze which, dependent upon the strength of
the bottom current, is either deposited or swept away.
TRACE METALS
Trace metals are conservative elements in sediments. Distribution and
accumulation of metals over background levels in sediments may delineate the
benthic area affected by disposal of waste. Recommendations have been made to
use either the individual metal concentration, or the metal-to-metal
concentration ratios, to trace a particular type of waste and separate it from
other wastes disposed nearby. These techniques have been applied to nearshore
disposal sites.
A-37
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Pearce et al. (1975) noted that the heavy metal content of sediment samples
taken in the vicinity of the 106-Mile Site appeared to be elevated relative to
uncontaminated Shelf sediments. The stations at which these elevated levels
occurred are located near the Hudson Canyon, therefore the investigators
suggested that materials which had an elevated heavy metal content, and which
originated inshore, were tranported seaward via the Shelf valley and Canyon.
Greig and Wenzloff (1977) reported that heavy metal values, in deepwater
sediments collected in 1976 in and near the 106-Mile Site, were generally
similar (Table A-10) to those reported for collections made in 1974 (Pearce et
al., 1975). Greig and Pearce (1975) reported concentrations for cadmium,
chromium, copper, nickel, lead, and zinc in waters of the outer Continental
Shelf. Cadmium, chromium, and copper were rarely detectable in sediments;
nickel and zinc were usually measurable, but were present in very small
amounts relative to their abundance in Bight Apex sediments. Lead varied
somewhat, but was often undetectable. The values obtained were generally less
than those previously reported for sediments collected from the New York Bight
Apex (Carmody et al., 1973; Greig et al., 1974). The concentrations found by
Greig and Pearce were also somewhat less than those reported for stations near
the 106-Mile Site.
TABLE A-10
AVERAGE CONCENTRATIONS OF SIX TRACE METALS
IN THE TOP 4 CENTIMETERS OF SEDIMENTS
U&C6
May 1974
Pearce et al.
(1975)
February 1976
Greig & Wenzloff
(1977)
Metal (mg/kg dry weight)
Cadmium
_
1.4
Chromium
25.9
25.8
Copper
27.6
27.0
Nickel
25.2
31.5
Lead
28.7
13.2
Zinc
60.2
50.5
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Harris et al. (1977) analyzed sediment samples from the mid-Atlantic
Continental Shelf for barium, cadmium, chromium, copper, iron, nickel, lead,
vanadium, and zinc. It was found that concentrations of iron, zinc, nickel,
lead, total organic carbon, and the percent silt-clay generally increased
seaward across the Shelf. These increases correlated with a decrease in the
average particle size of sediment grains across the Shelf. Metal concen-
trations, percent silt-clay, and total organic carbon showed a general
consistency from season to season.
ORGANICS
Hydrocarbon (C,,+) concentrations, in and near t"he 106-Mile Site, were
found to be similar to those of Continental Shelf sediments from the Northern
and Southern Areas, which are assumed to be uncontaminated (Greig and
Wenzloff, 1977). The amounts (approximately 20 mg/kg) of C.,.+ hydrocarbons in
sediments from the area near the 106-Mile Site were much less than those found
in sediments at other disposal sites in relatively shallow coastal water,
viz., 6,530 mg/kg at the Dredged Material Site and 1,568 to 3,588 mg/kg at the
12-Mile Sewage Sludge Disposal Site in the New York Bight Apex.
Smith et al. (1977) reported levels of total aliphatic and aromatic
hydrocarbons in sediments of the mid-Atlantic Continental Shelf to be
generally less than 1 ug/g (1 ppm). The concentrations strongly correlated
with the amount of silt-clay in sediments, suggesting that, whether inputs are
general or localized, hydrocarbons accumulate primarily in locations where
fine-grained sediments are deposited.
BIOLOGICAL CHEMISTRY
General observations on trace metal concentrations in phytoplankton can be
made despite the lack of specific data. The uptake of contaminants and
associated incorporation into the phytoplankton may have no apparent effect
upon the organisms or primary production; however, as the phytoplankton are
consumed, the contaminants can be transferred to and concentrated in consumers
at the next higher trophic level (biomagnification). The end result of this
accumulation through the food web is that higher trophic levels (and
A-39
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eventually man) may exhibit concentrations of contaminants far in excess of
ambient levels in the environment. This is considered to be a far less
important problem in the deep ocean than in nearshore waters since the
dispersed distribution and wide-ranging horizontal migrations of the
epipelagic nekton tend to retard the accumulation of contaminants in oceanic
nekton populations (Pequegnat and Smith, 1977). Other existing evidence
suggests that, aside from mercury and cadmium, few, if any, of the trace
metals are irreversibly accumulated by nektonic species.
Windom et al. (1973a), reporting on zooplankton samples collected between
Cape Cod and Cape Hatteras, found nearshore samples to be higher in mercury
than offshore samples. Species composition of the samples varied consider-
ably, although a general copepod dominance was maintained. However, the high
mercury concentrations measured did not seem as strongly correlated with
species composition as with sampling distance off shore.
Windom et al. (1973b) provide information on the cadmium, copper, and zinc
content (expressed as ppm dry weight) of various organs in 35 species of fish
obtained from waters of the North Atlantic. Cadmium concentrations in liver
tissue were generally less than 1.7 ppm, although one sample contained 5 ppm
cadmium. Cadmium levels in other organs and whole fish were usually less than
1 ppm; however, some species had values as high as 2.6 ppm. Copper levels in.
the fish tissues sampled were, in most cases, less than 10 ppm. Zinc levels
were reported to be in the range of 10 to 80 ppm; however, a zinc level of
397 ppm was obtained for the bay anchovy (Anchoa mitchilli).
Pearce et al. (1975) reported that the levels of silver, cadmium, and
chromium did not vary greatly in most of the finfish and invertebrates
collected within and adjacent to the 106-Mile Site. The results did show,
however, that copper, zinc, and lead varied significantly, with lead showing
the greatest variation of all metals. Liver tissues from the deep-sea
slickhead (Alepocephalus agassizi) had the highest levels of silver, cadmium,
copper, and zinc. The values for these metals were several orders of magnitude
greater than the metal concentrations found in windowpane flounder
(Scopthalmus aquosus) taken from the sewage sludge and dredged material
disposal sites in the New York Bight Apex. The levels of the metals (as wet
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weight) in liver tissues from the slickhead were: cadmium 13.9 ppm, copper
28.6 pm, silver 1.2 ppm, and zinc 271.0 ppm. The copper concentrations in
other species of fish obtained were similar to the copper levels in fish
examined by Windom et al. (1973b).
Greig and Wenzloff (1977) found uniform metal concentrations in three
species of mid-water fish (Gonostoma elongatum, Hygophum hygomi, and
Monaconthus [=Stephanolepis] hispidus) during spring 1974, 1975, and 1976
studies near the 106-Mile Site; however, copper concentrations were highest in
fish taken in 1976. In Apex predators, such as sharks, cadmium concentrations
were generally less than 0.12 ppm in muscle tissue, but levels in the liver
were consistently higher, ranging from 0.28 to 7.2 ppm. Lancetfish, oilfish,
and dusky shark had similar cadmium concentrations.
Copper and manganese concentrations were low in the muscle of the sharks
and other fishes examined; levels were mostly below 1.5 ppm for copper and
below 0.5 ppm for manganese. With the exception of lancetfish, almost all
samples of fish muscle examined had concentrations of mercury which exceeded
the 0.5 ppm action level set by the Food and Drug Administration. Mercury
levels in lancetfish were most often below 9.23 ppm. Lead concentrations were
below the detection limit (about 0.6 to 0.8 ppm) of the method employed for
both muscles and livers of the fishes examined. Zinc concentrations in the
muscles of fishes examined were several orders of magnitude greater than the
cadmium, copper, manganese, and lead levels. Zinc levels ranged from 1.0 to
6.9 ppm and were about the same magnitude as those found in the muscle of
several finfish obtained from the New York Bight.
In another study, Greig et al. (1976) determined the concentration of nine
metals in four demersal fish species and three epipelagic fish species from
the outer Bight in water depths of 1,550 to 2,750 m. It was found that
mercury concentrations in deepwater fish muscle averaged three times higher
than muscle concentrations reported by Greig et al. (1975) from offshore
Continental Shelf finfish.
A-41
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BIOLOGICAL CHARACTERISTICS
The biota at the 106-Mile Site exhibit complex diurnal, seasonal, and
longer term cycles of species composition and abundance. Several factors
contribute to these cycles: the influence of various water masses, each with
its characteristic biota, the location of the site relative to the boreal
fauna found to the north and the temperate to subtropical fauna found to the
south, and the effects of unusual or non-periodic physical conditions.
The mid-Atlantic is biologically heterogeneous; this section, however,
discusses only the environmental aspects of the region which are directly
relevant to the specific conditions at the 106-Mile Site. The water column is
described first, then the benthic biota are characterized. For the benthos,
the discussion is confined to organisms characteristic of fine silt and clay
bottoms at abyssal depths. A discussion of the biota typical of other
sediment types and other depths in the mid-Atlantic is not pertinent to this
EIS.
PHYTOPLANKTON
Phytoplankton are free-floating algae which produce the organic matter upon
which the rest of the marine food chain is built. Phytoplankton consist of
autotrophic algae which are represented by six taxonomic groups:
Bacillariophyta, Pyrrophyta, Cyanophyta, Coccolithophorida, Chlorophyta, and
Euglenophyta. The algal cells are commonly found in combinations of single,
filamentous, or colonial units of varying size in the euphotic zone (upper
100 m) and require sunlight, nutrients, and certain conditions of temperature
and salinity in order to synthesize organic matter. The various combinations
of these factors in the euphotic zone dictate the floral characteristics of
the waters at any particular time or place.
Few phytoplankton investigations have been performed at the 106-Mile Site,
and the available data indicate summer as the only season in which sampling
was performed. Hulburt and Jones (1977) found the phytoplankton abundance at
the 106-Mile Site to vary with depth from 100 to 100,000 cells/liter, with the
phytoplankton much more abundant in the upper 20 m than at 25 to 50 m depth.
A-42
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Abundance was greatly reduced at greater depths. The dominant species of
phytoplankton was a group of unidentifiable naked cells. Phytoplankton
populations at the 106-Mile Site were found to be composed of a mixture of
coastal and oceanic species, due to the location in a transitional area
between coastal and oceanic waters and in the path of meandering Gulf Stream
eddies.
Data from Hopkins et al. (1973) indicate the summer chlorophyll values at
the 106-Mile Site are highest at or near the surface, decrease to very low
levels at 100 m depth, and then slowly rise to a second maximum (much smaller
than the first) at depths greater than 1,000 m. Steele and Yentsch (1960)
observed these chlorophyll concentrations at great depths and attributed these
higher concentrations to the sinking of phytoplankton until their density
equals that of the surrounding water. The subsurface accumulation of
chlorophyll occurs at depths where water density, inversely related to
temperature, is increasing most rapidly. This phenomenon becomes more
apparent as the summer progresses and is most distinct in Slope waters. This
midwater accumulation of chlorophyll disappears with the destruction of
stratification of the water column in fall.
More data exist on phytoplankton in mid-Atlantic Continental Shelf and
Slope waters than exist for the 106-Mile Site, The locations of the stations
from which phytoplankton samples have been taken are shown in Figure A-15.
The available information indicates that the phytoplankton population in the
mid-Atlantic is comprised mainly of diatoms during most of the year. Hulburt
(1963, 1966, 1970) described 33 abundant phytoplankton species, of which 27
were diatoms, 4 were dinoflagellates, and 2 were nannoflagellates. Hulburt
(1963, 1966, 1970) and Hulburt and Rodman (1963) found that Rhizosolena alata
dominates during summer, and Thalassionema nitzschioides, Skeletonema
costatum, Asterionella japonica, and Chaetoceros socialis dominate during
winter. Spring dominants include Chaetoceros spp. and Nitzschia seriata.
Thalassionema nitzschioides dominates in fall.
In several studies, phytoplankton densities ranged between 10 and 10
cells/liter, generally decreasing with distance from land (Hulburt, 1963,
1966, 1970). Major pulses in phytoplankton abundance were due to four neritic
A-43
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70°
60°
40°
t 'CAPE
HATTERAS
O
O RILEY (1939)
• HULBURT (1964)
A HULBURT AND
MACKENZIE (1971)
• YENTSCH (1958)
• KETCHUM, RYTHER,
YENTSCH AND
CORWIN (1958)
• HULBURT AND
RODMAN (1963)
• HULBURT (1963)
(1966)
(1970)
BERMUDA
40°
70°
60°
Figure A-15. Station Locations of Major Phytoplankton
Studies in the Northeastern Atlantic
Source: Chenoweth, 1976b
diatom species: Skeletonema costatum, Asterionella japonica, Chaetoceros
socialis, and Leptocylindrus danicus (Hulburt, 1963, 1966, 1970; Malone,
1977). Uniform distributions were exhibited by Rhizosolena alata in summer,
and Thalassionema nitzschioides in winter. The flagellates Chilomonas marina,
C. gracilis, Ceratium lineatum, Katodinium rotundaturn, Oxytoxum variabile, and
A-44
-------
Abundance was greatly reduced at greater depths. The dominant species of
phytoplankton was a group of unidentifiable naked cells. Phytoplankton
populations at the 106-Mile Site were found to be composed of a mixture of
coastal and oceanic species, due to the location in a transitional area
between coastal and oceanic waters and in the path of meandering Gulf Stream
eddies.
Data from Hopkins et al. (1973) indicate the summer chlorophyll values at
the 106-Mile Site are highest at or near the surface, decrease to very low
levels at 100 m depth, and then slowly rise to a second maximum (much smaller
than the first) at depths greater than 1,000 m. Steele and Yentsch (1960)
observed these chlorophyll concentrations at great depths and attributed these
higher concentrations to the sinking of phytoplankton until their density
equals that of the surrounding water. The subsurface accumulation of
chlorophyll occurs at depths where water density, inversely related to
temperature, is increasing most rapidly. This phenomenon becomes more
apparent as the summer progresses and is most distinct in Slope waters. This
midwater accumulation of chlorophyll disappears with the destruction of
stratification of the water column in fall.
More data exist on phytoplankton in mid-Atlantic Continental Shelf and
Slope waters than exist for the 106-Mile Site. The locations of the stations
from which phytoplankton samples have been taken are shown in Figure A-15.
The available information indicates that the phytoplankton population in the
mid-Atlantic is comprised mainly of diatoms during most of the year. Hulburt
(1963, 1966, 1970) described 33 abundant phytoplankton species, of which 27
were diatoms, 4 were dinoflagellates, and 2 were nannoflagellates. Hulburt
(1963, 1966, 1970) and Hulburt and Rodman (1963) found that Rhizosolena alata
dominates during summer, and Thalassionema nitzschioides, Skeletonema
costatum, Asterionella japonica, and Chaetoceros socialis dominate during
winter. Spring dominants include Chaetoceros spp. and Nitzschia seriata.
Thalassionema nitzschioides dominates in fall.
In several studies, phytoplankton densities ranged between 10 and 10
cells/liter, generally decreasing with distance from land (Hulburt, 1963,
1966, 1970). Major pulses in phytoplankton abundance were due to four neritic
A-43
-------
70*
60'
40°
, CAPE
HATTERAS
O
O RILEY (1939)
• HULBURT (1964)
A HULBURT AND
MACKENZIE (1971)
• YENTSCH (1958)
• KETCHUM, RYTHER,
YENTSCH AND
CORWIN (1958)
• HULBURT AND
RODMAN (1963)
• HULBURT (1963)
(1966)
(1970)
BERMUDA
40°
70°
60°
Figure A-15. Station Locations of Major Phytoplankton
Studies in the Northeastern Atlantic
Source: Chenoweth, 1976b
diatom species: Skeletonema costatum, Asterionella japonica, Chaetoceros
socialis, and Leptocylindrus danicus (Hulburt, 1963, 1966, 1970; Malone,
1977). Uniform distributions were exhibited by Rhizosolena alata in summer,
and Thalassionema nitzschioides in winter. The flagellates Chilomonas marina,
C. gracilis, Ceratium lineatum, Katodinium rotundatum, Oxytoxum variabile, and
A-44
-------
Prorocentrum micans were locally abundant, but rarely dominant during summer.
Maximum cell densities were observed in December, and minimum densities in
July (Malone, 1977). Major changes in species composition occur inshore to
offshore. Dominant coastal species are primarily chain-forming centric
diatoms (Smayda, 1973), which require relatively high concentrations of
nutrients to sustain high bloom populations and are subject to wide seasonal
variations in abundance and diversity. Of secondary importance in coastal
waters are the dinoflagellates and other flagellated groups. In contrast,
oceanic waters under some influence of the Gulf Stream carry a phytoplankton
community characterized by dominance of coccolithophorids, diatoms,
dinoflagellates, and other mixed flagellates (Hulburt et al., 1960; Hulburt,
1963), all of which require somewhat lower nutrients and are subject to
reduced or dampened seasonal variations in abundance.
Riley (1939) showed the vertical distribution of phytoplankton from a Slope
Water station adjacent to the Continental Shelf and a station near the outer
boundary (Figure A-16). The inner station is characteristic of Shelf Waters
having higher surface abundance (2.5 ug/liter chlorophyll £) with the
phytoplankton disappearing at about 100 m depth. The outer Slope station
has relatively fewer surface phytoplankton (0.9 ug/liter chlorophyll a) but
cells are found at a greater depth (200 m). This illustrates the transition,
in terms of vertical abundance, between coastal and open ocean characteristics
within the Slope Water (Chenoweth, 1976b). Mid-Atlantic Shelf Waters are
well-mixed during winter and strongly stratified during summer. This sharp
seasonal distinction is reflected in the seasonal changes in phytoplankton
abundance. During summer, diversity is high, while at other times, when
growth conditions are more favorable, diversity is lowered. In Slope Waters,
the seasonal cycle is characterized by two equally intense pulses of
chlorophyll - the spring and fall blooms (Yentsch, 1977). In Shelf Waters,
the fall bloom is the most intense feature of the seasonal cycle. Chlorophyll
concentrations vary regionally and seasonally from less than 0.5 mg/liter to
about 6 mg/liter (Smayda, 1973). The seasonal variations in mean chlorophyll
content for the inshore (less than 50 m depth) and offshore (greater than
1,000 m depth) stations are given in Figure A-17. The annual range in primary
production (Figure A-18) does not differ appreciably between inshore
A-45
-------
Chlorophyll a in /xg/l
0 0.3 0.6 0.9 1.2 1.5 1.8 2.1 2.4 2.7
S 100
«•
0)
e
g- 200
Q
300
Station 3532 (200 Km NNE of DWD-106)
Station 3528 (200 Km E of DWD-106)
Figure A-16. Vertical Distribution of Chlorophyll
Source: Riley, 1939
3.0
2.0
1.0
Q
AVERAGE CHLOROPHYLL a /ug/l
.
^-INSHORE
•
-
:. •
f '
'.
f *
r
^OFFSHORE
in
W£.
SEP DEC FEB MAR APR JUL
1956 1956 1957 1957 1957 1957
Figure A-17. Summary of the Average Chlorophyll £ Concentrations at Inshore
(less than 50 m depth) and Offshore (greater than 1,000 m depth)
Sites in the Mid-Atlantic Bight
Sources: Ryther and Yentsch, 1958; Yentsch, 1963
A-46
-------
g CARBON/2/DAY
1.0
0.5
0
1.0
0.5
0
1.0
0.5
0
INSHi
<50
INTER
' 100-
ORE
M
MED
•200
IATE
M
OFFSHORE
" >1000 M
771
SEP DEC FEB MAR APR JUL
Figure A-18. Summary of Mean Daily Primary Production per Square Meter
of Sea Surface at Inshore (less than 50 m depth),
Intermediate (100 to 200 m depth), and Offshore (greater
than 1,000 m depth) Sites in the Mid-Atlantic Bight
Source: Ryther and Yentsch, 1958; Yentsch, 1963
2 2
(0.20 to 0.85 g C/m /day) and offshore stations (0.10 to 1.10 g C/m /day)
(Ryther and Yentsch, 1958). However, the total annual production differs over
2
the Shelf and Slope, with an annual production of 160 g C/m at the inshore
2
stations (less than 50 m ) decreasing progressively seaward to 135 g C/m at
2
the intermediate locations (100 to 200 m depth), and 100 g C/m at the
offshore stations (greater than 1,000 m depth).
Ketchum et al. (1958a) indicated that the nutrient-impoverished offshore
areas (Slope Water) result in physiological differences between inshore and
offshore phytoplankton. Results of their light and dark bottle experiments
show differences in the ratio of net to gross photosynthesis; high ratios in
September and February indicated healthy, growing populations, whereas lower
ratios in December and March indicated less healthy populations. Geograph-
A-47
-------
ically, the low ratio of offshore populations indicated poorer physiological
conditons. Ketchum et al. (1958a) suggested that this variation of net gross
photosynthesis ratios may be the result of nutrient deficiencies, particularly
in the offshore waters.
The critical depth, the depth to which plants can be mixed and at which the
total photosynthesis for the water column is equal to total respiration (of
primary producers), accounts for the low total annual production in the
offshore waters. Although compensation depth and the critical depth for
mid-Atlantic waters are not precisely known, Yentsch (1977) estimates the
depths to exist between 25 and 40 m depth and at 150 m depth, respectively.
If this estimate is accurate, critical depths are not encountered on the
Shelf, since the average water depth is about 50 m. Beginning in fall,
extensive vertical mixing occurs with the cooling of surface waters and an
increase in wind velocity. Since Shelf Waters are mixed to the bottom during
fall and winter, the average plant cell within the water column receives
adequate light for production. In addition, the plants have access to the
nutrients dissolved within the entire water column, and, since production is
limited by light only, production can proceed at a moderately high level.
Concentrations of chlorophyll decrease during fall and winter, moving from
the Shelf to the Slope (Yentsch, 1977). As winter conditions intensify, Slope
chlorophyll concentrations become much lower than Shelf Water concentrations.
This is due to Slope Waters which are deep enough for critical depth
conditions to occur, since these waters are mixed to a depth of 200 m or more.
Therefore, although daily photosynthesis may equal or exceed that of Shelf
Waters (Ryther and Yentsch, 1958), the average plant cell within the Slope
Water column does not receive sufficient light to grow, and production
proceeds at a low level.
In the spring, vertical mixing is impaired first in shallow waters and then
progessively seaward into deeper waters (Yentsch, 1977). Following the
development of the thermocline, there is a brief period of high production,
since cells above the thermocline are now exposed to much greater radiation.
Therefore, the spring bloom begins, and then is impaired, first on the Shelf
and, later, progressively seaward to the Slope. The spring bloom is of
A-48
-------
greater magnitude in Slope Waters than in Shelf Waters, since the nutrients
have not been depleted by growth during the winter. Oligotrophic conditions
prevail in Shelf and Slope Waters during the summer until the cooling and
mixing processes of fall destroy the thermocline. The fall bloom occurs
during the transition from a stratified to a mixed water column.
ZOOPLANKTON
Zooplankton are the passively swimming animals of the water column and
contain members of nearly every phylum. Zooplankton represent the second
trophic level of the food chain, since the group is dominated by herbivorous
Crustacea (copepods, euphausiids, amphipods, and decapods) which graze on the
phytoplankton. Zooplankton studies performed at the 106-Mile Site (Austin,
1975; Sherman et al., 1977; Harbison et al., 1977) have confirmed the variable
and transient nature of water masses in the area of the site. The composition
of the zooplankton population was found to be the result of mixing of the
Shelf, Slope, and Gulf Stream water masses. Even within areas for which the
water mass could be identified, Sherman et al. (1977) could not differentiate
species characteristic for the area. However, the contour of diversity
indices was such that a differentiation could be made between Shelf and Slope
Waters (Chenoweth, 1976c). Copepod populations in Shelf Waters were dominated
by boreal assemblages characterized by high abundance and few species, while
the Slope Waters contained a mixture of subtropical and boreal assemblages
which resulted in lower abundance of individuals and a greater number of
species.
The seasonal zooplankton biomass range was 7.7 to 1,780 ml/1,000 m in
3
summer and 5.5 to 550 ml/1,000 m in winter. The displacement volumes are
comparable with the literature values for Shelf and Slope Waters. The
dominant zooplankton species found at or near the 106-Mile Site during various
seasons of the year are listed in Table A-ll. The most common copepod genera
are Centropages, Calanus, Oithona, Euaugaptilus, Rhincalanus, and Pleuromamma.
Centropages and Calanus predominate in the Shelf and also in areas where Shelf
Water intrusions occur in the Slope Water. Calanus is least abundant in the
offshore areas where water column stability suggests an oceanic origin.
A-49
-------
TABLE A-11
DOMINANT ZOOPLANKTON SPECIES IN THE VICINITY OF THE 106-MILE SITE
(NUMBER OF SAMPLES IN WHICH THE SPECIES COMPRISED 50% OR MORE
OF THE INDIVIDUALS OF THAT GROUP/NUMBER OF STATIONS SAMPLED)
Source: Austin, 1975.
GROUP
Cope pods
Euphausiids
Chaetognaths
Pteropods
SPECIES
Centropages spp.
C. typicus
Clausocalanus arcuicornis
Oithona similis
0. spinirostris
Pleuromamma borealis
P. gracilis
Pseudocalanus minutus
Rhincalanus cornutus
Temora longicornis
Euphausia americana
Meganyctiphanes norvegica
Nyctiphane couchii
Stylocheiron elongatum
Thysanoessa gregaria
Sagitta enflata
S. serratodentata
S. spp.
Limacina helicina
L. retroversa
L. trochiformis
L. sp. (Juveniles)
Summer
1972
3/18
2/18
4/18
5/18
1/18
1/16
4/16
2/16
1/16
Winter
1973
4/16
5/16
1/17
4/17
4/17
Spring
1974
3/22
1/22
1/22
2/21
7/21
4/21
1/21
Winter
1976
2/22
1/22
10/22
1/22
2/21
2/21
• 3/21
3/21
Mixing of waters has been demonstrated by the presence of Gulf Stream Water in
the center of the disposal site study area, demonstrated by the abundance of
Rhincalanus, Euaugaptilus, Oithona, and Pleuromamma. A copepod common to deep
waters of the northwestern Atlantic, Euchirella rostrata, was found at all the
stations.
A-50
-------
The chaetognaths are dominated by Sagitta species and are most abundant
over the Shelf (greater then 23/m ) and least abundant beyond the Shelf break
(less than 10/m ). The euphausiids found at the 106-Mile Site are a mixture
of boreal-arctic and subtropical species which were dominated by Nyctiphanes
couchii, a cold-water form. Warm water species of the Euphausia and
Stylocheiron genera were also dominant. Pteropods were dominated by species
of Limacina.
Neuston organisms associated with the air-sea interface were sampled at the
disposal site 'during various seasons. The results are summarized in Table
A-12.
The zooplankton from Cape Cod to Hatteras have been studied more or less
continuously for the past 50 years; the stations studied are shown in Figure
A-19. However, results of many of these studies are not comparable due to the
use of different techniques for sampling and the varied ways of expressing
such parameters as abundance and biomass. Jeffries and Johnson (1973) point
out that most of the studies were, at best, of only a few years' duration.
Therefore, since few of the studies overlapped, the literature is sparse. The
data clearly show, however, that fluctuations occur not only in the total mass
of zooplankton, but in the abundance of some of the more common species.
The most striking feature of the mid-Atlantic zooplankton is the near-
complete dominance of calanoid copepods, both numerically and volumetrically
(Grice and Hart, 1962; Falk et al., 1974). Copepods also tend to show greater
diversity than any of the other zooplankton groups (Falk et al., 1974). Nine
species of copepods have been found to dominate the zooplankton at various
times, viz., Centropages typicus, Metridia lucens, Paracalanus parvus,
Pseudocalanus minutus, Oithona similis, Acartia tonsa, Temora longicornis,
Clausocalanus furcatus, and Calanus finmarchicus. In addition, the ctenophore
Pleurobrachia pileus and the pelagic tunicate Salpa fusiformis occasionally
dominate.
A-51
-------
TABLE A-12
DOMINANT NEUSTON SPECIES IN THE VICINITY OF THE 106-MILE SITE
(NUMBER OF SAMPLES IN WHICH THE SPECIES COMPRISED 50% OR MORE
OF THE INDIVIDUALS OF THAT GROUP/NUMBER OF STATIONS SAMPLED).
Source: Austin, 1975.
GROUP
Cope pods
Euphausiids
Chaetognaths
Pteropods
SPECIES
Anotnalocera patersoni
Calanus finmarchicus
Candacia armata
Centropages typicus
Clausocalanus arcuicornis
Labidocera acutifrons
Metridia lucens
Oithona similis
Pleuromamma gracilis
P. robusta
Rhincalanus nasutus
Eukrohnia hamata
Euphausia brevis
E. krohnii
]L SPP-
Meganyctiphanes norvegica
Nematoscelis megalops
Nyctiphanes couchii
Stylocheiron robustum
Sagitta enflata
S. serratodentata
S_._ spp.
Cavolina uncinata
Creseis virgula conica
Limacina helicina
L. retroversa
L_._ sp. (Juveniles)
Summer
1972
3/18
1/18
5/18
1/18
4/18
1/13
7/13
1/13
1/13
1/13
Winter
1973
3/15
3/15
1/15
1/15
2/15
1/15
1/15
1/15
1/15
1/15
2/15
1/15
4/15
Spring
1974
4/12
5/12
1/12
1/12
Winter
1976
1/18
1/18
12/18
1/18
1/14
1/14
2/14
2/14
3/14
A-52
-------
70°
60"
40°
NEW YORK s.jy*
O CLARK (1940)
• CRICE & HART (1962)
• CIFELLI (1962, 1965)
— ST. JOHN (1958)
A BOWMAN (1971)
• WATERMAN (1939) .
A LEAVITT (1935, 1938)
BERMUDA
40°
70°
60°
Figure A-19. Station Locations of Major Zooplankton Studies in the
Northeastern Atlantic
Source: Chenoweth, 1976c.
The following information on the less abundant members of the zooplankton
was reported by Chenoweth (1976c):
Chaetognaths were the second most abundant numerically and
volumetrically in Grice and Hart's (1962) transect study. In
the four regions studied (shelf, slope, Gulf Stream, Sargasso
Sea), chaetognath concentrations were highest in the shelf
waters and lowest in the slope waters. The twelve species of
A-53
-------
chaetognaths found in the slope water were of three
distributional types: shelf species, Gulf Stream-Sargasso
Sea species, and endemic slope water species. Sagitta
elegans was the most abundant form in both the slope and
shelf water. The two species endemic to the slope water
(Sagitta maxima and Eukrohnia hamata) were found at a number
of stations, mostly in March. They were cold-water forms
that have been reported at a number of cold, (approximately
7.4°C) deepwater slope areas along the East Coast. Grice and
Hart (1962) concluded that these species were indicative of
cold waters in general and slope waters in particular.
The foraminifera are more closely associated with the
hydrographic characteristics of water masses than any other
zooplankton group and therefore, are often used as indicators
of water mass mixing. The faunal composition of foraminifera
included twenty recognizable species. The shelf and inner
slope was characteristically temperate throughout the year
and was dominated by species of Globigerina. Important
species were Globigerina bulloides, G^_ pachyderma incompta,
G^ inflata, and G_^ aff. quinqueloba. Towards the Gulf
Stream, the temperate fauna was gradually replaced by a
diverse southern group dominated by Globigerinoides ruber, G_._
triloba, Globigerinella aequilateralis, Globorotalia
truncatuli, and Pulleniatina obliquiloculata. The slope
water yielded the highest abundance of foraminifera all year
with the seasonal peak in the fall and the spring. The
poorest concentration was found in the summer.
Euphausiids were not an important part of the total
zooplankton collection of Grice and Hart, ranking fifth in
mean displacement volume. However, they were a relatively
important component in the slope waters (8.3 percent of the
zooplankton volume with an average numerical abundance of
2.2/m ). A succession of species indicated seasonal changes
in the euphausiid population. September and December
collections were characterized by a large number of diverse
forms. Of the eleven species recorded, 6 were most typical
of warmer Gulf Stream and Sargasso Sea water and indicated a
mixing of these warmer waters in the slope area (Euphausia
tenera, Stylocheiron abbreviatum, j>^_ affine, S^_ carinatum, £5^
submii, and Nematoscelis microps). Two species were from
neritic waters (Meganyctiphanes norvegica and Thysanoessa
gregaria). Three species were practically endemic to the
slope area (Nematoscelis megalops, Euphausia krohnii, and
Euphausia pseudogibba).tl. megalops was found to be breeding
at most of the stations during March. The March and July
samples produced few species and lower abundance. In March,
the colder waters probably prevented the 6 warm-water species
from occurring, and in July, large collections of salps may
have affected euphausiid abundance.
A-54
-------
Grice and Hart (1962) show that although the am phi pods
represented relatively low volumes and numbers, they were
second only to the copepods in the number of species present.
The number of species increased seaward with 8 recorded for
the shelf, 15 for the slope water, 26 for the Gulf Stream,
and 46 for Sargasso Sea. They were, however, relatively more
abundant in the shelf waters than offshore. The most
frequently occurring shelf and slope species were Para-
themisto gaudichaudii and P_. gracilipes. These were
seasonally augmented by the occurrence of Gulf Stream and
Sargasso Sea species.
Siphonophores were found to have more representation
offshore than inshore. Of the 30 species recorded by Grice
and Hart (1962), 17 were found in slope waters and only 4 in
shelf waters. Volumetrically, they were more important in
the Gulf Stream and Sargasso Sea. The molluscs are
represented pelagically by the pteropods and heteropods.
Grice and Hart (1962) reported 10 heteropod and 19 pteropod
species from their transect, with very few found in the
neritic environment. Of the cephalopods, squid larvae were a
widely-distributed group of the oceanic component. However,
their abundance never exceeded 6.2 per 1000 m-^.
Early investigators found that certain species of zooplankton were
indicative of the continental region from which the samples were collected
(Bigelow and Sears, 1939; Clarke, 1940). Grant (1977), employing cluster
analysis, examined these indicator species and found that 3 distinct
communities are present throughout much of the year: a coastal community, a
central Shelf community, and a Slope boundary (oceanic) community. Grant
found that the coastal community is identified in all seasons except spring by
the great abundance of the copepod, Acartia tonsa. During spring, the coastal
community is characterized by the simultaneous occurrence of Centropages
hamatus and Tortanus discaudatus. Typical inhabitants of the central Shelf
community include Centropages typicus, Calanus finmarchicus, Sagitta elegans,
£. tasmanica, Nannocalanus minor, and Parathemisto gaudichaudii. C_. typicus
is the dominant organism, and, along with C_. finmarchicus and S_. elegans, is
an indicator of this central Shelf community. A distinct faunal boundary
exists at the Shelf break (200-m contour), with the organisms occurring
offshore of this boundary being oceanic in nature. Useful indicators of this
offshore water type include Metridia lucens, Pleuromamma gracilis, Euphausia
krohnii, Meganyctiphanes norvegica, and Sagitta hexaptera. M. lucens has an
extended distribution over the Shelf during winter and spring, as does M.
A-55
-------
norvegica in spring (Grant 1977); however, other oceanic species are seldom
found more than 16 to 24 km inside the 200-m contour (Sears and Clarke, 1940).
Occasionally, Shelf Waters become temporarily "overridden" with an oceanic
species (i.e., Salpa fusiformis) which reproduces rapidly, but this is due to
local propagation and is not an indication of an unusually large mixture of
Slope Water with Shelf Water, since other oceanic species occur only as traces
(Sears and Clarke, 1940).
Although information is generally lacking, a preliminary description of the
zooplankton seasonal cycle can be given. Grice and Hart (1962) noted that
maximum displacement volume occurred in July (0.76 ml per m ) and a minimum
displacement in December (0.04 ml/m ), a twenty-fold difference. Clarke
(1940) reported a ten-fold seasonal difference; however, Grice and Hart (1962)
considered their December values low because of a missing station and felt
that it should be closer to 10 ml/m , which would be comparable to Clarke's
value. The Shelf Water exhibited a much greater seasonal fluctuation (20- to
40-fold), whereas the Sargasso Sea volumes showed little seasonal variation.
Similarly, the numerical abundance of zooplankton varied seasonally in the
slope water but with lesser magnitude than neritic areas. Maximum average
3 3
values (571/m ) occurred in September and minimum values (36/m ) in July. The
3 3
March average (504/m ) was similar to that of the Shelf Waters (585/m ).
The available biomass data for the mid-Atlantic are summarized in Table
A-13. Grice and Hart (1962) determined that the mean zooplankton standing
crop in the Shelf Waters was about three times greater than in the Slope
Waters, wherein it was three to four times greater than that of Gulf Stream
and Sargasso Sea areas. If salps were included in the measurements, the Slope
zooplankton were four times less abundant than those of the Shelf and nine to
ten times more abundant than the zooplankton of the oceanic areas. This
compares with Clarke's (1940) estimates (salps included) of the Slope Water
zooplankton: four times less abundant than the Shelf zooplankton and four
times more than oceanic areas. Examination of the numerical abundance and the
displacement volumes of each taxonomic group indicates that this difference
between Shelf and Slope Waters is not due to the disappearance or decline of
any one group of organisms but apparently to the general reduction of
zooplankton in Slope Waters (Grice and Hart, 1962).
A-56
-------
TABLE A-13
ZOOPLANKTON BIOMASS IN THE MID-ATLANTIC
Region
Western North Atlantic
Coastal
Slope Water
(spring)
Slope Water
(summer)
Coastal
(yearly mean)
Offshore
(yearly mean)
Cape Cod-Chesapeake
Bay
Coastal
(summer)
(winter)
Continental Slope
38°-41° N (autumn)
New York-Bermuda
Coastal Water
(yearly means)
Slope Water
(yearly mean)
Displ. Vol.
ml/ 1000m3
8100
4300
540
400
700-800
400
328
1070
270
Wet wt.
mg/ra
430-1600
Net Mesh
mm
0.158
0.158
0.158
10 strands/cm
10 strands/cm
0.170
0.230
0.230
Depth Range
m
0-25
0-50
0-400
0-85
0-85
Variable
Variable
0-200
or less
0-200
0-200
Reference
Riley (1939)
Riley (1939)
Riley i Gorgy (1948)
Clarke (1940)
Clarke (1940)
Bigelow & Sears (1939)
Bigelow & Sears (1939)
Yashnov (1961)
Grice 5, Hart (1962)
Grice & Hart (1962)
Several authors have noted that the most productive area for zooplankton
seems to be near the edge of the Continental Shelf. The Grice and Hart (1962)
data show the most consistent peaks of either biomass or numbers to be at the
outer Shelf or inner Slope stations. During March, quantities for the inner
Slope exceed (in biomass and abundance) that of any other area. Riley et al.
(1949) also noted from their summary of existing data that the water at the
edge of the Shelf was unusually rich in zooplankton.
The published biomass and abundance relationships from coastal to oceanic
areas apply only to the surface zone since sampling in most surveys was at
A-57
-------
depths less than 275 m. Examinations of the vertical distribution and diurnal
migration of zooplankton in the Slope Waters indicates that significant
numbers of organisms reside below the surface zone (Leavitt, 1935, 1938;
Waterman et al., 1939). Leavitt's data show a series of peaks down to 2,000 m
depth - the largest occurring at 600 to 800 m depth. From these data it was
determined that between 40% and 90% of the animals were in depths less than
800 m; however, only one-half to one-fifth of the total volume occurred above
200 m depth. Waterman et al. (1939) determined that the malacostracan
Crustacea of the Slope Water migrated vertically from 200 to 600 m depth in
response to light stimuli. This implies that there are a large number of
zooplankton unaccounted for by the surface' surveys. Leavitt (1938) concluded
that the deep water zooplankton maximum was not due to the occurrence of a
well-developed bathypelagic fauna, but was comprised of species such as
Calanus finmarchicus and Metridia longa, which are abundant in boreal surface
waters. He suggested that the deepest maximum resulted from the intrusion of
water masses which originated in shallow waters of higher latitudes.
The neuston (organisms associated with the air-sea interface) of the mid-
Atlantic comprise a unique faunal assemblage quite different from subsurface
populations. The neuston is dominated during the day by the early life stages
of fish, which are joined at night by the zoea and megalop stages of decapod
Crustacea, primarily Cancer sp., which migrate vertically into the neuston
(Grant, 1977). The euneuston (organisms which spend their entire life cycle
in the surface layer) is usually less abundant than the "facultative" neuston
(organisms which spend only part of their life cycle in the surface layer).
The euneuston is dominated by pontellid copepods and the isopod Idotea
metallica.
NEKTON
Nekton are marine organisms (e.g., fish, cephalopods, and marine mammals)
which possess swimming abilities sufficient to maintain their position and
move against local currents. Nekton can be subdivided into three groups:
micronekton, demersal nekton, and pelagic nekton. Micronekton consist of
weakly swimming nekton (e.g., mesopelagic fish and squid) which are commonly
collected in an Isaac-Kidd Midwater Trawl. Demersal nekton are the highly
A-58
-------
motile members of the nekton associated with the bottom, whereas pelagic
nekton inhabit the overlying waters. Nekton schools are highly mobile,
migrate over long distances, and have unknown depth ranges, thus information
on these organisms is limited and qualitative.
Investigations of midwater nekton at the 106-Mile Site by Krueger et al.
(1975, 1977) have shown the community to be dominated by micronekton,
gonostomatid, and myctophid fishes. During the day, most fishes are found at
considerable depths (greater than 200 m), while at night, large numbers of the
population migrate to the upper layers of the water column. During the day,
between 50% and 80% of the catch in the upper 800 m was composed of Cyclothone
species (family Gonostomatidae), while lanternfish (family Myctophidae) added
14% to 35%. Cyclothone species remain at depths greater than 200 m both day
and night, but lanternfish migrate upwards at night, at which time they
account for 95% of the catch in the upper 200 m. Above 800 m at night, the
proportion of the population of Cyclothone species decreases, with a
concomitant increase in the lanternfish portion, probably as a result of
lanternfish migrating from below 800 m and becoming more easily caught at
night. An estimated 20% of the population of lanternfish migrate from below
400 m during the day to the upper 200 m at night; one-third to two-thirds of
these reach the upper 100 m (Krueger et al., 1977).
Most of the Cyclothone catch at the 106-Mile Site was attributable to £.
microdon and C. braueri, the first and third most abundant species for all
areas and seasons. C. microdon is most abundant below 500 m, whereas C_.
braueri predominates above 600 m. Both species appear to occur generally
shallower in winter than in summer. Of the 50 species of lanternfish
captured, only four were abundant. Krueger et al. (1977) reported Cerato-
scopelus maderensis as the second most abundant species overall, but only by
virtue of a single extremely large sample. Otherwise, this species was only
moderately abundant during winter, and rare or absent during summer. Hygophum
hygomi and Lobianchia dofleini were moderately abundant during summer but were
virtually absent during winter. Adult Benthosema glaciale were abundant
during winter, but during summer, the species was only moderately abundant and
composed primarily of juveniles. Cyclothone and lanternfish contributed
between 25% and 70% of the total biomass in the upper 800 m depending upon
A-59
-------
area and dial period. Therefore, small numbers of larger species contribute
greatly to the total fish biomass. Krueger et al. (1977) found that the
larger fish inhabit depths greater than 300 m and speculated that these fish
can concentrate toxic materials as a result of feeding on smaller fishes and
larger zooplankton. Only five species, Benthosema glaciale, Lepidophanes
guentheri, Cyclothone pallida, £. braueri, and £. microdon, were taken in all
areas and seasons.
Krueger et al. (1977) concluded that the 106-Mile Site, in summer and
winter, was characterized by a Slope Water fish fauna, upon which a Northern
Sargasso Sea fauna, presumably transported to the disposal site by warm-core
eddies, was superimposed. The Sargasso Sea species which were present in
summer were less abundant in winter, suggesting that their presence and
abundance are dependent upon eddy size, age, and/or core temperature.
The most common pelagic nekton in the 106-Mile Site include tunas, bluefin
(Thunnus thynnus), yellowfin (T_. albacares), big eye (T_. obesus), and albacore
(T_. alalunga), swordfish (Xiphias gladius), lancetfish (Alepisaurus spp.),
blue shark (Prionace glauca), mako shark (Isurus oxyrinchus), and dusky shark
(Carcharhinus obscurus). All of these species are seasonal migrants north of
Cape Hatteras and prey upon a variety of organisms (Casey and Hoenig, 1977).
Approximately 50% and 30% of the tuna diet consist of fish and cephalopods,
respectively. Crustaceans and miscellaneous organisms comprise the remainder
of their diet. Swordfish feed on surface fish (e.g., menhaden, mackerel, and
herring) and a variety of deepwater fish and cephalopods. Lancetfish feed on
small fish and zooplankton. The blue and mako sharks feed mostly on small
fish and cephalopods, while other sharks feed mainly on teleosts.
A considerable amount of information is available for mid-Atlantic nekton.
The dominant micronekton groups are the (1) mesopelagic fish - myctophids,
gonostomatids, sternoptychids; (2) crustaceans - penaeid and caridean shrimps,
euphausiids, mysids; (3) cephalopods; and (4) coelenterates - medusae and
siphonophores. These organisms form one of the major links in the pelagic
food chain, since they provide forage for the animals of higher trophic
levels. The mesopelagic fish occur in large schools which are continually
changing depths. Characteristically, these fish are in the surface layers at
A-60
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night and at great depths (1,200 meters) during the day. The general faunal
composition of mesopelagic fishes in the Western North Atlantic consist of a
few abundant and many rare species (Backus, 1970). Dominant, in terms of
numbers of species and individuals, are the fishes from the families
Myctophidae and Gonostomatidae.
The long-finned squid (Loligo pealei) and the short-finned squid (Illex
illecebrosus) are two of the most abundant cephalopod species found in the
mid-Atlantic. The former belongs to the family Loliginidae, which are
primarily Continental Shelf species, and the latter is a member of the family,
Ommastrephidae, which are oceanic squids. The long-finned squid migrates into
shallow water in April to spawn. In October and November, as temperatures
decrease in inshore areas, the long-finned squid moves offshore to the edge of
the Continental Shelf. The short-finned squid spends January through April in
rather dense aggregations along the outer Continental Shelf and Slope where
the water temperatures are relatively warm. In the spring (April to May),
when Shelf Waters begin warming, short-finned squid migrate shoreward. During
the summer, fall, and early winter, they are widespread throughout the entire
mid-Atlantic Continental Shelf. In November and December, they begin moving
to deeper, warmer, offshore waters. Short-finned squid range throughout the
water column to depths of at least 700 m.
The pelagic nekton include the large, oceanic fishes which are representa-
tives of the family Scombridae (mackerels and tunas), Xiphiidae (swordfish),
and Istiophoridae (marlins and sailfishes). The bluefin tuna (Thunnus
thynnus) and the white marlin (Tetrapterus albidus) are the dominant species
in the slope waters of the mid-Atlantic (Chenoweth et al., 1976a). Other
common species include the swordfish (Xiphias gladius), albacore (Thunnus
alalunga), and the skipjack tuna (Euthynnus pelamis).
The bluefin tuna is a highly migratory species which inhabits the waters of
the New York Bight during critical periods of its life cycle. Giant bluefin
(over 125 kg) pass northward annually through the Straits of Florida in May
and June during or just after spawning. They follow the Gulf Stream northward
and usually appear in mid-Atlantic Shelf Waters in June and July. Medium
sizes (35 to 125 kg), which are believed to have spawned in the mid-Atlantic,
A-61
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normally move inshore in June. All sizes have historically left these inshore
feeding areas with the arrival of autumn storms. In winter, the species has
generally been taken only by long-line fisheries over wide areas of the North
Atlantic.
The movement of the white marlin follows a pattern similar to that of
tuna, in that they move up the Florida current and Gulf Stream, into the
mid-Atlantic Shelf and Slope Waters in the summer, and then return to the
Lesser Antilles through the open ocean in the fall. The greatest summer
abundance occurs off the New Jersey to Maryland coasts to about 1,800 m
(Chenoweth et al., 1976a). These fish enter the area from the south about
June and July, concentrate in the area during August, and then move directly
offshore in September and October. The concentration of white marlin in
summer is probably related to feeding habits, since spawning occurs in the
Caribbean.
Swordfish range along the Shelf and Slope Waters of the mid-Atlantic coast
during the summer months. In winter, the fish are confined to the waters of
the Gulf Stream where surface temperatures exceed 15°C. In warmer months,
they range over a much wider area by following the northern movement of the
15°C isotherm. Several components of the swordfish population are related to
temperature. Females and larger, older individuals seem better able to
tolerate cooler waters than males or small individuals. Swordfish populations
at the edge of the Continental Shelf are, therefore, likely to consist
primarily of large females.
The cetaceans (whales and dolphins) are wide-ranging marine mammals which
transit mid-Atlantic Slope Waters. Data are sparse on species found in the
Slope Water and the role that this region plays in their life history. The
species of cetaceans found in the mid-Atlantic, with their range, distri-
bution, and estimated abundance are summarized in Table A-14. From the data
available on cetaceans in offshore waters, it appears that the Slope Waters
serve as a migratory route between northern summering grounds and southern
wintering grounds (Chenoweth et al., 1976). The proximity of rich feeding
grounds along a north-south migration route would make the Slope Waters an
extremely attractive region to the cetaceans. The 200-m isobath appears to be
the inshore boundary for the distribution of some of the larger species.
A-62
-------
TABLE A-14
WESTERN ATLANTIC CETACEANS
Family
Balaenidae*
Balaenopteridae
Balaenopteridae*
Salaenopteridae*
Balaenopterirfae
Balaenopteridae*
Delphinidae
Ccnwon
Name(s)
Right
whale
Blue
whale
Sei
whale
Finback
whale
Minke
whale
Humpback
whale
Killer
whale
Species Name
Eubalaena
alacialis
Balaenoptera
musculus
Balaenoptera
boreal is
Balaenoptera
physalus
Balaenoptera
acutorostra-
ta
Meaaptera
novaeanaliae
Orcinus
orca
Western Atlantic
Ranae and
Distribution
New England to Gulf
of St. Lawrence;
Possibly found as
far south as Flori-
da
Gulf of St. Lawrence
to Davis Strait:
routinely sighted
on banks fringing
outer Gulf of Maine;
Population much
reduced from origi-
nal number of about
1,100 in western N.
Atlantic
New England to
Arctic Ocean
Population centered
between 41°21'N and
57°00'N and from
coast to 2000 m con-
tour
Chesapeake Bay to
Baffin Island in
summer, eastern Gulf
of Mexico, north-
east Florida and
Bahamas in winter
Common near land
but can be found
in deep ocean
Tropics to Green-
land, Spitzbergen
Baffin Bay
Habitat
Pelanlc and
coastal; not
normally In-
shore
Pelagic,
deep ocean:
however oc-
casionally
approaches
land in deep
water regions,
e.g. the
Laurentian
Channel of the
St. Lawrence
River
Pelagic,
does not
usually
approach
coast
Pelagic
but enter
bays and
inshore
waters in
late sum-
mer
Pelagic, but
may stay
nearer to
shore than
other rorquals
(except hump-
back) .
Approaches
land more
closely and
commonly than
other large
whales; also
found in deep
ocean
Mainly pela-
gic and
oceanic, how-
ever they do
commonly
approach
coast
Estimated
Abundance in
Western North
Atlantic
200-1000
Generally not
cnmmnn; some
sightings ex-
pected in off-
shore regions;
no estimates.
1,570 off Nova
Scotia
7,200
No estimates
800 - 1,500
No estimates ap-
parently not seen
as commonly as in
more northerly
areas
A-63
-------
TABLE A-14. (continued)
Fami ly
1 Oelphlnldae
Oelphinidae
Delphinidae
Oelphlnldae
Physeteridae*
Physeten'dae
Z1phf idae
Ziphiidae
ZiphiTdae
Common
Name
Saddleback
dolphin
Atlantic
Pilot
whale
Bottle-
nosed
dolphin
Grampus ;
Grey
grampus ,
Risso's
dolphin
Sperm
whale
Pygmy
sperm
whale
Bottle-
nosed
whale
True's
beaked
whale
Dense-
beaked
whale
Species Name
Delphinis
delphis
Globicephala
melaena
Turslops
truncatus
Grampus
nn'seus
Physeter
catadon
Konia
breviceps
Hyperoodon
ampul latus
Mesoplodon
mi rus
Mesoplodon
densirostris
Western Atlantic
Ranae and
Distribution
Caribbean Sea to
Newfoundland; very
wide ranging; may be
most widespread and
abundant delphinid
in world
New York to Green-
land; Especially
common in Newfound-
land
Argentina to Green-
land, but most
comon from Florida,
West Indies, &
Caribbean to New
.England
Ranges south from
Massachusetts
Equator to 50°N
(females & juve-
niles) or Oavis
Strait (males).
Tropics to Nova
Scotia
Rhode Island to
Davis Strait
Northern Florida to
Nova Scotia
Tropics to Nova
Scotia
Habitat
Seldom found
inside 100 m
contour, but
does frequent
seamounts.
escarpments ,
and other off
shore features
Pelagic
(winter) &
coastal
(summer)
Usually
close to
shore &
near
islands;
enters bays
lanoons,
rivers
Coastal
waters; ha-
bitat poor-
ly known
Pelanic,
deep
ocean
Pelagic in
warm ocean
waters
Pelagic;
cold tem-
perate and
subarctic
waters
Nothing
is known
Probably
pelagic in
tropical and
warm waters
Estimated
Abundance in
Western North
Atlantic
Poorly known; pro-
bably more common
than available re-
cords' InoHcatev
may be more
common in Mass-
achusetts Bay
no estimates
No estimates;
Most common
whale seen in
Cape Cod Bay;
Schools of up
to 300 on
Georges Bank
Rare, especially
in inshore re-
gions; no esti-
mates
Uncommon, but
possibly not rare;
no estimates
Estimated 22,000
inhabit North
Atlantic Ocean
Very rare; only
one record
Poorly known; be-
tween 260-700
taken annually in
North Atlantic
Ocean, 1968-70
Extremely rare;
poorly known
Extremely rare:
stray visitor
* Endangered Species
Source: From Chenoweth et al., 1976a.
A-64
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TABLE A-14
WESTERN ATLANTIC CETACEANS
Fatni ly
Balaenidae*
Balaenopteridae
Balaenopteridae*
Balaenopteridae*
Balaenopteridae
Balaenopteridae*
Oelphlnidae
Coimcn
Nane(s)
Right
whale
Blue
whale
Sel
whale
Finback
whale
Minke
whale
Humpback
whale
Killer
whale
Species Name
Eubalaena
alacialis
Balaenoptera
musculus
Balaenoptera
borealis
Balaenoptera
physalus
Balaenoptera
acutorostra-
ta
Meaaptera
novaeanaliae
Orcinus
orca
Western Atlantic
Ranqe and
Distribution
New England to Gulf
of St. Lawrence;
Possibly found as
far south as Flori-
da
Gulf of St. Lawrence
to Davis Strait:
routinely sighted
on banks fringing
outer Gulf of Maine;
Population much
reduced from origi-
nal number of about
1,100 in western N.
Atlantic
New England to
Arctic Ocean
Population centered
between 41°2TN and
57°00'N and from
coast to 2000 m con-
tour
Chesapeake Bay to
Baffin Island in
sunnier, eastern Gulf
of Mexico, north-
east Florida and
Bahamas in winter
Common near land
but can be found
in deep ocean
Tropics to Green-
land, Spitzbergen
Baffin Bay
Habitat
Pelanic and
coastal; not
normally in-
shore
Pelagic,
deep ocean:
however oc-
casionally
approaches
land in deep
water regions,
e.g. the
Laurentian
Channel of the
St. Lawrence
River
Pelagic,
does not
usually
approach
coast
Pelagic
but enter
bays and
inshore
waters in
late sum-
mer
Pelagic, but
may .stay
nearer to
shore than
other rorquals
(except hump-
back)
Approaches
land more
closely and
commonly than
other large
whales; also
found in deep
ocean
Mainly pela-
gic and
oceanic, how-
ever they do
commonly
approach
coast
Estimated
Abundance in
Western North
Atlantic
200-1000
Generally not
cmnmnn ; some
sightings ex-
pected in off-
shore regions;
no estimates.
1,570 off Nova
Scotia
7,200
No estimates
800 - 1 ,500
No estimates ap-
parently not seen
as commonly as in
more northerly
areas
A-63
-------
TABLE A-14. (continued)
Fam1 1y
: Delphlnldae
Oelphlnidae
Oelphinidae
Oelphinidae
Physeteridae*
Physeteridae
Ziphiidae
Ziphiidae
Ziphiidae
Common
Name
Saddleback
dolphin
Atlantic
Pilot
whale
Bottle-
nosed
dolphin
Grampus ;
Grey
grampus ,
Risso's
dolphin
Sperm
whale
Pygmy
sperm
whale
Bottle-
nosed
whale
True ' s
beaked
whale
Dense-
beaked
whale
Species Name
Delphinis
delphis
Globicephala
melaena
Tursiops
truncatus
Grampus
nriseus
Physeter
catadon
Konia
breviceps
Hyperoodon
ampullatus
Mesoplodon
mi rus
Mesoplodon
densirostris
Western Atlantic
Range and
Distribution
Caribbean Sea to
Newfoundland; very
wide ranging; may be
most widespread and
abundant delphinid
in world
New York to Green-
land; Especially
common in Newfound-
land
Argentina to Green-
land, but most
common from Florida,
West Indies, &
Caribbean to New
England
Ranges south from
Massachusetts
Equator to 50°N
(females & juve-
niles) or Davis
Strait (males).
Tropics to Nova
Scotia
Rhode Island to
Davis Strait
Northern Florida to
Nova Scotia
Tropics to Nova
Scotia
Habitat
Seldom found
inside 100 m
contour, but
does frequent
seamounts.
escarpments,
and other off
shore features
Pelagic
(winter) &
coastal
(summer)
Usually
close to
shore S
near
islands;
enters bays
lagoons,
rivers
Coastal
waters; ha-
bitat poor-
ly known
Pelagic,
deep
ocean
Pelagic in
warm ocean
waters
Pelagic;
cold tem-
perate and
subarctic
waters
Nothing
;s known
Probably
pelagic in
tropical and
warm waters
Estimated
Abundance in
Western North
Atlantic
Poorly known; pro-
bably more common
than available re-
cords' indicate;:
may be more
common in Mass-
achusetts Bay
no estimates
No estimates;
Most common
whale seen in
Cape Cod Bay;
Schools of up
to 300 on
Georges Bank
Rare, especially
in inshore re-
gions; no esti-
mates
Uncommon, but
possibly not rare;
no estimates
Estimated 22,000
inhabit North
Atlantic Ocean
Very rare; only
one record
Poorly known; be-
tween 260-700
taken annually in
North Atlantic
Ocean. 1968-70
Extremely rare;
poorly known
Extremely rare:
stray visitor
* Endangered Species
Source: From Chenoweth et al., 1976a.
A-64
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Five species of sea turtles are known to be associated with mid-Atlantic
coastal and Slope Waters (Table A-15). Three of the species (hawksbill,
leatherback, and Atlantic ridley) are endangered, and the remaining two (green
and loggerhead) are expected to soon be classified as endangered. Leather-
backs (Dermochelvy coriacea), loggerheads (Caretta caretta), ridleys
(Lepidochelys kempi), and green turtles (Chelonia mydas) are regular migrants
in East Coast waters, usually most numerous from July through October, at
which time, the turtles follow their primary food (jellyfish) inshore. The
exact migration route used by these organisms is not known.
The main components of the demersal nekton are flatfish (flounders,
halibut, plaice, and sole), cartilaginous fishes (skates, rays, and
torpedoes), and "roundfish" (cod, haddock, hake, and cusk). The diet of these
groups consists mainly of bottom-dwelling animals (e.g., crustaceans,
mollusks, echinoderms, and worms) although a number of the roundfish are
predaceous on other fish and shrimp. Spawning activity occurs generally near
the bottom, but in some cases the eggs, and in many instances the larvae, are
pelagic.
Markle and Musick (1974) found 29 species and 17 families of benthic fishes
in the Slope Waters of the region between Nantucket and Cape Hatteras. The
dominant demersal fish in the mid-Atlantic were reported to be the synapho-
branchid eel (Synaphobranchus kaupi), the macrourids (Mezumia spp.), the
long-finned hake (Phycis chesteri), and the flatfish (Glyptocephalus
cynoglossus). Schroeder (1955) reported that numbers and weights of fish
caught increased between 400 and 1,000 m depth. Slope levels below 1,000 m
were regions of reduced abundance, biomass, and diversity, with the 1,000-m
isobath being the point at which a significant change occurs. The most
significant species of demersal fish found in Slope Waters, and the average
abundance, are listed in Table A-16. Generally, the deeper-water forms (e.g.,
the macrourids [grenadiers], offshore hakes, batfish, and stomiatoids) are
found in low quantities scattered throughout the area. These species are
probably never as abundant as the shallower water forms which are found in the
upper Slope levels.
A-65
-------
TABLE A-15
THREATENED AND ENDANGERED TURTLES FOUND_IN MID-ATLANTIC SLOPE WATERS
Name
Species Name
Cjogrcsphic-6 a thyme trie Range
Habitat
Reason for Decline
^Hawksbill
turtle
+Leatherback
turtle
"Loggerhead
turtle
*Grecn
turtle
^Atlantic
rldley
Eretniochelys
iinbrlcata
Dermochelvy
coriacea
Caretta
caretta
Chelonia
Lepidochelys
kempi
tropical wacers, rare in New
ling 1 ana waters, nests en
Carribean shores and along
Atlantic coast to Brazil on
undisturbed beacnes.
New England waters summer-
autumn. Closely associated
with slope waters during
migration
New England waters •3ununer-
autumn. Migrate Atlantic
coast to/from Sargasso
Sea
occasionally seen in New
England waters in summer.
Tropical oceans. Rare
north of Cape Cod.
New England waters during
summer months, breeds on
more tropical beaches
deep ocean
highly
pelagic,
feeds on
pelagic
jellyfish
frequently
signted in
coastal waters,
more littoral
than leather-
back or nawks-
bill
deep slope
waters between
Gulf Stream
and littoral
feeding grounds
more littoral
than leather-
back or hawks-
bill
heavily exploited
for shell
some slaughter by
fishermen, eggs
collection on
breeding grounds
predation by
racoons and
people, egg
destruction of
breeding beaches
due to coastal
development
reduction of
breeding grounds
and commercial
exploitation
eggs plundered on
breeding beaches
*proposed threatened status ^endangered species
-------
Water over the mid-Atlantic Continental Shelf contains few permanent
residents. The fish fauna is composed primarily of continuously shifting
populations which move north, many into the Gulf of Maine, during the warm
months, and retreat south during the cold months (Larsen and Chenoweth, 1976).
During the spring, along the Shelf edge and upper Slope, the weight and
numbers of fishes are far greater than in the fall. This is particularly true
of highly migratory forms such as silver hake (Merluccius bilinearis), spiny
dogfish (Squalus acanthias), and red hake (Urophycis tenuis). The overall
average of numbers of fish caught and their catch weight in the spring were
684 and 819 kg, respectively, in contrast to 374 and 140 kg in the fall.
BENTHOS
The benthos of the 106-Mile Site exists at abyssal depths on the lower
mid-Atlantic Continental Slope and Rise. Research on the Slope faunal
assemblages was begun only recently, and has centered around the contributions
of comparatively few investigators. This accounts for the sparse amount of
data with respect to Continental Slope benthic populations, particularly at
the 106-Mile Site. There is substantial evidence, however, that the major
components of faunal assemblages at various Slope depths do not change
significantly throughout the mid-Atlantic and neighboring areas (Larsen and
Chenoweth, 1976; Rowe et al. , 1977; Pearce et al., 1977a). Thus, it is
possible to use faunal data from adjacent areas in order to enhance the data
and interpretations associated with the disposal site fauna.
Variations in sediment types are generally recognized as primary factors
which 'influence benthic faunal distributions on the mid-Atlantic Shelf. These
factors, however, are of doubtful importance in influencing benthic faunal
distributions in the 106-Mile Site Slope area, due to minimal sediment
variations within similar areas (Rowe and Menzies, 1969). Temperature can be
discounted as an important factor since no seasonal changes or variations with
depth occur below 1,000 m (Larsen and Chenoweth, 1976; Rowe and Menzies,
1969). It has not been determined to what extent species interaction within
the site determines faunal composition and zonation, but competitive exclusion
may be a critical factor (Sanders and Hessler, 1969).
A-67
-------
AT
TABLE A-16
AVERAGE NUMBER AND WEIGHT PER TOW OF DEMERSAL FISH TAKEN
SHELF EDGE AND SLOPE DURING FALL AND SPRING TRAWL SURVEYS, 1969 - 1974
Common Name
Silver Hake
Offshore Hake
Red Hake
White Hake
Spiny Dogfish
Mackerel
Butterfish
American Goosefish
Witch Flounder
Black Bellied Red fish
Northern Sea Robin
Striped Sea Robin
Armored Sea Robin
Bat fish
Pearlsides
Greeneye
Species Name
Av. No.
Merluccius bilinearis
M. albidus
Urophycis chuss
U. tenuis
Squalus acanthias
Scomber scombrus
Poronotus triacanthus
Lophius americanus
Glyptocephalus cynoglossus
Helicolenus dacty lopterus
Prionotus carolinus
P. evolans
Peristedion miniatum
Ogcocephalus vespertilio
Maurolicus spp.
Cliloropthalmus agassizii
Shelf Break
Fall
Av. Wt.
13
1
2
1
1
1
263
2
1
2
1
187
Av. No.
(kg)
3
1
2
1
1
1
67
3
1
1
1
1
Spring
Av. Wt.
30
1
7
1
69
99
130
1
1
1
169
3
Av. No.
(kg)
25
1
9
1
350
158
57
12
1
1
67
1
Slope
Fall
Av. Wt.
8
3
1
1
1
1
14
2
1
13
1
24
Av. No.
(kg)
5
3
1
2
1-
1
3
14
1
3
1
1
Spring
Av . Wt .
76
6
36
2
80
5
57
2
3
13
2
7
(kg)
66
8
32
16
468
8
18
44
3
3
1
1
OO
Source: Adapted from Larsen and Chenoueth, 1976.
-------
Deep-sea nutrition is probably the most important factor which influences
benthic faunal distributions in the site vicinity. Larsen and Chenoweth
(1976) hypothesize that the lower levels of available organic carbon at
greater depths are key factors which determine faunal biomass and density in
the deep benthos. The importance of competitive exclusion relates directly to
the abundance and distribution of nutrients.
Food materials consumed by the benthic fauna of the 106-Mile Site, the
associated food sources, and transport mechanisms are incompletely known.
Several dominant species of fish in the site are known to feed only upon
epibenthic and infaunal invertebrates, whereas other fish feed primarily on
pelagic items (Cohen and Pawson, 1977; Musick et al., 1975). Most of these
pelagic items were diurnal migrants, which correlated with the views of
Sanders and Hessler (1969) with respect to the importance of these migrants in
efficient transport of food from the euphotic zone to deeper layers. The
majority of fish at the site are probably generalized feeders, since this is
characteristic of the fish inhabiting greater depths (Haedrich et al. , 1975)
and many generalized feeding fish have been found at the site (Musick et al.,
1975).
The dominant epibenthic and infaunal invertebrates of the site are deposit
feeders whose abundance and distribution would depend upon the availability of
detrital food items (Jones and Haedrich, 1977; Pearce, 1974). It is generally
recognized that the food supply of the benthos originates from shallower
areas, particularly the euphotic zone (Sanders and Hessler, 1969), but the
primary mechanism by which the food is transported to the deeper layers is
uncertain. The most important mechanism transporting detritus to the benthos
of the site is probably the passive sinking of potential food items.
Turbidity currents may also play some part, but their role has been discounted
(Sanders and Hessler, 1969).
Many authors have recognized distinct quantitative and qualitative zones of
distribution for the benthic fauna of mid-Atlantic Continental Slope areas.
The number and demarcation of zones may vary between authors, but they all
center their zones on an axis horizontal or vertical to the Slope. Cohen and
Pawson (1977) describe a horizontal distribution pattern of benthic fish and
A-69
-------
invertebrates in the site. They observed great variance in the abundance of
the four most common epibenthic invertebrates from one site region to the
next, but were hesitant to label this distribution as patchy.
Vertical distributions are more commonly recognized in the site, the
general trend being one of decreasing numbers of taxa and individuals with
increasing depth (Cohen and Pawson, 1977; Pearce et al., 1977a; Musick et al.,
1975). This trend is typical for Slope and deep-sea areas (Haedrich et al.,
1975; Rowe and Menzies, 1969; MacDonald, 1975). Musick et al. (1975)
recognize the Shelf-Slope break above the site as an area of increased
diversity, species richness, and biomass of benthic fish populations. This
pattern remained stable down to the 2,200 m depth of the site, where it
rapidly declined. Haedrich et al. (1975) also recognized these two zones in
an area northeast of the site.
Surveys of the benthos in the site have found no species of present
commercial importance and only a few of potential importance. The shellfish
commonly harvested on the adjacent Shelf, including the surf clam, sea
scallop, and southern quahog, do not extend their range onto the Continental
Slope. The lobster, presently fished in canyon and Shelf areas above the
site, is not found in the site (Pratt, 1973). The red crab, Geryon
quinquidens, is a potential commercial species of the mid-Atlantic but is
found only in Slope areas shallower than the site (Musick et al., 1975; Pratt,
1973).
No demersal fishes of commercial importance are presently being harvested
from the site vicinity, and only a few potential species have been found
there. Two dominant site species, Coryphaenoides cupestris and Alepocephalus
agassizii, have been harvested experimentally by the Russian and British
fishing industries from areas outside the site. Waters containing the site
serve as a nursing ground for Glyptocephalus cynoglossus, the adults of which
support a fishery elsewhere (Musick et al., 1975).
Musick et al. (1975) reported 48 species of demersal fishes from 12 trawl
stations in and around the 106-Mile Site. They described the diversity of the
fish community as being higher than that of estuarine and Shelf communities.
A-70
-------
The dominant species of fishes were different at each deeper station within
the site: Synaphobranchus kaupi at shallower depths, Nezumia bairdii and
Antimora rostrata at mid-depths, and predominantly Coryphaenoides armatus at
the deepest stations. At increasing depths, the smaller species decreased in
number and the larger species increased in number. This resulted in the
steady level of biomass observed throughout the site, as mentioned above, but
with an increasingly smaller number of fish comprising the biomass at each
depth.
Cohen and Pawson (1977) observed 55 species of fishes during 9 dives in the
deep sea research vessel (DSRV) ALVIN. They described the overall distribu-
tion as patchy and noted that most of the species were rarely encountered.
The six most common fishes included two of the dominant species in the above
study: the eel, Synaphobranchus kaupi, and the morid, Antimora rostrata. The
other four species were the rattails, Nematonurus armatus and Lionurus
carapinus, the halosaur, Halosauropsis macrochir, and the lizard fish,
Bathysaurus ferox. Densities of fishes in two depth zones were estimated by
counting fish along six transects. There was a relative abundance of fish,
showing patchy distribution, from 1,720 to 1,819 m depth. The range of
2
densities for this depth zone was 5.7 to 32.8 fishes per 1,000 m . The
density from 2,417 to 2,545 m depth was lower, ranging from 1.83 fishes per
2
1,000 m , and the fishes were distributed more evenly. The dominant species
listed above are common dominants of the mid-Atlantic (Larsen and Chenoweth,
1976).
The epibenthic invertebrates of the 106-Mile Site have been described in
two studies, by Cohen and Pawson (1977) and Rowe et al. (1977), both of which
are based on visual and photographic observations from the DSRV ALVIN. These
studies were limited by the observers' abilities to detect epibenthic
invertebrates from the vantage point of the ALVIN'S viewports and in
photographs. Animals which avoid submersible vehicles will be consistently
missed by both methods. This is assumably what caused the "selectivity" of
the former study; Cohen and Pawson do not indicate if other detectable
invertebrates were selectively omitted from the report. Although it is
A-71
-------
unknown how many species may be missing, the reported results most likely
include all the dominant species and major contributors to the total biomass
of epibenthic invertebrates in the site.
According to Cohen and Pawson (1977), the four most abundant invertebrates
2
in decreasing order, and peak densities per 1,000 m , were Ophiomusium
(brittle star), 2,445; Cerianthus sp. (tube anemone), 813; Echinus affinus
(sea urchin) 259; and Euphronides (holothurian), 101. Rowe et al. (1977)
reported identical results for numerical dominance with the exception of the
substitution of Phormosoma placenta (sea urchin) for Euphronides. The average
2 2
number of species was 2.36/m , ranging from 0.25 to 5.15/m . In studies of
similar areas to the north of the site (Jones and Haedrich, 1977; Haedrich et
al., 1975), Ophiomusium was consistently found to be the most numerically
abundant species, with Echinus affinus as a major contributor. The major
contributor to the biomass in each study was always one of the numerically
dominant species common to each site.
It may be concluded, therefore, that there is little difference between the
major epibenthic invertebrate faunal components of the site and those of other
mid-Atlantic Continental Slope areas of similar depth (Jones and Haedrich,
1977; Haedrich et al., 1975). Echinoderms are generally the most important
faunal component of these areas.
The macroinfauna collected at or near the 106-Mile Site is presented in
Table A-17. The species are considered to be typical for the mid-Atlantic
Slope region (Pearce et al., 1977a). Diversity and density of infauna
decrease with increasing depth and distance offshore. Polychaetes are the
*
dominant species, followed by bivalves, nematodes, and peracarids. Pearce et
al. (1977a) reported a range of densities for 22 stations in the site vicinity
2 2
of 0 to 119 organisms/0.1 m . The number of taxa ranged from 0 to 34/0.1 m .
*Polychaetes and nematodes were common at all depths sampled, while peracarids
and molluscs generally occurred shallower than 768 m.
A-72
-------
Infauna data indicate that there are no significant differences in the
species richness or abundance between the 106-Mile Site and control stations
(Pearce et al., 1977a).
TABLE A-17
BENTHIC INFAUNA COLLECTED AT OR NEAR THE 106-MILE
TAXON
Anthozoa
Pennatulacea
Rhynchocoela
Nematoda
Oligochaeta
Polychaeta
Notomastus latericius
Heteromastus filiformis
Ampharete arctica
Ampharete sp. #1
Aricidea albatrossae
Aricidea sp. #1
Paraonis gracilis
Paraonis cornatus
Paraonis abranchiata
Paraonis sp. #1
Syllis (Langerhansia) #1
Polynoidae
Antinoella sarsi
Stenolepis tetragona
Orbiniidae
Phylo michaelseni
Ancistrosyllis groenlandica
Ancistrosyllis sp.
Glycera capitata
Goniada maculata
Poraxillella gracilis
Asychis biceps
Axiothella sp. #1
Leichone dispar
Paramphinome jeffreysii
Lumbrineris tetraura
Lumbrineris sp.
Armandia sp.
TAXON
Polychaeta (cont.)
Onuphis (Nothia) sp. #1
Drilonereis longa
Amaena trilobata
Polycirrus sp. #1
Sabellidae #1
Tharyx sp. #1
Spiophanes wigleyi^
Nicon sp. #1
Cossura longocirrata
Ownenia fusiformis
Myriochele danielsseni
Sipuncula
Goldfingia flagrifera
Crustacea
Peracarida
Amphipoda
Harpinia cabontensis
Harpinia n. sp.
Gastropoda
Olivella sp.
Scaphopoda
Dentalium occidentale
Dentallium sp. #1
Bivalvia
Malletia sp.
Nucula t'enuis
Thyasira trisinuata
Ophiuroidea
Amphipholis squamata
Echinoidea
Spatangoidea
Holothuroidea
Chaetognatha
Source: Adapted from Pearce et al., 1977a.
A-73
-------
APPENDIX B
CONTAMINANT INPUTS TO THE
106-MILE OCEAN WASTE DISPOSAL SITE
-------
CONTENTS
Title
HISTORICAL USAGE (1973-1978) B-l
PROJECTED INPUTS B-5
WASTE CHARACTERISTICS B-6
Du Pont-Grasselli B-12
Du Pont-Edge Moor B-l 7
American Cyanamid B-l 9
Merck and Company B-22
ILLUSTRATIONS
Number Title Page
B-l Historical and Projected Dumping Activity at the 106-Mile Site . . B-2
TABLES
B-l Amounts of Material Dumped at the 106-Mile Site
from 1973 to 1978 B-3
B-2 Projected Amounts of Wastes to be Dumped During 1979-1980
at the 106-Mile Site B-5
B-3 Annual Estimated Mass Loading for Suspended Solids,
Petroleum Hydrocarbons, and Oil and Grease at the
106-Mile Site, 1973-1978 B-7
B-4 Concentrations of Suspended Solids, Petroleum Hydrocarbons,
and Oil and Grease in Industrial Waste Dumped
at the 106-Mile Site . B-7
B-5 Suspended Solids, Petroleum Hydrocarbons, and Oil and
Grease Released at the 106-Mile Site, 1973-1978 B-8
B-6 Estimated Annual Industrial Trace Metal Mass Loading B-9
B-7 Average Metal Concentrations in Wastes at 106-Mile Site B-ll
B-8 pH, Specific Gravity, and Percent Solids in Industrial
Waste Dumped at the 106-Mile Site B-12
B-9 Characteristics of Typical Sewage Sludge
Digester Cleanout Residue . ..... B-12
B-10 Nonpersistent Organphosphate Insecticides Released by
American Cyanamid, 1973-1978, at the 106-Mile Site B-21
B-iii
-------
APPENDIX B
CONTAMINANT INPUTS TO THE
106-MILE OCEAN WASTE DISPOSAL SITE
HISTORICAL USE (1973-1978)
The 106-Mile Site was proposed for use in 1965 by the U.S. Fish and
Wildlife Service as an alternative to the inland discharge of industrial
chemical wastes which might contaminate potable water supplies. However, some
chemical wastes were disposed at the site during 1961, 1962, and 1963. From
1961 to 1978, approximately 5.1 million metric tons of chemical wastes,
102,000 metric tons of sewage sludge, and 287,000 metric tons of sewage sludge
digester cleanout residue were dumped at the site. In addition, munitions
were dumped in the past at a location in the northwest corner of the site.
During 1951 to 1956 and 1959 to 1962, 14,300 drums of radioactive wastes
containing 41,400 curies of radioactivity were dumped 10 nmi (18.5 km) south
of the southern edge of the 106-Mile Site,
When ocean waste disposal came under EPA regulation in 1973, 66 permittees
were dumping wastes at the site. Since 1973, the number of permittees has
steadily declined until, as of mid-February 1979, only four permittees
remained: American Cyanamid (Linden, N.J.); E.I. du Pont de Nemours and Co.,
Inc., Edge Moor Plant (Edge Moor, Del.) and Grasselli Plant (Linden, N.J.);
and Merck & Co. (Rahway, N.J.). Despite the decline in the number of
permittees, the amount of waste increased 134% from 341,000 metric tons in
1973 to 797,000 metric tons in 1978. The increase in amount was primarily the
result of the relocation of industrial waste generators from the New York
Bight Sewage Sludge Site in 1974, Du Pont-Grasselli from the New York Bight
B-l
-------
Acid Wastes Site in 1974, and Du Font-Edge Moor from the Delaware Bay Acid
Waste Site in 1977. The latter Du Pont plant discharged 380,000 metric tons,
or 50% of total waste released in 1977, as compared to the previous year's
total of 375,000 metric tons for all permittees. Waste from the City of
Camden, New Jersey, was relocated by court action to the site in 1977.
However, Camden contributed only 6% of the annual total or 48,000 metric tons.
In 1978, the amount of dumped waste totalled 797,000 metric tons representing
a 4% decrease from the high in 1977. Overall, approximately 75% of the waste
discharged from 1973 to 1978 was from three industrial sources: American
Cyanamid, Du Font-Edge Moor, and Du Pont-Grasselli.
Figure B-l illustrates the dumping trends at the 106-Mile Site from 1973 to
1978. The actual amounts dumped and percent contribution of each permittee
appear in Table B-l.
800
700
£ 3, 600
S Z
= O
Q H
£ U 500
ce
< H
O g 400
t v*
= i
O < 300
5
< 2
J O
< I
g t 200
100
NUMBER OF PERMITTEES
80
70
60
Z
50 §
40
30
20
10
m
73
0
1973 1974 1975 1976 1977 1978 1979 1980 1981 1982
Figure B-l. Historical and Projected Dumping Activity at the 106-Mile Site
B-2
-------
TABLE B-l ^
AMOUNTS OF MATERIAL DUMPED AT THE 106-MILE SITE FROM 1973 TO 1978
(Thousands of Metric Tons)
Permittee
American Cyanamid Co.
Camden, N.J.
Chevron Oil Co.
Du Font-Edge Moor
Du Pont-Grasselli
Hess Oil Co.
Mixed Industries
**
Mixed Municipalities
Totals
1973
118 (35)
—
25 (7)
--
116 (34)
7 (2)
34 (10)
41 (12)
341
1974
137 (31)
—
26 (6)
—
155 (35)
—
35 (8)
93 (21)
446
1975
116 (20)
—
22 (4)
--
264 (46)
—
78 (14)
96 (17)
.576
1976
119 (32)
—
—
--
164 (44)
—
67 (18)
25 (7)
375
1977
130 (17)
48 (6)
—
380 (50)
107 (14)
—
85 (11)
16 (2)
766
1978
111 (14)
54 (7)
--
372 (47)
172 (22)
—
72 (9)
16 (2)
797
Totals
731 (22)
102 (3)
73 (2)
752 (23)
978 (30)
7 (0.2)
371 (11)
287 (9)
3,301
w
Co
* Permittees' percentages of annual totals appear in parentheses.
t Crompton and Knowles, Merck and Co., and Rebels Chemical Co.
** Permittees using New York Bight Sewage Sludge Site (sewage sludge digester cleanout residue).
-------
Over the years, Du Pont-Grasselli has been the primary contributor of waste
to the site, releasing 978,000 metric tons, or approximately 30% of the total
from 1973 to 1978. The amounts ranged from 107,000 metric tons in 1977 to
264,000 metric tons in 1975, averaging 163,000 metric tons annually. Du Pont-
Grasselli dumps waste seven to nine times per month.
Du Font-Edge Moor, the second major waste contributor, moved the dumping
operation from the Delaware Bay Acid Waste Disposal Site to the 106-Mile Site
in March 1977. Du Font-Edge Moor has been dumping at the site for only two
years; however, they have released approximately 752,000 metric tons, or 23%
of the total volume of waste dumped between 1973 and 1978, Du Font-Edge Moor
barges waste to the site an average of seven times per month.
From 1973 to 1978, American Cyanamid disposed of approximately 731,000
metric tons of chemical waste, averaging 122,000 metric tons per year.
American Cyanamid's volume constituted approximately 22% of the waste which
was dumped at the site during that period. The volumes ranged from 111,000
metric tons in 1978 to 137,000 metric tons in 1974. American Cyanamid waste
is barged to the site an average of seven times per month.
The mixed waste of a number of industries has been barged to the site. In
1973, 63 industrial permittees (besides the three already discussed) were
dumping at the site, but now only Merck and Co. remains. From 1973 to 1978,
approximately 371,000 metric tons of mixed industrial wastes were dumped,
comprising 11% of the total volume released during that period. The mixed
input ranged from 34,000 metric tons in 1973 to 85,000 metric tons in 1977,
averaging 62,000 metric tons per year. Dependent upon the barge and the
volume of waste, Merck's waste is dumped once or twice per month.
Sewage sludge has also been dumped at the site. The City of Camden sewage
sludge disposal operation was relocated to the site in 1977. Camden
discharged 102,000 metric tons, or 7% of the waste dumped during 1977 and
1978. Camden1s waste volume represented 3% of the total waste dumped at the
site from 1973 to 1978. Camden ceased ocean dumping on June 15, 1978.
B-4
-------
Sewage sludge digester cleanout residues from many New York/New Jersey area
municipal wastewater treatment plants were released at the site from 1973 to
1978. Approximately 287,000 metric tons were dumped, comprising 9% of the
total dumped during this period.
PROJECTED INPUTS
Table B-2 summarizes the projected dumping amounts and scheduled phaseout
dates for the current permittees at the 106-Mile Site.
TABLE B-2
PROJECTED AMOUNTS OF WASTES TO BE DUMPED DURING
1979-1980 AT THE 106-MILE SITE
Permittee
American Cyanamid
Du Font-Edge Moor
Du Pont-Grasselli
Merck
Scheduled Phaseout Date
,
April 1981
May 1980
—
April 1981
Yearly Totals
Thousands of Metric
Tons/Year
1979
123
299
295
36
753
1980
123
136
295
36
590
1981
30
0
295
10
335
Du Pont-Grasselli has investigated several land-based alternatives, two in
detail: biological treatment and incineration. These alternatives do not
comply with state and/or Federal environmental regulations and, therefore,
have been rejected in favor of ocean disposal. The waste has been
demonstrated to comply with EPA's marine environmental impact criteria;
however, EPA and the New Jersey Department of Environmental Protection (NJDEP)
have recommended further detailed investigations of alternatives by Du Pont.
B-5
-------
Du Pont-Grasselli has projected that its annual waste volumes will not exceed
295,000 metric tons. Du Pont-Grasselli1s current permit expires January 14,
1981. It will be eligible for renewal at that time, assuming that Du Pont
continues to demonstrate compliance with EPA's need and environmental impact
criteria.
Du Pont-Edge Moor is currently complying with an EPA-imposed schedule to
cease ocean dumping by May 1980 in favor of other alternatives. The iron
chloride in the waste will be converted to ferric chloride and marketed as a
water treatment chemical. The company is constructing facilities which will
allow recycling of hydrochloric acid, a major component of the waste. The
concept has been tested in the laboratory and at a pilot plant, and is
expected to be fully operational in 1980 (Kane, 1977).
American Cyanamid will continue to ocean-dump according to its compliance
schedule until April 1981, when the land-based treatment is operational. The
land-based alternative waste disposal method selected by Cyanamid basically
consists of on-site carbon treatment and off-site thermal oxidation of the
balance of the wastes. Whether or not these alternative treatment
technologies can comply with environmental regulations has not been determined
at present.
Merck has determined that two feasible modifications of present ocean
disposal methods can be implemented: (1) on-site pre-treatment of existing
wastes followed by discharge to a municipal treatment plant, and (2)
manufacturing process changes which would produce wastes dischargeable
directly into a municipal treatment plant. Merck is complying with an
EPA-imposed schedule to cease dumping by April 1981.
WASTE CHARACTERISTICS
The characteristics of wastes dumped at the site since 1973 are summarized
in Tables B-3 to B-9. The future waste characteristics of the four remaining
permittees are expected to follow historical trends. Merck waste, previously
undifferentiated from the mixed industrial waste analyses, is characterized
separately as data permit.
B-6
-------
TABLE B-3
ANNUAL ESTIMATED MASS LOADING FOR SUSPENDED SOLIDS, PETROLEUM
HYDROCARBONS, AND OIL AND GREASE AT THE 106-MILE SITE, 1973-1978
Constituent
Suspended Solids
Petroleum Hydrocarbons
Oil and Grease
Metric Tons/Year
1973
1,200
5
200
1974
400
30
200
1975
2,300
600
100
1976
10,400
30
200
1977
2,500
200
700
1978
4,300
50
100
TABLE B-4
CONCENTRATIONS OF SUSPENDED SOLIDS, PETROLEUM HYDROCARBONS, AND OIL
AND GREASE IN INDUSTRIAL WASTE DUMPED AT THE 106-MILE SITE
(rag/liter)
Permittee
American Cyanamid
Du Pont -Edge Moor
Du Pont-Grasselli
Mixed Industries
Suspended Solids
Mean
312
2,192
760
81,000
Range
2-2,375
60-21,000
5-15,090
12-771,000
Petroleum Hydrocarbons
Mean
314
<0.3
16
1,361
Range
5-5,270
—
1-108
1-57,600
Oil and Grease
Mean
872
4
17
1,088
Range
10-6,214
1-24
1-108
6-4,850
B-7
-------
TABLE B-5
SUSPENDED SOLIDS, PETROLEUM HYDROCARBONS, AND
OIL AND GREASE RELEASED AT THE 106-MILE SITE, 1973-1978
(Metric Tons)
Permittee and Year
American
Cyanamid
1978
1977
1976
1975
1974
1973
Du Font-
Edge Moor
1978
1977
Du Pont-
Grasselli
1978
1977
1976
1975
1974
• 1973
Mixed ^
Industries
1978
1977
1976
1975
1974
1973
Camden,
N.J.
1977
Chevron
Oil Co.
1975
1974
1973
Hess
Oil Co.
1973
Total Suspended Solids
Amount
Dumped
97
39
27
19
60
19
1,100
68
53
19
45
607
97
49
3,048
527
10,300
168
226
1,100
1,815
34
14
14
0.3
Permittee's
Percent of
Annual Total
Dumped
2
1
1
1
15
2
25
3
1
1
1
26
24
4
72
21
99
72
57
93
74
1
4
1
1
Petroleum Hydrocarbons
Amount
Dumped
34
100
15
55
18
NR
0.1
0.1
0.6
1
2
NR
NR
NR
12
9
12
551
7
5
93
35
2
NR
—
Permittee's
Percent of
Annual Total
Dumped
73
49
51
—
—
—
<1
1
1
1
6
—
—
—
26
4
43
—
—
—
46
—
—
—
—
Oil and Grease
Amount
Dumped
75
223
74
17
97
NR
1.6
0.9
2
3
2
6
2
NR
36
13
98
97
108
0.2
505
22
3
2
214
Permittee's
Percent of
Annual Total
Dumped
65
30
43
12
46
—
2
1
2
1
1
4
1
—
31
2
56
69
51
— —
68
15
1
—
—
NR - Not reported
* Crompton and Knowles, Merck and Co., and Reheis Chemical Co.
B-8
-------
TABLE B-6
ESTIMATED ANNUAL INDUSTRIAL TRACE METAL MASS LOADING
^^•^^ Year/Volume
^^\^
Trace Metal/ ^"^^^
Permittee ^~^^^
Cadmium
American Cyanamid
Du Font-Edge Moor
Du Pont-Grasselli
Mixed Industries
Chevron Oil
Hess Oil
TOTAL
Chromium
American Cyanamid
Du Font-Edge Moor
Du Pont-Grasselli
Mixed Industries
Chevron Oil
Hess Oil
TOTAL
Copper
American Cyanamid
Du Pont -Edge Moor
Du Pont-Grasselli
Mixed Industries
Chevron Oil
Hess Oil
TOTAL
1973
Volume •
Dumped
(kg)
1
—
12
197
1
<1
211
156
—
33
483
1
4
Total
Dumped
(Z)
<1
—
6
93
<1
<1
23
—
5
71
<1
<1
677
11
—
35
954
8
3
1
—
3
94
1
1
1,011
1974
Volume
Dumped
(kg)
<1
—
29
5,484
3
—
Total
Dumped
(Z)
<1
—
1
99
<1
—
5,516
46
—
87
552
11
—
7
—
13
79
1
—
696
5
—
64
509
25
—
1
—
11
84
4
—
603
1975
Volume
Dumped
(kg)
<1
—
72
19,430
1
—
Total
Dumped
(Z)
<1
—
1
99
<1
—
19,503
58
—
89
557
1
—
8
—
13
79
<1
—
705
5
—
73
733
15
—
<1
—
9
89
2
—
826
1976
Volume
Dumped
(kg)
<1
—
33
180
—
—
Total
Dumped
(Z)
<1
—
15
84
—
—
213
50
—
19
146
—
—
23
—
9
68
—
—
215
13
—
41
481
—
—
2
—
8
90
—
—
535
1977
Volume
Dumped
(kg)
<1
185
8
529
—
—
Total
Dumped
(Z)
<1
23
<1
65
—
—
812
56
69,208
64
3,909
—
—
<1
94
<1
5
—
—
73,845
14
827
2,069
87
—
—
<1
22
56
2
—
—
3,695
1978
Volume
Dumped
(kg)
3
107
25
33
—
—
Total
Dumped
(Z)
2
64
15
19
—
—
168
23
98,982
21
934
—
—
1
99
1
1
—
—
99,960
156
1,221
220
266
—
—
8
65
12
15
—
—
1,863
w
SO
-------
TABLE B-6 (Continued)
^"\^^ Year/Volume
Trace Metal/ ^\^
Permittee ^^^^
Lead
American Cyanamid
Du Font-Edge Moor
Du Pont-Grasselli
Mixed Industries
Chevron Oil
Hess Oil
TOTAL
Mercury
American Cyanamid
Du Font-Edge Moor
Du Pont-Grasselli
Mixed Industries
Chevron Oil
Uess Oil
TOTAL
Nickel
American Cyanamid
Du Font-Edge Moor
Du Pont-Grasselli
Mixed Industries
Chevron Oil
Hess Oil
TOTAL
Zinc
American Cyanamid
Du Font-Edge Moor
Du Pont-Grasselli
Mixed Industries
Chevron Oil
Uess Oil
TOTAL
1973
Volume
Dumped
(kg)
47
54
142
4
4
Total
Dumped
(Z)
19
22
57
1
1
251
11
1
22
9
2
24
2
49
20
5
45
217
83
100
18
2
52
20
24
4
<1
420
82
49
11,985
4
5
1
1
99
1
1
12,125
1974
Volume
Dumped
(kg)
6
115
759
53
Total
Dumped
(Z)
<1
12
81
6
933
2
2
9
1
14
14
64
8
14
83
114
142
16
23
32
40
4
355
32
154
15,549
68
<1
1
98
<1
15,803
1975
Volume
Dumped
(kg)
13
386
674
12
Total
Dumped
(Z)
1
36
62
1
1,085
1
2
1,622
1
1
1
98
1
1,626
166
199
418
2
21
25
53
1
785
18
141
7,087
33
<1
2
97
<1
7,279
1976
Volume
Dumped
(kg)
2
104
822
Total
Dumped
(Z)
<1
11
89
928
3
1
960
<1
<1
99
964
129
110
332
23
19
58
571
25
41
3,165
1
1
98
3,231
1977
Volume
Dumped
(kg)
2
13,663
38
96
Total
Dumped
(Z)
<1
89
1
1
15,336
1
4
<1
<1
10
40
5
5
10
138
7,315
59
413
2
91
1
5
8,009
163
20,796
27
133
<1
89
<1
<1
23,382
1978
Volume
Dumped
(kg)
8
12,573
229
200
13,010
3
6
1
1
Total
Dumped
(Z)
<1
97
2
1
27
55 .
9
9
11
40
11,119
133
287
1
96
1
2
11,579
77
51,800
83
580
<1
98
<1
1
52,540
w
I—•
o
-------
TABLE B-7
AVERAGE METAL CONCENTRATIONS IN WASTES AT THE 106-MILE SITE
Metal
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Seawater
Concentration
2-3
0.15
1
3.0
0.03
0.05-0.19
5-7
10
Reference
Kopp, 1969
Fleischer et al . , 1974
EPA, 1976
Hero, 1964
Home, 1969
Robertson et al . , 1972
NAS, 1974
EPA, 1976
American Cyanamid
Mean
620
4
550
350
120
30
1,100
560
Range
20-2,600
1-150
45-4,900
1-4,100
1-1,000
1-200
145-6,400
7-5,150
Du Font-Edge Moor
Mean
140
320
270,200
3,250
40,540
30
29,060
100,960
Range
5-525
20-900
52,600-900,000
4-7,400
2,700-76,000
<1-500
200-65,000
110-530,000
Du Pont-Grasselli
Mean
7
170
330
3,150
900
7
730
540
Range
1-30
3-700
10-3,500
25-154,700
10-4,900
<1-20
30-2,000
30-2,700
Mixed Industries
Mean
30
3,200
21,170
10,900
8,840
300
4,900
163,800
Range
1-130
20-15,600
4-170,000
1-115,000
8-62,000
21-3,830
20-31,500
15-1,400,000
-------
TABLE B-8
pH, SPECIFIC GRAVITY, AND PERCENT SOLIDS
IN INDUSTRIAL WASTE DUMPED AT THE 106-MILE SITE
Permittee
American Cyanamid
Du Pont-Edge Moor
Du Pont-Grasselli
Merck
PH
Mean
5.0
0.6
12.9
Range
2.7 - 8.3
0.1 - 1.0
12.4 - 13.6
5-7
Specific Gravity
Mean
1.028
1.135
1.109
1.28
Range
1.015 - 1.055
1.085 - 1.218
1.036 - 1.222
-
Percent
Solids
0.03
0.16
0.07
0.08
TABLE B-9
CHARACTERISTICS OF TYPICAL
SEWAGE SLUDGE DIGESTER CLEANOUT RESIDUE*
Specific gravity
Total solids (mg/liter)
Volatile solids (mg/liter)
Petroleum hydrocarbons (mg/liter)
Liquid cadmium (mg/liter)
Solid cadmium (mg/kg)
Liquid mercury (mg/liter)
Solid mercury (mg/kg)
1,016
52,400
38,500
16
0.2
45
0.002
0.39
*From the barge analysis of Nassau County sewage
sludge dumped on 10/26/78.
DU PONT-GRASSELLI
The principal process generating the Du Pont-Grasselli waste is the
production of DMHA (N,0-dimethylhydroxylamine) and anisole. The Grasselli
plant is authorized to dispose of approximately 295,000 metric tons annually
(Table B-2). Disposal is accomplished by subsurface release of the waste at a
rate not exceeding 200,000 liters (52,000 gallons) per nautical mile. This
rate permits complete dumping of an average barge load of 1.5 million liters
in approximately 70 minutes (assuming a barge speed of 6 knots), over a linear
distance of approximately 7.4 nmi.
B-12
-------
The major trace metals present in Grasselli waste, in decreasing order of
input volume, are: copper, lead, nickel, zinc, chromium, and mercury.
The organic portion of the Grasselli waste is composed of sodium methyl
sulfate (up to 50% of the organic phase), methanol (20%) and
N,0-dimethylhydroxylamine (DMHA) plus other amines (1%). The remainder is in
the form of phenols, anisole, and other compounds.
DMHA has been monitored in the Grasselli waste since 1975. Concentrations
have ranged from 20 to 364 mg/liter, averaging approximately 115 mg/liter.
Annual inputs average 17,000 kg annually, ranging from 10,000 kg in 1978 to
27,800 kg in 1977. Since the first report of volumes of the compound in 1975,
Du Pont-Grasselli has released 69,000 kg of DMHA at the 106-Mile Site.
Monitoring of anisole also began in 1975. Concentrations in the Grasselli
waste have ranged from 1 to 14 mg/liter, averaging approximately 5 mg/liter.
Annual volumes have ranged from 600 kg in 1978 to 1,700 kg in 1975. The
average annual input is 900 kg. The Grasselli plant has released
approximately 3,000 kg of anisole at the 106-Mile Site since 1975. Du Pont-
Grasselli is the only known source of anisole at this site.
Phenols have been monitored in the Grasselli waste since 1973.
Concentrations have ranged from 0.2 to 3,550 mg/liter, averaging 209 mg/liter.
Yearly inputs have ranged from 200 kg in 1978 to 204,000 kg in 1975. The
average annual input of phenols by Grasselli is 45,000 kg. Du Pont-Grasselli
has disposed of approximately 226,000 kg of phenols at the 106-Mile Site since
1973.
TOXICITY
Results of bioassay tests, which were conducted between 1973 and 1977, show
that the toxicity of Grasselli waste to brine shrimp (Artemia salina) has
varied between 48-hour LC50 values of 3,250 to 100,000 ppm. This variation
may be due primarily to a change from nonaeration to aeration of the samples
rather than to changes in the toxicity of the material. Bioassays conducted
B-13
-------
since 1977 with Atlantic silversides (Menidia menidia) yield 96-hour LC50
values ranging between 560 ppm and 6,950 ppm for aerated tests and between 660
ppm and 6,170 ppm for nonaerated tests. Bioassays on diatoms (Skeletonema
costatum) produce 96-hour EC50 values between 160 ppm and 8,600 ppm. Tests
with copepods (Acartia tonsa) give 96-hour LC50 values ranging between 57 ppm
and 238 ppm. Notwithstanding changes in required testing procedures, some of
the observed variations may be due to differences in the character of the
individual barge loads, despite originating from the same waste source.
In 1976, Du Pont sponsored an extensive series of studies to describe the
in situ dispersion characteristics and biological effects of ocean-disposed
waste waters from Grasselli plant (Falk and Gibson, 1977). The studies were
prompted by Du Font's desire to demonstrate to the EPA the validity of the
time-toxicity concept, i.e., determining the maximum length of time in which
wastes would remain at a sufficiently high concentration to cause acute toxic
effects, considering wastewater dispersion and toxicity as functions of time.
The studies demonstrated that:
(1) Under oceanographic conditions least likely to enhance dispersion,
the peak wastewater concentration in the barge wake is, initially,
about 450 ppm one minute after release.
(2) Wastewater concentrations decline to a peak of about 80 ppm within 4
hours after release, and to about 60 ppm after 12 hours.
(3) In 178-day chronic toxicity tests, the no-effect level for opossum
shrimp (Mysidopsis bahia) and sheepshead minnow (Cyprinodon
variegatus) were found to be 750 ppm.
(4) The wastewaters are not selectively toxic to a particular life stage
of Cyprinodon or Mysidopsis.
(5) There is little difference in the toxicity of the wastewater to
several species of marine organisms.
These results supported the discharge of Grasselli waste into the site over a
5-hour period, at a barge speed of 5 knots, without adverse impact.
B-14
-------
DILUTION AND DISPERSION
Mixing of waste with seawater is a function of prevailing meteorological
and oceanographic conditions. After discharge from the barge, immediate
mixing (within the first 15 minutes) occurs primarily as a result of
barge-generated turbulence. After immediate mixing, wind, waves, currents,
and density stratification components dictate the rate and direction of
dispersion and dilution.
Bisagni (1977b) studied the behavior of Du Pont-Grasselli wasted dumped at
the 106-Mile Site in June, 1976, using Rhodamine-WT dye mixed with the waste
as a tracer. Water column profiles showed that the surface mixed layer
extended down to a depth of 20 m. Below the surface mixed layer, a seasonal
thermocline was found between 20 and 50 m depth. The permanent thermocline
was between 200 and 350 m depth. The waste remained in the upper 60 m of the
water column.
The initial concentration of the undiluted waste within 15 minutes after
release was 19.3 ppra. Water samples collected within an hour of commencement
of dumping indicated that the dilution ranged from 18,000:1 to 4,600:1. After
70 hours, dilution was estimated to range from 210,000:1 to 45,000:1. During
a second dilution study performed in June, minimum factors of 54:1 to 100:1
occurred within 10 minutes after the dumping had begun. After 30 hours, a
dilution of about 110,000:1 was estimated.
Orr (1977a) tracked the precipitate formed by the Grasselli waste during
June and September, 1976, using a multifrequency acoustic backscattering
system. In June, a sharp density gradient in the water column was at a depth
of 10 m. The data indicated that the particulates separated into two
components: a lighter phase which was trapped in the upper 10 to 20 m of the
water column, and a heavier phase which sank to the base of the mixed layer.
These phases were observed to behave in two different ways: collecting in a
thin layer on an isopycnal surface (i.e. a plane surface of equal density) or
appearing as a diffuse cloud within patches of water having nearly constant
density.
B-15
-------
The study conducted in September, 1976, by Orr (1977a) used an acoustic
system with improved sensitivity. In this study, acoustic and dye
measurements were collected simultaneously. The waste was observed to spread
2 2
over an area of 4 nmi (13.7 km ) by both methods. The results of this study
show that the residence time of the suspended matter can exceed 24 hours. The
particulates were heavily concentrated in the upper 15 m of the water column.
The waste settled from an initial uniform distribution to collections of
particles in dense layers. The particles which were trapped in the seasonal
thermocline outlined the associated isopycnal surfaces, and were from 15 cm to
5 m in thickness. In at least one instance, particulates associated with the
seasonal thermocline were observed to have penetrated it and appeared as a
diffuse cloud extending down to a depth of nearly 80 m. The data also
indicated that particles which penetrated the seasonal thermocline and were
trapped at the base of the mixed layer, spread horizontally much faster than
particles trapped by the seasonal thermocline.
Kohn and Rowe (1976) studied the dilution and dispersion of Du Pont-
Grasselli waste during September, 1976, using Rhodamine-WT dye as a tracer.
Dispersion of the waste was monitored by means of two fluorometers, one
drawing water from a depth of 5 m and the other drawing from a depth of 10 m.
Data were gathered for a period of 19 hours following the start of discharge.
The initial dilution of the waste was 4250:1 at 5 m, while after 17 hours the
dilution was 12,500:1. The waste plume movements following the dump were
estimated on the basis of the movements of "window shade" current drogues and
from fluorometer readings. In general, the plume moved in a semicircular
path, returning to the starting position after about 20 hours. The Du Pont
waste was observed to pass through the upper 5 m of the water column and
stabilize between 10 m depth and the top of the thermocline.
Falk and Gibson (1977) described a dye dispersion study conducted by EG&G
on the Grasselli waste in September, 1976, during a time when ambient
conditions at the 106-Mile Site were least conducive to waste dispersion
(i.e., calm seas, light winds, strong thermocline present). The results of
the survey indicated that the waste material was limited to the surface mixed
layer by the strong thermocline. The horizontal extent of the waste ranged
from 35 m in width initially, to 300 m after 2 hours, to 600 m after 8 hours,
B-16
-------
and to 1,000 m after 11 hours. Minimum waste dilutions were 5,000:1
initially, 15,000:1 after 2 hours, and 15,000 to 30,000:1 after 11 hours. The
average waste dilutions were 10,000:1 initially, 20,000 to 40,000:1 after 2
hours, and 30,000 to 80,000:1 after 11 hours.
Hydroscience (1978c, 1978d, and 1979d) monitored dumps of Grasselli waste
in May, July, and October 1978. In all surveys, the wastewater concentration
after 4 hours was well below the chronic no-effect level for appropriate
sensitive marine organisms of 750 ppm, a dilution of 1,300:1.
DU FONT-EDGE MOOR
Du Font-Edge Moor waste is generated by the manufacture of titanium dioxide
using the chloride process. The waste consists principally of an aqueous
solution of iron and miscellaneous chlorides, and hydrochloric acid.
Du Font-Edge Moor is authorized to dump approximately 299,000 metric tons
during 1979 and 136,000 metric tons during 1980 (Table B-2). Disposal of the
was,te is accomplished by subsurface release at a rate not exceeding 140,045
liters (37,000 gallons) per nautical mile. This rate permits complete
dumping of an average barge load of 3.8 million liters of waste in approxi-
mately 4.5 hours (assuming a barge speed of 6 knots), over a linear distance
of approximately 27 nmi (50 km).
Ten trace metals are usually reported in the analyses of Du Font-Edge Moor
waste. These are, ranked by decreasing input volume: iron, titanium,
chromium, vanadium, zinc, lead, nickel, copper, cadmium, and mercury. Organic
components are present in insignificant amounts of Edge Moor waste
(Table B-4).
TOXICITY
Bioassays conducted since 1977 with Atlantic silversides (Menidia menidia)
yield 96-hour LC50 values greater than 5,000 ppm for aerated tests and between
5,000 ppm and 14,400 ppm for nonaerated tests. Bioassays on diatoms
(Skeletonema costatum) produce 96-hour EC50 values between 712 ppm and
3,450 ppm.
B-17
-------
In 1976, Du Pont sponsored an extensive series of in situ studies to
describe the dispersion characteristics and biological effects of ocean
disposed waste waters from the Edge Moor plant (Falk and Phillips, 1977). The
dispersion studies were conducted at the Delaware Bay Acid Waste Disposal
Site.
A series of laboratory toxicity experiments conducted with the Du Pont-Edge
Moor wastes gave the following results:
1. In 200-day chronic toxicity tests, no-effect levels for opposum
shrimp (Mysidopsis bahia) and sheepshead minnow (Cyprinidon
variegatus) were found to be in the range of 25 to 50 ppm.
2. pH-adjusted waste produces mortalities only at concentrations
several orders of magnitude above the unaltered waste.
3. Pulsed exposure of grass shrimp (Palaemonetes pugio) to initial
wastewater concentrations of 250 ppm, followed by dilution slower
than that observed in the barge wake, produced no mortalities.
4. Maximum waste concentrations in the barge wake were calculated to be
approximately 150 ppm within 2 hours, and about 5 ppm within eight
hours. The two-hour calculated wake concentrations is well below
the acute LC50 value range of 240-320 ppm and the eight-hour wake
concentration is well below the calculated chronic no-effect level
of 25 to 50 ppm for unaltered waste.
Based upon these results, Falk and Phillips (1977) reached the conclusion
that the Edge Moor wastewaters can be discharged into the marine environment
over a 5-hour period, at a barge speed of 6 knots, without adverse impact, and
without violating the requirements of Section 227.8 of the EPA Ocean Dumping
regulations.
DILUTION AND DISPERSION
In September 1976, EG&G conducted a dispersion study of Edge Moor
wastewater at the Delaware Bay Acid Waste Site (EG&G, 1977). A well-defined
thermocline was present at a depth of 20 m, winds were blowing at 8 to
12 m/sec (15.5 to 23.2 kn), and waves were 1 to 2 m. The waste concentrations
were monitored over 8 hours using pH and iron concentrations. Minimum
B-18
-------
dilutions were 7,000:1 within 2 hours and 200,000:1 within 8 hours. The
2-hour concentration was well below acute LC50 values reported for the
organisms tested, and the 8-hour concentration was well below the chronic
no-effect level of 25 to 50 ppm (dilutions of 40,000:1 and 20,000:1,
respectively).
In May 1978, Hydroscience, Inc. (1978a) studied the dilution and dispersion
of the Du Font-Edge Moor waste following its release at the site. A weak
thermocline was present at a depth of 13 m. Based upon a comparison of
undiluted and post-dumping (after 4 hours) seawater concentrations of
particulate iron, minimum dilutions were estimated at 75,000:1. Measurements
indicated that the Du Font-Edge Moor waste did not significantly penetrate the
seasonal thermocline and the waste was diluted and dispersed only within the
upper 13 m of the water column. Surveys conducted during July and October did
not yield dilution values; however, the waste was estimated to have been
diluted below the chronic no-effect level (Hydroscience, 1978b, 1979a). These
observations are compatible with observations made at the Delaware Bay Acid
Waste Site while Edge Moor was still dumping its waste there (Falk and
Phillips, 1977).
AMERICAN CYANAMID
American Cyanamid produces industrial wastes which are generated during the
manufacture of approximately 30 different organic and inorganic compounds.
The broad categories which comprise the waste are approximately 25% chemical,
35% equipment and floor wash, 25% vacuum jet condensate and 15% from overhead
and bottom distillate units. The chemical products manufactured include
rubber, mining and paper chemicals; nonpersistent organophosphate
insecticides; surfactants; and various intermediates.
American Cyanamid is authorized to dispose of approximately 123,000 metric
tons annually (Table B-2). Disposal is accomplished by subsurface release of
waste through automatic and/or manual vent valves at a rate not exceeding
113,500 liters (30,000 gallons) per nautical mile. This rate permits complete
offloading of an average barge load of 1.5 million liters of waste in
approximately 2 hours (assuming a towing speed of 6 knots), over a linear
distance of approximately 13.5 nmi (25 km).
B-19
-------
American Cyanamid waste is routinely analyzed for trace metals. In order
of decreasing input volume, they are: nickel, arsenic, chromium, zinc, lead,
copper, mercury, and cadmium.
Because the American Cyanamid waste mixture is complex, it is extremely
difficult to characterize all of the organic compounds present in the waste.
Thus, the organic content of American Cyanamid waste is known only in general
terms. Table B-10 lists the various nonpersistent organophosphate
insecticides released by American Cyanamid since 1973.
TOXICITY
Results of bioassays conducted since 1977 show that the toxicity of the
waste to Atlantic silversides (Menidia menidia) has varied between 96-hour
LC50 values of 0.24 ppm to 2,900 ppm for aerated tests and between 0.10 ppm to
2,900 ppm for non-aerated tests. Bioassays conducted from 1973 to 1977 with
brine shrimp (Artemia salina) yielded 48-hour LC50 values of 670 ppm to
21,000 ppm. Bioassays on diatoms (Skeletonema costatum) gave 96-hour EC50
results which varied between 10 ppm and 1,900 ppm. Additional tests with
copepods (Acartia tonsa) gave 96-hour LC50 values which varied between 19.5
ppm and 3,500 ppm. These variations may be due to the differences in the
toxicity of the individual barge loads, although from the same waste source.
However, such variation is not outside the ranges applied to bioassay results
of this type.
DILUTION AND DISPERSION
In August, 1976, Kohn and Rowe (1976) studied the dilution and dispersion
of the American Cyanamid waste after release at the site. Enough Rhodamine-WT
fluorescent dye was added to the waste in a barge to yield an undiluted dye
concentration of 9.36 ppm. For 17 hours following the start of the waste
discharge from the barge, a continuous flow of water was pumped from a depth
of 5 m into an onboard fluorometer. The initial dilution of the American
Cyanamid waste was 115:1, and the dilution after 17 hours was 2,500:1.
B-20
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TABLE B-10
NONPERSISTENT ORGANPHOSPHATE INSECTICIDES
RELEASED BY AMERICAN CYANAMID, 1973-1978, AT THE 106-MILE SITE
Constituent
Malathion
Thimet
Counter
Abate
Cytrolane
Cygon
Cyolane
Description
General Insecticide
Systemic Insecticide
Soil Insecticide
Manufacturing
Concentrate
Insecticide
Technical Systemic
Insecticide
Systemic Insecticide
Technical Systemic
Insecticide
Metric Tons/Year
1973
188
92
0
0
15
73
0
1974
183
133
0
0
9
54
0
1975
13
12
2
0
0
12
0
1976
39
34
37
0
18
0
0
1977
117
73
28
14
3
2
0
1978
10
11
3
0
3
0
1
The waste plume movements following the dump were estimated from the
movements of "window shade" current drogues and from the fluorometer readings.
In general, the plume moved in a semicircular path, returning to the starting
position after about 20 hours. American Cyanamid waste remained in the upper
few meters of the water column.
Hydroscience, Inc. (1978e, 1978f, 1979c) studied the dilution of the
American Cyanamid waste in several seasonal surveys. Comparisons of undiluted
waste concentrations and postdump concentrations 4 hours following the dump
indicated minimum dilutions of approximately 25,000:1 in May, 14,000:1 in
July, and 9,200:1 in October. Hydroscience (1978f) studied the dispersion of
the waste in July 1978, using Rhodamine WT dye. The maximum distance that the
plume traveled from the dump location was 675 m in 4 hours, and at this point,
the concentration of the waste was near detection limits.
B-21
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MERCK AMD COMPANY
Merck's aqueous waste is generated in the manufacture of thiabendazole, a
pharmaceutical product. Previous discussion in this appendix included Merck
among the mixed industrial wastes permittees.
Merck is authorized to dispose of approximately 36,300 metric tons
annually. Disposal is accomplished by subsurface release of the waste at a
rate not exceeding 378,000 liters (100,000 gallons) per nautical mile. This
rate permits complete dumping of an average barge load of 5.7 million liters
in approximately 6 hours (assuming a towing speed of 6 knots), over a linear
distance of approximately 38 nmi (70.3 km).
The six major trace metals present in the Merck waste are, in order of
decreasing input volume: nickel, lead, vanadium, beryllium, chromium and
cadmium.
TOXICITY
Bioassays conducted on mixed industrial wastes between 1973 and 1977 with
brine shrimp (Artemia salina) yielded 48-hour LC50 values of 1,525 ppm to
100,000 ppm. Bioassays conducted since 1977 with Atlantic silversides
(Menidia menidia) give 96-hour LC50 values ranging between 650 ppm and
100,000 ppm for aerated tests, and between 150 ppm and 100,000 ppm for
non-aerated tests. Bioassays on diatoms (Skeletonema costal: urn) produce
96-hour EC50 values between 65 ppm and 12,000 ppm. Tests with copepods
(Acartia tonsa) yield 96-hour LC50 bioassay values ranging between 29.7 ppm
and 5,300 ppm. Some of the observed variations may be due to the differences
in the characteristics of the individual barge loads.
B-22
-------
DILUTION AND DISPERSION
Hydroscience, Inc. (1978g) performed the dilution study in May 1978 for the
mixed industrial waste generated by Merck and Reheis Chemical. Based upon
comparisons between the concentrations of aluminum and carbon in the barge
wastes and the concentrations of these same parameters found in the seawater
samples collected after 4 hours following the disposal, minimum dilution
factors of 20,000:1 and 52,000:1 were observed. A July 1978 survey yielded a
minimum dilution at 4 hours of 150,000:1; the plume was barely detectable at
1,000 m from the site of release. An October survey also yielded a minimum
dilution of 150,000:1 after 4 hours (Hydroscience, 1979d).
B-23
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APPENDIX C
MONITORING
-------
CONTENTS
Title Page
SHORT-TERM MONITORING C-2
LONG-TERM MONITORING C-4
TABLES
Number Title Page
C-l Short-Term Monitoring Requirements C-3
C-iii
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APPENDIX C
MONITORING
The Final EPA Ocean Dumping Regulations and Criteria (40 CFR 220 to 229)
discusses monitoring requirements (Section 228.9):
(a) The monitoring program, if deemed necessary by the
Regional Administrator or the District Engineer, as
appropriate, may include baseline or trend assessment
surveys by EPA, NOAA, other Federal agencies, or
contractors, special studies by permittees, and the
analysis and interpretation of data from remote or
automatic sampling and/or sensing devices. The primary
purpose of the monitoring program is to evaluate the
impact of disposal on the marine environment by
referencing the monitoring results to a set of baseline
conditions. When disposal sites are being used on a
continuing basis, such programs may consist of the
following components;
(1) Trend assessment surveys conducted at intervals
frequent enough to assess the extent and trends of
environmental impact. Until survey data or other
information are adequate to show that changes in
frequency or scope are necessary or desirable,
trend assessment and baseline surveys should
generally conform to the applicable requirements
of Section 228.13. These surveys shall be the
responsibility of the Federal government.
(2.) Special studies conducted by the permittee to
• identify immediate and short-term impacts of
disposal operations.
(b) These surveys may be supplemented, where feasible and
useful, by data collected from the use of automatic
sampling buoys, satellites or in situ platforms, and
from experimental programs.
(c) EPA will require the full participation of other
Federal and State and local agencies in the development
and implementation of disposal site monitoring
programs. The monitoring and research programs
presently supported by permittees may be incorporated
into the overall monitoring program insofar as
feasible.
C-l
-------
Further in Section 228.10, the Ocean Dumping Regulations delineate specific
types of effects upon which monitoring programs must be built:
(1) Movement of materials into estuaries or marine
sanctuaries, or into oceanfront beaches, or shorelines;
(2) Movement of materials toward productive fishery or
shellfishery areas;
(3) Absence from the disposal site of pollution-sensitive
biota characteristic of the general area;
(4) Progressive, non-seasonal, changes in water quality or
sediment composition at the disposal site, when these
changes are attributable to materials disposed of at the
site;
(5) Progressive, non-seasonal, changes in composition or
numbers of pelagic, demersal, or benthic biota at or near
the disposal site, when these changes can be attributed to
the effects of materials disposed of at the site;
(6) Accumulation of material constituents (including
without limitation, human pathogens) in marine biota at or
near the site.
Thus, the regulations identify two broad areas which must be taken into
account in monitoring:
(a) Short-term or acute effects immediately observable and monitored at
the time of disposal, and before disposal of the waste itself.
(b) Long-term or progressive effects measurable only over a period of
years and indicated by subtle changes in selected characteristics
over time.
SHORT-TERM MONITORING
The permit program administered by EPA Region II has provided the means for
monitoring immediate effects of disposal. The program acts as an important
check on the variable chemical characteristics of the waste, the biological
influence as measured by bioassays and the cumulative totals of known
potential toxicants (see Appendix B, Tables B-5, B-6, and B-7). This program
provides information about the environment at the time of disposal and the
dispersion and dilution of the wastes under varying oceanographic conditions.
Table C-l summarizes the parameters measured at sea for each permittee.
C-2
-------
TABLE C-l
SHORT-TERM MONITORING REQUIREMENTS
Permittee
Parameter to be Monitored
General
All Dumpers
Temperature
Dissolved oxygen to 100 m
Conductivity
pH
Chlorophyll £
Total mercury
Total cadmium
Total organic carbon
1, 15, 30 m
Merck
Du Pont-Grasselli
Du Pont-Edge Moor
American Cyanamid
Secchi disk to extinction point
Special
Sulfonate
Phenol
Total Kjeldahl nitrogen
Total iron
Total vanadium
Pesticides in the waste at the
time of the dump
In 1978, three seasonal surveys were made at the site:
• May - no upper thermocline
• July - strong upper thermocline (28 m)
• October - weak upper thermocline (68 m)
A dye dispersion study was made for each waste type during the July survey
(see Appendix B, page B-13, for results). For each survey a drogue was set at
the thermocline in the waste plume, where the wastes were expected to
accumulate. Samples were taken at 4-, 6-, 8-, and 10-hour intervals at
various depths (Table C-l). Two stations were sampled immediately before the
waste release to establish the background levels. Samples from the barge were
analyzed for the same parameters, so that minimum dilution factors could be
calculated.
C-3
-------
This program will be continued as one of the permit requirements. The
sampling program is the minimum design sufficient to detect changes resulting
from the disposal of chemical wastes. The effects documented at the site are
transitory (see Chapter 4), and have not caused measurable long-term damage to
populations of organisms indigenous to the site or adjacent areas. This
sampling program periodically confirms that the wastes are diluted well below
the chronic "no-effect" concentrations (as determined by the monthly
bioassays) within the allowable short period of initial mixing.
The physical and chemical variables monitored were chosen, based upon the
composition of the wastes and the possible effects of waste discharge. Water
column sampling is adequate to detect unusual, adverse effects of disposal;
benthic samples are not required since the wastes apparently do not penetrate
the thermocline, and would not reach the bottom in measurable amounts at this
deep site. Therefore, no changes in the existing permittee monitoring program
are recommended.
LONG-TERM MONITORING
As discussed in Chapter 3 and Appendix B, extensive research effort has
been directed to determine the fate of wastes released at the 106-Mile Site.
Nevertheless, there are many aspects of waste disposal at this site which are
poorly understood and which must be refined before a meaningful trend
assessment and long-term monitoring program can be accomplished. Studies must
provide further information on the following factors:
• The penetration of seasonal and permanent thermoclines by different
wastes
d The fractionation of wastes in the water column and the association
of potentially toxic substances with different fractions
• The fate of wastes related to Gulf Stream eddies and general current
patterns
• The refinement and selection as monitoring tools of acoustical
tracking, dye or trace metal dispersion data, and organic markers
(methyl sulfate)
C-4
-------
Studies on these and other important aspects of monitoring at the 106-Mile
Site are part of a continuing effort of NCAA's Ocean Dumping Program (National
Ocean Survey), supplemented by permittee-supported work.
Further impetus to a formal monitoring program resulted from the passage of
PL 95-273, which empowers NOAA to develop a five-year plan for ocean pollution
research and monitoring. On a broader scale of time and space, the "Ocean
Pulse" program of the National Marine Fisheries Service should provide
valuable monitoring data. Thus, long-range monitoring and trend assessment of
waste disposal in complex deep oceanic regions (e.g., the 106-Mile Site) are
feasible only through the combined resources of several agencies under the
future NOAA five-year plan.
C-5
-------
APPENDIX D
CHAPTER III, FINAL EIS ON OCEAN DUMPING
OF SEWAGE SLUDGE IN THE NEW YORK BIGHT
-------
CONTENTS
Title
ALTERNATIVES TO THE PROPOSED ACTION
OCEAN-DUMPING ALTERNATIVES ....
LAND-BASED ALTERNATIVES
ILLUSTRATIONS
Number Title Page
8 Coliforms in New Jersey Coastal Waters D-4
9 Coliforms in Long Island Coastal Waters D-5
D-iii
-------
APPENDIX D
CHAPTER III, FINAL EIS ON OCEAN DUMPING
OF SEWAGE SLUDGE IN THE NEW YORK BIGHT
This Appendix is Chapter III of the Final Environmental Impact Statement on
sewage sludge dumping in the New York Bight (EPA, 1978). It is reproduced
here to document the earlier considerations of using the 106-Mile Site as an
alternate sewage sludge site. Included are discussions on land-based
alternatives to ocean dumping of sewage sludge.
ALTERNATIVES TO THE PROPOSED ACTION
Alt*MTMM\es ni the proposed airtion considered in this EIS Mil into two categories: other oc ean-dumpinx
alternates i-liort-tfrrni and land-based sludge disposal alternatives (lonj<-term).
Since implementation of land-based disposal methods in the metropolitan area is still some years off, a
suitable interim ocean dumping alternative is needed. In addition to the proposed action, the ocean-dumping
alternatives are:
— Continued use of the existing dump site (No Action or Phased Action),
— Use of an alternate dump site other than the Northern or Southern Area, including sites off the
continental shelf, and
— Modification of dumping methods to mitigate potential marine and shoreward impacts.
The land-based sludge disposal alternatives are:
— Direct land application,
— Incineration,
— Pyrolysis, and
— Use as a soil conditioner.
These land-based alternatives have been studied by the Interstate Sanitation Commission (ISO under a grant
from EPA. The ISC sludge disposal management program was issued in October 1976. Since that time, EPA
has awarded grants to most of the ocean dumping permittees for specific studies of land-based sludge
management alternatives within their geographic areas. The EPA has also placed a condition on the ocean
dumping permits issued in August 1976, requiring that ocean dumping be phased out by December 31,
1981. This phase-out date was legislatively mandated in November 1977, by amendment to the Marine
Protection Research and Sanctuaries Act of 1972.
Alternatives to the proposed action are discussed in Chapter III.
D-l
-------
CHAPTER III
ALTERNATIVES TO THE PROPOSED ACTION
Generally, sewage sludge can be either dumped in the ocean or disposed of by land-based methods.
The latter constitute the only legitimate long-range solution to the New York-New Jersey metropolitan area's
sludge disposal problem, and they will have to be implemented as ocean dumping is phased out. The back-
ground studies for land-based sludge disposal management in the metropolitan area were completed by ISC
in 1976. The testing and implementation phases have begun. Current predictions are that land-based sludge
disposal methods can be implemented in time to meet the December 31. 1981 deadline for phasing out
ocean dumping of sewage sludge.
Until this full-scale, land-based sludge disposal program can be implemented, however, ocean dumping
will continue to be the only practical method of disposing of the volumes of sludge produced in the metro-
politan area. Within the ocean-dumping alternative, options are available with regard to where the sludge is
dumped and how it is dumped. The proposed action, immediate designation and use of an alternate dump
site in either the Northern or Southern Area is described in detail in Chapter IV. Chapter III discusses the
other ocean-dumping alternatives and summarizes the results of the ISC studies of land-based sludge disposal
methods.
OCEAN-DUMPING ALTERNATIVES
In addition to the proposed action, the ocean-dumping alternatives considered in this EIS are: 1 >
continued use of the existing dump site (No Action and Phased Action). 2) use of an alternate dump site
other than the Northern or Southern Area, and 3) modification or dumping methods to mitigate potential ma-
rine and shoreward impacts. The phasing out of ocean dumping by the end of 1981 would not be compro-
mised under anv of these alternatives.
Continued Use of the Existing Dump Site
The NO Action alternative involves continued use of the existing dump •xte until land-based methods of
sludge disposal can be implemented. Under this alternative, the existing dump site would have to accommo-
date in 1981 more than one and a half times the volume of sludge dumped in 19*7; moreover, the site
would have to accommodate the increased volume without endangering public health or the marine envi-
ronment. The primary argument for the No Action alternative is that it limits environmental impacts to the
existing site rather than spreading them to another area of the marine environment.
The original argument for moving the sewage sludge dump site was that greatly increased volumes of
sludge might impair the recreational quality of Long island and New Jersey's beaches. As discussed below,
Current studies tend to show that this argument is largely invalid, lending support to the NO Action alterna-
tive.
A variation on the No Action alternative is the Phased Action alternative, under which sewage sludge
would continue to be dumped at the existing site until a comprehensive monitoring program indicated an
impending hazard to public health or damage to recreational water quality. Under the phased alternative, an
alternate dump site would have to be designated and held in reserve for possible future use. Since this
alternative would maximize use or the existing dump site, adverse impacts on an alternate dump site would
be minimized, and sludge hauling costs would not be increased unnecessarily.
D-2
-------
This was the alternative recommended in the draft EIS. However, when the fish kill and beach closure
incidents discussed in Chapter II occurred, doubts were raised aboui the acceptability of continuing to use
the existing dump site. Studies of the fish kill and beach closure incidents found that sludge dumping was at
most a minor contributing factor. Those findings were reconfirmed at a public hearing held in Toms River,
New Jersey, on May 31 and June 1, 1977, to consider possible relocation of the New York and Philadelphia
sewage sludge dump sites. On the basis of the evidence presented, the hearing officer recommended (hat
neither dump site be moved.
With specific reference to sludge dumping in the New York-New Jersey metropolitan area, the hearing
officer also recommended: 1) strict enforcement of existing phase-out schedules and deadlines, 2) inclusion
in the sludge dumping EIS being prepared by EPA-Region II of specific criteria for determining the need for
relocation or the dump site, 3) intensified monitoring of the existing dump site, and 4) immediate designation
of the alternate 60-mile site (this would be the site in the Northern Area recommended in the draft EIS). The
report of the Toms River hearing officer, which was issued on September 22, 1977, is presented in Appendix
C.
On March 1, 1978, the EPA's Assistant Administrator for Water and Hazardous Materials issued his
decision on proposals to relocate the New York and Philadelphia sewage sludge dump sites. The decision
report is presented in Appendix D. In all important respects, the Assistant Administrator's decision is in
agreement with the findings, conclusions, and recommendations of the Toms River hearing officer:
It is my determination that sewage sludge dumping by these municipalities [in the New York-New Jersey
metropolitan area) should not be relocated at the present time; however, efforts should begin immedi-
ately to designate the 60-mile site for the disposal of New York/New Jersey sewage sludge in the event
such sludge cannot be dumped at the New York Sight site for public health reasons prior to December
31, 1981.
In accordance with this decision, EPA intends to designate the existing site for continued use, as well as
the 60-mile site in the Northern Area for possible future use. An intensified monitoring program has already
been implemented; it is described in detail in the Monitoring and Surveillance section of Chapter XI. Criteria
that can be used to determine whether public health reasons require moving sludge dumping operations
from the existing to the alternate site at any time between now and December 31, 1981 have been drawn
up bv EPA-Region II, and are presented in Appendix E. Finally, a Regional Enforcement Strategy, designed to
insure that ocean dumping of sewage sludge is replaced by environmentally acceptable land-based disposal
methods b\ the legislatively mandated deadline of December 31, 1981, has been developed by EPA-Region
II. and is presented in Appendix F.
EPA Monitoring Studies. In April 1974, EPA initiated a program to investigate the quality of the water
and bortom sediments in the New York Sight and along the Long Island and New Jersey beaches (USEPA,
Julv 1974, April 1975). Data from the surf and near-shore waters indicate that water quality remains ex-
cellent in terms of total and fecal coliform density, and that it is acceptable for contact recreation (Figures 8
and 9> Although the data show a few random elevated coliform counts, no violation of state standards is
indicated nor does there appear to be any systematic degradation of water quality. Sediment data indicate
slightly elevated bacterial counts at certain near-shore sampling stations, but these can be attributed to inland
runoff or to wastewater outfalls.
Sampling is continuing along transects between the existing dump site and the following points: the
Long Island shore, the entrance to New York Harbor, and the New Jersey shore. Results to date indicate that
a clean water and sediment zone, about 10 to 11 km (S.S to 6 n mi) wide, separates the area affected by
sludge from the Long Island coast. As a supplement to the sampling program, EPA has expanded the moni-
toring and review process to insure protection of public health and welfare and prevention of coastal water
quality degradation (see the Monitoring and Surveillance section of Chapter XI).
NOAA-M6SA Studies. On the basis of two comprehensive reports prepared by NOAA-MESA (March
197S. February 1976), there seems to be no significant accumulation of sewage sludge at the existing dump
site, although some sludge particles may be mixing with natural fines in the Christiansen Sasin, northwest of
D-3
-------
k
A
2
2
GEOMETRIC MEAN
NUMBERS
3
3
3
2
3
37
••25
• 19
13
116
50
GEOMETRIC MEAN
NUMBERS
22
11
ill
15
Ml
STAT'ONS
NEV JERSEY
STATE -STANDARD
16
16
• 10
NO NEW JERSEY
STATE STANDARD
40 40 20 0 20 40 *0
FECAL COLJFORM TOTAL COL I FORM
(MPM/100 ML) (MPN/100 ML)
COLJFORMS IN NEW JERSEY COASTAL WATERS
K1LQMCTCXS
10 20
SOURCE: USEPA, APRIL 1375-
Ml US (STATVTt)
:o
Ml t.£S
D-4
FIGURE 3
-------
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V
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-I
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STATIONS
GEOMETRIC MEAN
NUMBERS
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I
18 15 17
GEOMETRIC MEAN
NUMBERS
NEW JfKSEY
- lio
- 100
o
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2S002
-------
the site. Both reports also note that the general ecological *rrV( ts ui si-wage sluice dumping .irv iiidis(mBuish-
able from those associated with other sources of pollutants in the Bight Apex uhe dumping of dredged
material and acid wastes, contaminants from the plume (if the Hudson estuary, shore-zone pollutant con-
tributions, and atmospheric fallout of contaminants).
However, sludge dumping does exert significant local effects. The catch of groundfish appears to be
reduced in areas with higH-carbon sediments, such as the area of the existing sludge dump site. Furthermore,
it is apparent that very few surf clams reach commercial size within the area now impacted by sludge
dumping. Although some fish in the Bight Apex are afflicted with fin rot. this disease is not thought to be
attributable solely or even primarily to sludge dumping.
The NOAA-ME5A reports do not indicate anv shoreward movement of coliform contamination as a
result of sludge dumping at the existing site, but thev do note the apparent persistence of coiiform bacteria in
the vicinity, especially in bottom sediments. There is no evidence that under current FDA regulations the
cessation of sewage sludge dumping at the existing site would permit reopening of the immediate area to
shdlfishing. The complete text of NQAA-VlESA'i conclusions and recommendations from the February 1976
report is presented in Appendix C.
At the Toms River hearing in 1977, NOAA concurred with EPA's recommendation of continued use of
the existing dump site based on the fact that there is no demonstrated need for relocation (see Appendix C).
Related Studies. The most recent study of the area (Mueller et at., 1976) indicates that sludge dumping
accounts for 0.04 to I1 percent, at most, of the total pollutant loading in the Bight Apex; pollutant loadings
from non-dumping sources iwastewater discharges, runoff, and atmospheric fallout) far outweigh those from
all current ocean-dumping sources (sewage sludge, dredged material, acid wastes, and cellar dirt).
A study bv the Town of Hempstead (1974) supports the conclusion that sewage sludge dumped at the
existing site does not significantly affect the quality of the waters or beaches or Long island.
Use of an Alternate Dump Site Other Than the Northern or Southern Area
Besides the Northern and Southern Areas, possible locations for an alternate sewage sludge dump sice
include: the other existing dump sites in the Bight Apex (the dredged material, acid wastes, cellar dirt, and
wreck sites); other areas in the New York Bight; and an-js off the continental shelf, notablv the chemical
wastes dump site. These locations are discussed below.
Other Existing Dump Sites in the Bight Apex. Dumping sewage sludge at one of the
other existing sites in the Bight Apex (the dredged material, aud wastes. rHIar dirt, or \\reck site) would
violate the original concept of segregating wastes b\ dump site. X would be extremely difficult to isolate the
true cause of adverse environmental effects at a site where two or more types of wastes were dumped. The
end result would probably be several seriously contaminated dump sites in the Bight Apex, instead of the
two that now exist (the sewage sludge and dredged material sites) Use of the existing dredged material site
for sludge dumping would be particularly ill-advised because the site is only about 9 km 15 n m» from the
New Jersey shore: the existing sludge dump site is about 20 km (11 n mi) offshore.
Other Areas in the New York Sight. Solely in terms of minimizing potential environmen-
tal impacts; a Site located offshore. 148 to 153 km i30 to 85 n mil rrom the Sandy Hook-Sockawav Point
transect, and within the depression of the Long Island Shelf Vallev. about 80 m i264 ft) deep, would be pref-
erable, in this area, the tendency is towards bottom transport off the continental shelf, which would mini-
mize the potential for sludge transport to adjacent biological resource are.is. including the Hudson Shelf
Valley and near-shore shellfisheries. In addition, the greater depth would provide maximum dilution and
dispersion of the sludge, minimizing any adverse effects.
The one major drawback to use of this area is that it is beyond the maximum 1 20 km i65 n mil range
of the existing barge fleet. It would be difficult to justify the greatlv increased costs of transportation and
possible fleet capitalization in terms of concomitant benefits. Benefits to public health would not increase
proportionally with distance. Both the Northern and Southern Areas appear to be far enough from the Long
D-6
-------
Island and New Jersey coasts, and in deep enough water, to minimi;? potential impact) on public health and
marine life.
Areas Off the Continental Shelf. In the draft EIS. the alternative or dumping sewage sludge in areas
off the continental shelf, such as at the existing chemical v\asie> dump site, wa* quickK dimmed because or
the prohibitive transportation costs and because ot the unknown effects ol dumping sewage sludge m those
waters. Developments since that time, the 1976 fish kill and beach closure incidents isee Chapter Hi and the
1977 public hearing on possible relocation of sludge dump sites (see Appendices C and Oi. have indicated
the need for a more extensi\ e evaluation of this alternative.
The decision report issued by EPA-Headquarters on proposals to relocate the New York and Philadel-
phia sewage sludge dump sites specifies six major factors that must be considered in determining the feasibil-
ity of using an off-the-shelf site for sewage sludge disposal: known environmental acceptability, ability to
monitor impact, surveillance of dumping activities, economic burden, logistics, and the effect of utilizing
such a site on the ability of dumpers to meet the December 31, 1981 deadline for the termination of harmful
sewage sludge dumping (Appendix D). Briefly, the chemical wastes site does not appear favorable on any of
these six counts. The environmental acceptability of dumping sewage sludge there is unknown, and scientific
opinion by and large recommends against use of this site for sludge dumping. Monitoring and surveillance
capabilities are substantially reduced, primarily because of the great distance to the chemical wastes site.
Distance is also the primary factor in making the chemical wastes site economically and logistically disadvan-
tageous. The prohibitive cost in turn diminishes the ability of dumpers to meet the 1981 deadline by divert-
ing the available economic resources from the development of acceptable land-based disposal methods.
Each of these factors is explored in more detail below.
Environmental Acceptability - Although the MPRSA recommends that the dumping of wastes be
done in areas off the continental shelf, wherever feasible, the limited information available on this area
suggests otherwise. At a 1971 ocean disposal conference, cosponsored by the Woods Hole Oceanographic
Institution IWHOI) and the COE, the panel on biological effects stated:
Disposal should not occur in the deep sea. i.e. beyond the continental shelf. A fundamental reason for
this suggestion is the following. The deep sea is an area where biological decomposition rates are ap-
parently very low in comparison with other ocaan regions. It is an area of great constancy with respect to
the physical-chemical environment and it is thought that the fauna living there is finely tuned to small
environmental changes. Thus, the fauna may be quite susceptible to large environmental perturbations
such as might be expected with the introduction of dredge spoils. If deleterious effects occur m the deep
sea, the opportunities to alter the course df events is [sic] minimal. We therefore suggest that the deep
sea should be off limits for disposal activities at least until other information is brought to bear wnich
would render the possible dangers non-existent. (WHO), 1971).
A simitar view was expressed at a 1974 workshop at Woods Hole, sponsored by the National Acad-
emy of Sciences (NAS):
Data for the evaluation of the deep sea as a disposal site are inadequate. This is due to: difficulties in
conducting bioassays: slow rates of mixing and diffusion potentially resulting in anaerobic conditions:
slow organic degradation: and narrow tolerance ranges for sensitive assemblages of organisms. Al-
though the area is relatively stable in comparison to the shelf and nearshore. the much greater scientific
uncertainty, and consequently increased risk associated with off-shelf disposal, dictate that any but the
most innocuous use of the area should be approached with extreme caution. (NAS, 1976).
In 1974. NQAA, in cooperation with EPA and with several academic /research institutions, began gath-
ering background information on conditions at the chemical wastes site. Three baseline survev cruises (1974,
1975, and 1976) and several field studies (February, June, August, and September 1976; July 1977; and
February and April 1978) have been conducted. A report on the baseline survey cruises has been published
(NOAA, June 1977); the Introduction and Summary r'rom that report, which deals with the chemical wastes
0-7
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Site's physical, biological, and chemical characteristics and il<> ujniammani input*, .iri* prfMontcd in Appendix
H.
The chemical wastes site has been in use since I9f>5. Therefore, at the time or NOAAS first baseline
survey cruise, the site had been in use for about nine years, making it impossible for NOAA to ubtam a pure
pre-dumping baseline. Most of the data gathered by NOAA concern chemical wastes dumping by American
Cyanamid and by OuPont's Crasselli Plant since these two companies accounted for SO percent of the total
volume of material dumped at the chemical wastes site. The applicability of these data to an assessment of
sewage sludge dumping at the chemical wastes site is limited because paniculate sewage sludge bears little
resemblance to dissolved chemical wastes. •
After EPA authorized the dumping of sewage sludge from Camden. Sew Jersev. at the chemical wastes
site in early 1977, NOAA began making plans to study the possible effects. That opportunity to study the
possible effects of sewage sludge dumping at the chemical wastes site ended on lune 12. 1978. when Cam-
den terminated its ocean dumping operations, a few days short of the expiration of its permit. Camden now
disposes of its sludge through a composting process that is described later in this chapter (see the section on
land-Based Alternatives).
While Camden was using the chemical wastes site. NOAA conducted a coliform test and a tracking
study. Although data collection and analysis are in a preliminary stage, some information on sludge dumping
at the chemical wastes site has been furnished by NOAA.
In June 1977, researchers from WHOl collected samples of seawater during, and tor some time after,
the release of primary sewage sludge from Camden. New lersey. The samples were tested for the presence
of total and fecal coliform bacteria:
Positive results were limited to the first hour of surface sampling from witrtin me plume area.
Regarding total coliforms. 75 percent of the samples collected proved positive and gave a most proba-
ble number range of 1*240 total calls per 100 ml. Measurements on these same samolea for fecal
cotiforms were positive at the 25 percent level and provided a range of 1-120 cells per 100 ml.
No positive results from either test were obtained from any of the subsurface samples. Possibly
tnosa results might have differed given the opportunity for continuous sampling over the entire plume.
However, the necessary gear was not available at this time and we had to rely on a stationary ship to
acquire water samples from beneath the surface.
There are strong indications that the bacterial population associated with sewage sludge is rapidly
dispersed by tne turbulence and sinking associated with sludge release. Most of the bactenal load ap-
pears to remain associated with solid material which rapidly descends to the deeper portions of the
water column where a positive sampling becomes highly dubious. (Vaccaro and Cennet. 1977).
In July 1977, sewage sludge released at the chemical wastes site was acoustically monitored to deter-
mine its qualitative dispersion characteristics. Preliminary results of the tracking study show a slow, wide
distribution of the waste material:
A sharp thermal gradient CTC/m) existed between 13 and 2* m. The waste field on either side of the
dump axis was observed to be distributed through the first 18 m of tne water column. On the dump axis.
the waste was observed to penetrate to a depth of 60 m. The deeper penetration was of limited horizon-
tal extant, conical in shaoe (apex at the point of deepest penetration), and was distributee continuously
from near the surface to the 60 m depth. The heaviest particle concentration appeared to be in the first
40 m of the water column. A shear with a velocity maximum between 15 and 20 m advectad :he waste
field in tne horizontal. Thus, the waste was slowly distributed over an increasing area as matanat sank
from the mixed layer to the seasonal thermodine. During the 32 hr experimental period, the particle field
became distributed over tne first 45 m of the water column. The distribution was not uniform. Heavy
concentrations of bacxscattering. hence panicles were found to be associated witn one or two strong
thermal gradients (sicj. The tnicxness of the heavy scattering areas ranged from S to 10 m. The layers
were periodically displaced by as much as is m by the internal wave field. The horizontal aistnoution of
trie waste field will be determined as our data reducacn progresses. The column of material whicn pene-
trated to 60 m was observed several hours after tne dump. There appeared to be little change in its
depth of penetration or size. (Orr, unoub.l.
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Although increased dilution and dispersion are Kt*ner.ilh i onsidt-rcc) to be positive aspects of dumping
in deeper waters, there are serious drawbacks as well. In irsdmunv at the Toms River hearing in 1977. Or.
Carol Litchfield. a marine microbiologNt, cautioned (hat mo\ inn the dump sue to deeper waters would signif-
icantly increase the time required tor sludge decomposition:
The very factor which is appealing to many people in moving and relocation o' the dump site in
the deeper waters is the very factor which is going to assure that there will be a longer residence time of
the sludge and a greater accumulation of the material that is dumped.
Another concem...is what happens to tne organisms that are introduced along with the sewage
sludge.
Unfortunately, there is very little information on the survival of conforms in deeper waters.
It has been repeatedly shown, however, that decreased temperatures aid the survival of conform
bacteria in the increased salinities and slightly increased pressures that they would encounter at the
deeper dump site, therefore, automatically assuming that deeper waters will "take care of" potential
pathogens more efficiently than that which occurs at the present location, could lead to a very false
sense of security.
In summary, based solely upon the scientific data available through numerous other studies we
know that only about ten percent of the problem would be relieved by moving of the dump site.
This would probably have little positive effect on decreasing the survival of potentially pathogenic
micro-organisms, and would definitely result in slower decomposition, and hence, greater accumulation
of the dumped organic matters, (in USEPA, June 1. 1977; see also Appendix C).
Another point that must be considered is the unknown consequences of dumping sewage sludge and
chemical wastes at the same site. As previously mentioned, combining different types or wastes at one dump
site makes it extremelv difficult to isolate the true cause of any adverse environmental effects. This would be
an especially difficult problem at the chemical wastes site because the effects of chemical wastes dumping
alone are not yet well understood:
The chemical behavior of the substances discharged at 0WO-106 [the chemical wastes site) and
their impact on the mahne environment are unknown. A research group consisting of investigators from
Woods Hole Oceanographic Institution, University of Rhode Island. National Marine Fisheries Service.
and the Smithsonian Institution have developed a multidisciplmary oceanographie study at DWO-106 to
consider the physical, biological, and chemical factors associated with dumping of chemical wastes. The
primary chemical questions to be considered in this program are:
1. Does the discharge of wastes at OWO-106 produce elevated concentrations of potentially
toxic metals in the seawater?
2. What are the horizontal and vertical extents of chemical impact at the dumpsite?
3. What are the cnemical forms of metals which may be toxic to manne organisms?
4. To what extent are the metals discharged at OWO-106 taken up by organisms, suspended
particles, and seafloor sediments?
Answers to these questions will provide a basis for evaluating the consequences of chemical
wast* disposal at OWO-106 and for designing a future monitoring program to assure that this ocean
dumping does not materially degrade the quality of the manne environment (Hausknecht and Kester.
December 1976).
Despite the limited information available on the chemical wastes site, it has been suggested as an alter-
nate sewage sludge dump site. The hope of avoiding d recurrence of' the fish kill and beach closure incidents
discussed in Chapter 11 is the reason most often cited for this suggested move. However, as reported in
Chapter II, results of the studies of the fish kill and beach closures have shown that both incidents were
basically the result of atypical atmospheric and hydrography conditions, and that sludge dumping was at
most a minor contributing factor. Therefore, moving the sludge dumping operations to the chemical wastes
site would have no value as a preventive measure.
During its investigation of the fish kill and beach closures. EPA-Region II sought the opinion of other
federal and state agencies about the relationship of sludge dumping to these incidents. Specifically. SPA-
Region It asked NQAA. the USCC. FDA, ISC. the Fish and Wildlife Service, the New York State Department
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of Environmental Conservation (NYSOEO, and NJDEP whether they thought sludge dumping was responsible
for the incidents and whether they would recommend relocation of the dump site:
In that during this past spring and summer, there have been several environmental episodes, mainly the
wash-up of ftoatables and trash on Long Island and New Jersey beacrtes. an extensive kill of bentrtic
organisms in the New York Bight, and considerable press and political pressure to associate dumping
practices as a dree; cause of these episodes, we would appreciate your comments regarding the fol-
lowing:
1. Does your Agency believe that dumping is the direct cause of tnese episodes? If so. do
you have any technical evidence to support this claim?
2. Oo you maintain, as you have indicated in the past, the position that sludge dumping at the
existing site should be continued? If not what would be your position on moving to either of the two sites
studied by NOAA and located roughly 60 miles offshore? What would be your opinion of moving the
dump site off the Continental Shelf to the present chemical wastes site? if you believe that the dump
site, on the basis of the recent incidents, should be relocated, what environmental factors do you con-
sider appropriate in that decision? (See Appendix I.)
In general, there was a lack of enthusiasm for any move from the existing dump site. Only one agency,
NjDIP, favored relocation; it recommended a gradual shift to the chemical wastes dump site, but only after
a thorough evaluation of the potential impacts in accordance with NEPA. Copies or the individual responses
can be found in Appendix I.
At the Toms River hearing in 1977, NjOEP restated its recommendation for a gradual shift to the chemi-
cal wastes site after a thorough environmental assessment of the consequences. At the same time, NOAA
slightly modified its position. In general, NOAA continues to strongly recommend against any move from the
existing dump site based on the fact that there is no demonstrated need for such a move. Nevertheless, if an
alternate site must be chosen, NOAA would prefer the chemical wastes site to a site in either the Northern
or Southern Area. However, NOAA's acceptance of the chemical wastes site as an alternate sludge dump
site is conditioned on the demonstration that "the net adverse environmental effects are lor are likely to be)
less as a result of dumping the material at OWO-106 [the chemical wastes site) than at the original dump
site." (in USE?A. May 31, 1977).
After reviewing ail of the testimony submitted at the Toms River hearing in 1977. the hearing officer
briefly recounted the reasons why sludge dumping at the chemical wastes site would be environmentally
unacceptable:
The preponderance of informed scientific opinion urges extreme caution in dumping wastes in the
deep ocean, particularly wastes containing solid materials, because of tne many unknowns about this
part of the environment There is a strong feeling among manna scientists (Mat it would be possible to
start long-range trends which would be undetectafile until it was too late to take corrective measures.
Specific concerns with the dumping of sewage sludge in the deep ocean are tne possible persis-
tence of pathogens for long periods of time, the accumulation of biodegradable materials whicri could
ultimately float up undecayed to contaminate seas and beaches, the development of anaerobic deep
sea environments, and the damage-to deep sea organisms which are used to extremely stable condi-
tions.
Based on this informed scientific opinion, it is concluded that dumping of sewage sludge at the
108-mHe site (the chemical wastes site) has a potential for irreversible, long-range, and therefore unrea-
sonable degradation of the marine environment, and that the use of this site 'or this purpose would be
contrary to the intent of the Act [the MPRSAj and the Convention [the international Convention on tne
Prevention of Marine Pollution by Dumping of Wastes and Other Maner). (See Appendix C.)
Monitoring and Surveillance - Although precise information is not available, indications are that both
monitoring and surveillance of sewage sludge dumping at the chemical wastes site would be more difficult.
far more expensive, and perhaps less reliable than at the existing site. As NOAA observed in its baseline
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survey report on the chemical wastes site, monitoring is tar more complicated at off-the-shelf sites:
The environmental effects of disposal in deeper waters are...more difficult to measure and. hence, to
predict This is due to factors such as greater depths of water and distances from shore and also to the
general paucity of environmental and biological information in off-the-shelf areas. In the case of OWO-
106 (the chemical wastes site] this situation is further complicated by the interactions of maior water
masses. Shelf Water, Slope Water, and Gulf Stream eddies. The OWO-106 is a complex oceanographic
area in which to assess natural environmental conditions and the impact of man's activities upon those
conditions (NOAA. June 1977; see Appendix H).
In testimony at the Toms River hearing, Kenneth Kamlet. representing the National Wildlife Federation,
expressed serious doubts about the feasibility of monitoring sludge dumping operations at the chemical
wastes site:
Relocation of sludge dumping to the 10S-site [the chemical wastes site] would essentially deny
the opportunity to monitor the situation and render it vitually impossible to alter the course of events
should corrective action be necessary.
This is a frequently cited concern. For example, at the EPA workshop on "Evaluation of Ocean
Dumping Criteria" convened at Airtie House, August 31 - September i. 1973, a group chaired by Or.
Edward 0. Goldberg, and including among others. On. Oean F. aumpus. Gilbert T. Rowe. and David
Mercel, concluded that, although off-Shelf dumpsite locations "would be amenable to mixing of liquids, it
is not possible to predict the effect and fate of solids at great depths and it would be difficult to monitor
their effects." Dr. Holger Jannasch has pointed out that "the feasibility of short-term studies (on deep-
sea biodegradation) is very limited." and that, for this and other reasons, "it will probably be difficult or
impossible "to show" — not because there will be no harm..." (but because) (s)cientific evidence for or
against such an effect will be very difficult to obtain" (in USEPA. May 31, 1977).
In connection with the Toms River hearing. NOAA was asked by the hearing officer to provide informa-
tion on the feasibility of developing a program to monitor the effects of sludge dumping at the chemical
wastes site. In reply, NOAA stated that such a program would be possible but also very expensive:
The techniques required for a monitoring program are available. It is. however, more time-consuming
and thus more expensive to monitor a site which is 100 miles from shore and 2.000 meters deep than
one which is nearshore and shallow.
An effective monitoring program would be built upon our existing knowledge. Initial work directed specifi-
cally at sewage sludge would be to define the volume of water through which the sludge settles, the
area of the bottom accepting the waste, the rate of water renewal, and rates of deep-sea sludge oxida-
tion. The effects of sludge on deep-sea biota would be addressed through field sampling and by applica-
tion of specialized techniques for observation at low temoerature and high pressure. .
It is estimated that such a program would require about S2.S million for each of its first two years and.
thereafter, about S1.0 million per annum (Martineau, October 11, 1977).
After evaluating all of the information presented at the Toms River hearing, the hearing Officer con-
cluded that it would not be feasible to design an effective monitoring program tor sewage sludge dumping at
the chemical wastes site (see Appendix O.
Similar problems arise in terms of surveillance at the chemical wastes site. As previously reported, the
USCC has responsibility under the MPRSA for surveillance and other appropriate enforcement activity with
regard to ocean dumping, and the USCC - Third District is responsible for surveillance of ocean dumping in
the New York Sight.
At the Toms River hearing. Commander Mullen, representing the Third Coast Guard District, testified
about the difficulties of conducting a thorough surveillance program if sludge dumping is moved r'rom the
existing site to either the 60-mile site or the chemical wastes site:
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Surveillance of sewage sludge disposal operations at the New York Bight Site (li-rmle site) is
conducted by four Coast Guard vessels which are of the 82 foot and 95 foot classes. These are rela-
tively small vessels.
An average of four vessel patrols per week are conducted at this' site. The patrols occur both
daytime and nighttime and are intended primarily to detect and to deter dumping outside of the dump*
sites, although other EPA requirements, affecting rate of discharge, discharge of floatabies. and so forth
are also monitored.
In addition, a daily schedule of multi-mission helicopter patrols by Coast Guard Air Station Brook-
lyn is also conducted which in part monitor the same activities.... [The helicopters used in this program)
are of the type HH-52A. with an operational limitation of approximately 25 miles from shore.
Surveillance at the Industrial Waste Site (the chemical wastes site) is conducted by shiprider
Currently, five petty officers at New York and two at Philadelphia are involved, it should be noted
at this point that the departure times of the vessels and barges are subject to substantial changes as a
result of mechanical failures or weather and tidal conditions.
As a result, shipriders are often tied up for considerable periods of time awaiting departure for a
particular disposal trip.
Considerable time is also involved in transporting the shipnder to the barge, which requires a
vehide and an additional man.
Coast Guard National Policy is to provide 75% surveillance of toxic chemical dumps which are
disposed of at the Industrial Waste Site. With regard to surveillance of sewage sludge and other material
ocean dumped. Coast Guard policy is to provide 10% surveillance.
Now let us consider the feasibility of surveillance at each of the alternative sewage sludge dis-
posal sites.
As I mentioned earlier, surveillance at the 106-mile site [the chemical wastes site) is conducted
entirely by shipriders. Disposal of all the area's sewage sludge at the 106-mile site would cause a dra-
matic increase in the number of dumps occurring there.
In order to provide the 10% level of surveillance presently maintained over sewage sludge. Coast
Guard shipriders would have to be utilized for these additional missions.
This would require the allocation of new personnel at the Captain of the Port offices and exten-
sive use of reserve petty officers.
The use of reserve petty officers as shipriders is a concept that has recently been tested by the
Captain of the Port Philadelphia. Some of the problems encountered included a lack of expertise with all
types of navigational equipment
The reservists generally have to be provided with refresher training in the use of Loran A, Omega.
dead reckoning etc. Delays in vessel and barge departures due to weather and mechanical failure
caused the reservist to spend considerable time in stand-by status.
This tends to be a serious problem in terms of manpower utilization due to the short active duty
period of each reservist
Helicopters would have the capacity to check vessels in transit to the 106-mile sice, but surveil-
lance at the dump site is beyond the capabilities of the shore based HH052A [sic).
In the near future, we hope to implement an automated ocean dumping surveillance system.
This system is presently being field tested. Such a system would greatly facilitate our ability to
monitor dumps at any of the dump sites far offshore.
It is anticipated that regulations requiring installation of OOSS will be issued within six months.
Three modes of surveillance are being considered for the 60-mile site (in the Northern or South-
em Area], should sludge dumping be moved there. Shipriders could be utilized as at the industrial Waste
Site and essentially the same problems would be encountered.
Although the time required to complete a mission would be less, the departure delays and time
required to transport the shipridar to and from the vessel would still exist.
In considering use of the 95 and 32 foot patrol boats for surveillance at the SO-mile site, new
problems arise that do not exist for surveillance at the present sludge dump.
The 82 and 95 foot class vessels are ill adapted to cruising during rough waters encountered on
the high seas.
Larger class vessels have been committed to offshore fisheries patrol and are fully utilized wnile
assigned to that program. While the possibility exists that the larger vessels used on fisheries patrol
could occasionally pass in the vicinity of the 60-mile dump site, it is unlikely that the frequency of tnis
happening could result in an effective surveillance program.
The proximity of the 11-mile site [the existing sewage sluoge dump site) to Grcuos Sandy Hook
and flocXaway allows for easy accass to the site and keeps the 32 ana 95 foot patrol aoats "close to
home" in an excellent position to respond to other missions most importantly search and rescue.
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It is important to note, mat the 82 and 95 foot patrol boats are the primary SAR [search and
rescue] boats for Coast Guard Surveillance goal of 10% (sic).
As mentioned earlier. Coast Guard safety policy is to utilize the HH-52A helicopter up to 25 miles
from shore.
The proposed 60-mile site is 33 miles from Long Island. 8 miles beyond the aircraft's normal
range. In other words, the HH-52As could be used for occasional surveillance of barges and vessels in
transit to the 60-mile site, but actual surveillance of disposal operations at the site would by necessity be
limited.
The Automated Ocean Dumping Surveillance System (OOSS) once available, would provide an
additional alternative to monitoring at the 60. mile site.
In conclusion, the resulting surveillance programs for sewage sludge dumped at either the 60 mile
sits or the 106 mile mile site would not be as effective as they are presently, unless sufficient lead time
were available to acquire additional shipriders, or unless implementation of the automated ocean dump-
ing surveillance system were to first take place.
In the interim period, while attempts are being made to obtain additional resources, it is recom-
mended that a requirement be added to all permits issued for the 60 or 106 mile site for daytime and
nighttime that the master of the ocean dumping vessel prepare at the time of occurrence a navigational
Overlay of the dumping vessel's trackline during the dumping operation, indicating the times and posi-
tions at entry and exit of dumpsite and beginning and end of dump.
It is our intention to make every effort to acquire the needed extra persons as soon as any
decision is made to move the sludge site, but the extent of lead time needed to actually obtain the
needed resources is not known at this time (in USEPA. May 31. 1977).
In summary. Commander Mullen's assessment was that there would be no insurmountable technologi-
cal problems associated with providing the standard 10 percent surveillance of sewage sludge dumping, at
the chemical wastes site. However, until the electronic surveillance device being tested by the USCC is
approved and installed on vessels engaged in ocean dumping, an effective surveillance program would be
economically and logistically burdensome, requiring substantial increases in equipment and personnel as well
as the lead time to acquire the needed equipment and to adequately train Coast Guard reservists in its use.
In his report on the Toms River hearing, the hearing officer acknowledged the difficulties pointed out by
Commander Mullen, but concluded, "there is no indication that surveillance of dumping at the 106-mile site
[the chemical wastes site) would not be feasible" (see Appendix C).
Logistics and Economics - Even if there were enough data to determine the potential effects on the
marine environment of dumping sewage sludge at the chemical wastes site, and even if those effects were
found to be acceptable, the logistical and economic drawbacks associated with the distance to the chemical
wastes site would probably preclude this alternative. At its closest point, (he chemical wastes site is 210 km
(1 IS n mi) from the Sandy Hook-Rockaway Point transect. The limitations of the existing fleet are such that a
maximum distance of 120 km (65 n mi) was made one of the criteria for selecting an alternate sewage sludge
dump site. Transporting sludge to the chemical wastes site or to some other area off the continental shelf
would necessitate upgrading and expansion of the existing fleet.
As shown in Table 7, only twelve vessels are actually in use in the New York Bight, and one of those.
the barge Westco I. is not seaworthy for use beyond the existing sludge dump site. This reduces the total
fleet to eleven and the total carrying capacity to 41,374 cu m (34,112 cu yd) or about 91 percent of the
carrying capacity of the full thirteen-vesse! fleet.
At an average speed of 13 km/hr (7 knots), a tanker would take approximately 54 hours to make a
round trip to the chemical wastes site (see Table 29). At an average speed of 9 km/hr (5 knots), a barge
would take approximately 72 hours. These time estimates include 10 hours per trip for docking and loading
and 5 hours per trip for discharging the sludge. The 5-hour discharge limitation was imposed by the USCC
for safety reasons at the existing dump site. It is used here to facilitate time comparisons between the existing
dump site and the chemical wastes site. If the chemical wastes site were actually to be used, the time
required for discharge would be substantially greater because the USCC safety limit would not apply and the
discharge rate would have to be established in accordance with section 227.3 of the current ocean dumping
regulations (see Appendix S). Thus, the round trip time to the chemical wastes site would be 54 hours plus
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for a tanker and 72.hours plus for a barge. A round trip to the existing sewage sludge dump site takes about
26 hours for a tanker and 30 hours for a barge.
Given the time constraints associated with the chemical wastes site and assuming that necessary over-
hauls would put each vessel out of service for about one month per year, the maximum number of annual
trips to the site would be 147 for each tanker and HI for each barge. It is most unlikely that the maximum
number of trips could actually be made, however, because this would require that each vessel be in round-
the-clock service for the other eleven months of the year.
Even if optimum conditions prevailed, the total volume of sludge that could be transported to the
chemical wastes site by the available eleven-vessel fleet (six tankers and five barges) would be 5.0 million cu
m (6.6 million cu yd) per year. Almost 4.0 million cu m (5.3 million cu yd) of sludge were dumped at the
existing site in 1977, and over 6.0 million cu m (7.9 million cu yd) are projected to be dumped in 1978 (see
Tables 6 and 9).
The situation could be improved somewhat by the addition of the Liquid Waste NO. J, which is now in
use in Puerto Rico. This would bring the number of vessels to twelve (six tankers and six barges) and the total
hauling capacity to about 5.3 million cu m (7.0 million cu yd) per year. However, since this volume will
probably be surpassed in 1973, fleet augmentation cannot be avoided if a site off the continental shelf is
chosen for sludge dumping.
The sludge dumping fleet could be enlarged either by hiring or by constructing the needed vessels. Both
of these options would be prohibitively expensive, and the latter would also be infeasible considering the
time required to construct the needed vessels and the scheduled phase out of ocean dumping in 1981.
Expanding the fleet of dumping vessels and increasing the travel time for each vessel in order to make
use of the chemical wastes site would dramatically raise the cost of sludge dumping for those municipalities
that now hold ocean dumping permits (see Table 6):
Cost per Cost per
Dump Site • Wet Ton cu m
Existing $1.25 $1.95
Northern or
Southern Area 4.00 to 5.00 6.30 to 7.30 4.70 to 5.90
Chemical Wastes 8.00 to 10.00 12.50 to 15.60 9.40 to 11.30
Thus, the cost of using the chemical wastes site would be twice the cost of using a dump site in the Northern
or Southern Area, and six to eight times the cost of continuing to use the existing sewage sludge dump site.
Had the chemical wastes site been used for sludge dumping in 1977, it would have cost the municipal
permittees somewhere between $49.0 million and $61.0 million instead of the $7.6 million that it cost to use
the existing site. By 1981, use of the chemical wastes site for sludge dumping would cost the municipal
permittees somewhere between $124.0 million and $154.0 million. The cost to New York Ctv alone could
be as much as $64.0 million; currently, sewage sludge dumping at the existing site costs the city $2.2 million
per year (Samowitz, June 14, 1977).
Other costs would rise as well, including the cost of monitoring the dump site and the cost of the
USCC's surveillance operations.
Its dubious environmental acceptability and its extreme cost are the major but not the only drawbacks
to dumping sewage sludge at the chemical wastes site. Greater navigation hazards would result from the
dumping vessels' increased travel time on the open ocean. Short dumping, including emergency dumping.
would almost certainly increase. Added to this is the fact that using the chemical wastes site for sludge
dumping would be of negligible benefit to the water quality of the Sight Apex. Of ail of the pollutant sources
in the Sight Apex, sludge dumping is hardly the most significant, and its removal to the chemical wastes site
could not by itself effect a substantial change in water quality.
Effect of Using the Chemical Wastes Site on the Ability of Dumpers to Meet the December 31,
1981 Deadline • The prohibitive cost associated with using the chemical wastes site for sewage sludge
disposal would threaten the ultimate objective of terminating sludge dumping by December 31. 1981. The
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economic resources of the communities involved are finite, dnd if they are spent on transporting sludge to
the chemical wastes site, they will not be available for implementing land-based disposal methods. This
particular aspect of using the chemical wastes site is a matter of concern not only to the communities that
would have to bear the cost, but to federal agencies, to environmental groups, and to some of the Congress-
men who were instrumental in amending the MPRSA to specify the 1981 deadline (see Appendices C and
Di.
Although NOAA would prefer that the chemical wastes site rather than a site in the Northern or South-
em Area be used in an emergency between .now and 1981, NOAA opposes summarily moving sludge
dumping from the existing site to the chemical wastes site:
NOAA is not in agreement with trie proposal to move the sludge dump site which serves the New
York-New Jersey metropolitan area from the Apex to the deep water site at 106 miles [the chemical
wastes site).
Our position is that no need has been established to require moving the existing dump site, and
that all sewage sludge dumping should be halted by 1981.
We are concerned that an open door policy of sewage sludge could ultimately lead to the situa-
tion in which most or substantial amounts of east coast municipal and industrial waste dumping is carried
out at that site.
Such a policy would seriously undermine efforts to encourage ocean dumpers to seek land cased
alternatives to ocean dumping (emphasis added) (in UScPA, May 31, 1977).
A similar view was expressed by Kenneth Kamlet. representing the National Wildlife Federation, at the
Toms River hearing in 1977. In responding to the argument that the increased cost of using the chemical
wastes site would make land-based disposal more cost-competitive with ocean dumping and therefore more
attractive to the municipalities involved, Mr. Kamlet stated:
In the first place, any significant increment between now and the end of 1981 (the deadline for
completing the phase-cut of sewage sludge ocean dumping) in the cost of sewage sludge disposal could
as easily discourage as encourage the expedited phase-out of sludge dumping. H it had tha affect of
diverting into continued ocean dumping limited funds which would otherwise tie available to implement a
dumping phase-out (emphasis added].
In trie second place, if the cost increment for relocating the dumpsite were not substantial
enough to jeopardize the implementation of land based alternatives, chances are they would also not be
substantial enough to provide much if any incentive to accelerate a dumping phase-out (in USEPA, May
31. 1977).
Congressman Edwin Forsythe. the ranking minority member of the House Subcommittee on Oceanog-
raphy, also testified against moving sludge dumping to an alternate site, particularly the chemical wastes site:
A decision regarding the location of municipal sewage sludge dumping is a critical resource
management problem. Since tne environmental and fiscal resources at stake are extremely valuable, our
decision-making must be based on rationality. Attempts to sensationalize the issue, and politically expe-
dient pressure to move the problem "out of sight", "out of mmd", must be resisted.
The net effects at present of a dumpsite move would be the following: a new site would be
contaminated, with little recovery of existing dumpsites.
Municipalities will exhaust their financial resources on increased transportation costs and ocean
dumping barge construction while alternative treatment methods go unfunded (emphasis added]. The
government will investigate and monitor new dumpsites at the time when Congress has reaffirmed its
unequivocal intent to end ocean dumping of sewage sludge by 1981.
Finally, responsible parties seeking permanent solutions to the region's waste disposal problem
will have their efforts diffused if a quicx-fix. "out-of-sight", "out-of-mind" non-solution is adopted.
I am particularly concerned about the possiblity of dumping sewage sludge at Oeepwater dump-
site 106 [the chemical wastes site).
The sensitivity of biota, the likely impact on fisheries, trie difficulty of policing, the high probability
of short dumps, and the impossible task of thoroughly monitonng adverse impacts at the site clearly
indicate that dumping at the 10S-site could be an environmental nightmare (in USE?A. May 31, 1977).
D-15
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Congressman Forsythe and the Chairman of the House Subcommittee on Oceanography later reiterated
these same concerns during EPA's 1978 ocean dumping authorization hearings (see Appendix 0).
The estimated cost to municipalities of using the chemical wastes site for sludge dumping is shown in
Table 30. An increase of 641 to 800 percent over the cost of using the existing dump site between 1978 and
1981 is projected. This large an increase would almost certainly detract from the search for alternative land-
based disposal methods. As the hearing officer's report for the Toms River hearing concludes:
Nona of the municipalities stated that they could not meet the added costs, but they did point out
that there would be difficulties in funding, and that these costs might have to coma from funds presently
allocated for implementing alternatives (emphasis added). (See Appendix C.)
Modification of Dumping Methods
Current sludge dumping procedures, as set forth in each ocean dumping permit, require that the sludge
be discharged within the designated dump site, at a uniform rate of 15,500 gallons per n mi (27,44) liters
per km) and a speed of at least 3 knots (5 km/hr). Vessel traverses must be at least 0.5 n mi (1 km) apart.
These requirements have been stipulated by the USCC for safety reasons in this heavily trafficked area. They
would not be applicable if sludge dumping were moved to a site outside the Bight Apex.
Methods of sludge release considered in this 615 include simple overboard dumping, jet discharge, and
discharge in the vessel's wake (the present method).
Overboard Dumping. This method consists of simply releasing the sludge from the vessel; the material
descends by its own momentum. Since its vertical motion is affected by buoyancy, the initial distribution is
mainly within the surface water layers.
let Discharge. This method involves pumping the sludge from the vessel through an opening
beneath the surface. It is effective in passing the material through the surface layers, but it results in a more
confined initial distribution, usually at the depth of neutral buoyancy of the sludge.
Discharge in the Vessel's Wake (Present Method). This method results in high initial mixing and
dilution, but the sludge's vertical motion is still dependent on density differences between it and (he receiv-
ing waters.
Considering the 30 to 60 m (100 to 200 ft) depths and the flow patterns in the Northern and Southern
Areas, the present dispersive method of sludge dumping should be continued at an alternate dump site for
the following reasons:
— Sewage sludge dumped at or near the surface will settle over a wide area because of its low bulk
density, 1.01 g/cu cm.
— Differences in the thermohaline (temperature and salinity) density structure of the ocean would
probably slow the settling of sludge under stratified conditions and would negate the effective-
ness of a pumped subsurface discharge.
— Dispersion at either the Northern or Southern Area is primarily a function of sea state, depth, and
water mass movements. As such, it is not likely to be improved by altering the present dumping
technique.
— Given the volumes of dumped sludge projected through 1981 and the limitations of the present
fleet, use of sophisticated dumping techniques would probably be both technically impossible
and economically prohibitive. Moreover, such techniques would be of little value in improving
dispersion patterns.
— Monitoring of the dump site would be facilitated if dumping were limited to a specific surface
area.
D-16
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LAND-BASED ALTERNATIVES
Although an immediate changeover to land-based disposal of sewage sludge m the Ne* York-
iff«.e\ metropolitan area is not feasible, current predictions are that land-based methods can be implemented
in time to meet the December 31, 1981 deadline for phasing out ocean dumping of sewage sludge.
In lune 1975 and'lune 1976, ISC issued reports on Phases 1 and 2, respectively, of a three-phase
sludge management study funded by EPA. In October 1976, the study was completed with the publication
of ISCs sludge disposal management plan for the New York-New jersey metropolitan area. The study's
purpose was to describe the feasible land-based alternatives for sludge disposal and methods of implement-
ing them. As the study progressed and more information was gathered, ISC modified its recommendations
accordingly; the final report, published in October 1976, sets forth ISC's current position on the question of
sludge management in the metropolitan area.
ISC Phase 1 Report
The Phase 1 report was primarily concerned with the following land-based methods of sewage sludge
disposal: direct land application, incineration, pyrolysis, and use as a soil conditioner or fertilizer.
Direct Land Application. Sewage sludge in its liquid form can sometimes be applied to the land as a
soil conditioner or fertilizer. Those characteristics of sludge that affect its suitability for direct land application
include the organic matter content, the available nutrients (nitrogen, phosphorous, potassium, and trace
elements), the quantities of heavy metals, and the toxic organic* (especially chlorinated hydrocarbons), in
general, three factors limit the immediate implementation of direct land application of metropolitan area
sludge.
First, the sludge generated by metropolitan wastewater treatment facilities contains high concentrations
of heavy metals (cadmium, chromium, copper, lead, mercury, nickd, and zinc) and significant quantities of
toxic organics (chlordane, diddrin, endrin, heptachlor, lindane, and mirex). If these substances leached into
the soils underlying a land-application site, they would be harmful to adjacent streams and groundwater
aquifers.
Second, metropolitan area sludge is low in nutrients (as are most domestic sewage sludges) in compari-
son with commercial fertilizers.
Finally, land is not available in the metropolitan area for a large-scale land-application program. The
cost of transporting large quantities of sludge to suitable sites outside the metropolitan area appears to be
prohibitive.
Incineration. Sewage sludge incineration results in waste gases, paniculate*, and a relatively small
quantity of sterile ash that retains most of the heavy metals originally present. Air pollution controls, such as
wet scrubbers, are necessary to remove the particulates. odors, nitrogen oxides, sulfur oxides, volatile toxic
organics, and airborne heavy metals (cadmium, lead, and mercury). Multiple-hearth incineration has the least
potential for air pollution; it can bum without auxiliary fuel (gas, oil, or coal), and it is compatible with a
phased change-over to pyrolysis. The ash, of course, which contains heavy metals, must ultimately be dis-
posed of in an environmentally acceptable manner.
To bum without auxiliary fuel, sludge must generally be dewatered, that is, the liquid content must be
reduced from its usual range of 93 to 97 percent to less than 65 percent.
Although the air pollution problems posed by this method of sludge disposal could be minimized by
incinerating the material on ships or offshore platforms, the costs cannot be justified since other, more eco-
nomical, methods of sludge disposal are available.
D-17
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Pyrolysis. Destructive distillation, or pyrolysis. is the process of breaking down organic matter, such as
sewage sludge, by heating it in the absence of oxygen. The resulting bv-products are A number ni gases, a
carbon/ash char, and a liquid waste containing a wide variety of organic compounds. Pyrnivys is senerdllv
cheaper than incineration because it produces fewer participates and thus requires less in the way or air
pollution controls. The by-products, char and gases, can be used as fuels. To date, however, no large-scale
pyrolysis tests have been conducted on sewage sludge alone, so prior to implementation of this alternative, a
pilot demonstration plant would have to be built and successfully operated.
Use as a Soil Conditioner. Problems with the use of sewage sludge as a soil conditioner or fertilizer
are much the same as those with direct land application: the high concentrations of heavy metals and toxic
organic compounds must be removed or reduced. In addition, the sludge must be dried to 5 or 10 percent
moisture content and fortified with nutrients before it can be used as a fertilizer. Finally, there is the problem
of promoting consumer acceptance.
Conclusions and Recommendations. The ISC Phase I report (1975) drew the following conclusions
regarding land-based sludge disposal methods for the metropolitan area and the eventual, phased implemen-
tation of those methods.
The most feasible alternative to ocean dumping would be pyrolysis (the sludge having been dewatered
with filter presses). This conclusion was based on considerations of environmental impact, economic feasibil-
ity, and energy recovery. Pyrolysis has the least potential for negative impacts on water, air, or land re-
sources. It could be implemented within ten years.
Multiple-hearth incineration could be implemented sooner than pyrolysis, and the incinerators could be
convened to pyrolysis units once that process was demonstrated to be successful. Incinerators, however,
would face more difficult siting problems because of their potential for air pollution and because of the
possibility of local community resistance. The incinerators needed to handle the volumes of sludge projected
for the year 2000 would cost on the order of $400 to SSOO million (in 1973 dollars).
Direct land application could be implemented only in fringe areas (outside the metropolitan area),
where population density is low and large tracts of land are available, and where agricultural enterprises
would provide a market for sludge-based fertilizers and soil conditioners.
A small-scale pilot study should be undertaken immediately with the aid of an equipment manufacturer
who is familiar with both pyrolysis cechrtololgy and multiple-hearth furnace construction. The purpose would
be to identify and define the required engineering parameters prior to full-scale demonstration plant con-
struction.
The complete text of the Phase 1 report's conclusions and recommendations is presented as part of
Appendix j.
ISC Phase 2 Report
The object of the Phase 2 report (ISC, 1976a) was to develop and recommend a specific, coordinated
disposal program based on the technical findings of the Phase 1 report (ISC, 1975). In sum. the Phase 2
report recommends the construction of regional pyrolysis plants at six separate locations in the metropolitan
area and only limited land application of sludge.
Incineration and Pyrolysis. To date, pyrolysis of sludge alone has been studied only in pilot-scale tests;
large-scale demonstrations have utilized solid wastes. The iSC's Phase 1 report indicated that multiple-hearth
furnaces could be built by 1981, initially operated as incinerators, and then converted to pvrolysis units as
that technology developed. Between the publication of the Phase 1 and Phase 2 reports, it was learned that
such furnaces could be designed and constructed as pyrolysis units directly during the same time span:
incineration was therefore not considered further.
The ISC evaluated the retention of anaerobic digestion capabilities at individual plants because a num-
ber of operating wastewater treatment plants have, or plan to construct, these digesters, it was found that
maintenance of existing anaerobic digesters was cost-effective, but that new digesters should not be built if
sludge was to be pyrolyzed.
-------
Land Application, Composting, and Landfilling. Land application and composting are feasible sludge
disposal alternatives for outlying plants in the metropolitan area. These plants could form regional groups for
direct land application or for sludge composting.
Landfilling of stabilized, dewatered sludge is cost-effective only for the smaller suburban wastewater
treatment facilities, and only if landfill sites are available. Landfilling, however, should be considered a short-
term solution, to be used while long-term direct land application or composting programs are instituted. In
addition, landfilling was found not to be feasible for sludges produced by treatment plants in highly urban-
ized portions of the metropolitan area because of the larger quantities of sludge produced and the limited
lifespans of available landfill sites.
Sludge Management. The plan recommended in ISC's Phase 2 report calls for pyrolysis of sludge
produced in urban treatment plants and land application or composting of sludge produced in outlying
plants. The recommended pyrolysis sites and areas to be served are:
1. Port Newark (New Jersey regional), serving Bergen, Hudson, and Union counties, and the Passaic
Valley Sewerage Commissioners.
2. Sayreville, serving the Middlesex County Sewerage Authority.
3. Cedar Creek, serving Nassau County.
4. Twenty-Sixth Ward, serving Coney Island, Jamaica, Rockaway, and Twenty-Sixth Ward.
5. Hunts Point, serving Bowery Bay, Hunts Point, Tallmans Island, and Wards Island.
6. Fresh Kills (New York regional), serving Newtown Creek. North River, Owls Head, and Port
Richmond.
Conclusions and Recommendations. Pyrolysis is favored as a particularly promising means of dispos-
ing of the large volume of municipal sewage sludge expected to be produced by the year 2000. The ISC
Phase 2 report concludes that if future federal policies prohibit or significantly curtail the ocean dumping of
sludge, pyrolysis is the best alternative for its disposal. The report also recommends the construction of six
regional pyrolysis facilities (listed above). Only limited amounts of sludge are seen as suitable for direct land
application.
The ISC condudes that direct land application of either treated or untreated sludge in quantities suffi-
cient to dispose of the expected volumes would be dangerous because of the large heavy metal and toxic
organic content and the threat of surface and groundwater contamination. Pyrolysis is also preferred to
incineration because units could be more easily decentralized. While pyrolysis equipment capable of reduc-
ing sludge is not yet in commercial operation, recent technological advances make it appear that the method
could be in practical use by the early 1980s.
While the ISC acknowledges the urgent need for the cessation of ocean dumping, it considers EPA's
phase-out date of December 31, 1981 to be somewhat optimistic.
The complete text of the Phase 2 report's summary chapter is presented as part of Appendix ].
ISC Sludge Disposal Management Program
The latest ISC report (1976b) presents ISC's plan for sewage sludge management in the New York-New
Jersey metropolitan area. It combines the Phase 1 and Phase 2 reports with an examination of legal-
institutional implementation problems.
In general, the sludge management plan currently recommended by ISC is very similar to the one
recommended in the Phase 2 report. The major difference, is that ISC now places a greater emphasis on
composting followed by land spreading. The sludges produced by several treatment plants in the metropoli-
tan area are now suitable for composting and land spreading. Other sludges are still unsuitable, primarily
because of their heavy metal and synthetic organics content. However, pretreatment of industrial wastewa-
ters could resolve these problems.
D-19
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Relative to pyrolysis, the ISC recommends five facility sites rather than the six given in the Phase 2
report:
1. Port Newark (New jersey regional), serving Bergen, Hudson, and Union counties, and the Passaic
Valley Sewerage Commissioners.
2. Sayreville. serving (he Middlesex County Sewerage Authority.
3. Cedar Creek, Serving Nassau Countv.
4. Twenty-Sixth Ward, serving Newtown Creek, Owls Head. Coney Island. Ian-Mica, Rockawav.
and Twenty-Sixth Ward.
S. Hunts Point, serving Sowery Bay, Hunts Point, Tallmans Island, and Wards Island.
The ISC makes no recommendation relative to the North River or Red Hook treatment plants that are being
constructed in New York City; both plants are scheduled to go into operation in the mid-1980's.
The complete text of the summary chapter of the October 1976 report is presented as part of Appendix
J.
Testing and Implementation
As noted at the start of this chapter, the testing and implementation phases of the sludge disposal
management program have begun. Since no large-scale pyrolysis test had been conducted on sewage sludge
alone. ISC recommended, in its Phase I Report, that a pilot demonstration plant be built and successfully
operated. In 1976, EPA funded such a pilot test. Nichols Engineering and Research Corporation was con-
tracted to test sludge pyrolysis at its Belle Mead, New Jersey, research facility. Sludges from several treat-
ment plants were chemically conditioned, dewatered. and pyolyzed under various design conditions in a
Nichols Herreshoff Multiple Hearth Furnace. Nichols has reported that pyrolysis can be used as a commer-
cially feasible and cost effective thermal destruction method for sludge disposal without using fuel, including
afterburning at 7S9*C (T400T) (ISC 1978).
In December 1976, a sludge composting project in Camden, New lersey, was funded by EPA and
NIOEP. This project uses a technique developed by the U.S. Department of Agriculture's experimental sludge
composting station in SeJtsville, Maryland. During the process, which takes a total of thirty days, dewatered
sludge is mixed with a bulking agent, such as wood chips, corn cobs, or waste paper, and stacked in piles.
The piles are blanketed with an inert material, and air is drawn through the piles. Aerobic biological degrada-
tion increases temperatures within the piles to 32*C (180"R, thus destroying most pathogenic bacteria.
The Camden composting facility, which was dedicated in June 1978. established several major environ-
mental precedents. It is the largest composting operation of its type in the United States. It is also the first
such municipal undertaking in the New York-New Jersey area. Most important, it is the first instance of
cessation of ocean dumping by a large municipal sewage treatment plant <58,118 cu m or 76.471 cu yd per
year).
All municipal permittees in EPA-Region II are required by permit condition to select and implement an
environmentally acceptable alternative to ocean dumping on or before December 31, 1981. Each permittee
has been given a final phase-out date based upon the individual permit implementation schedule. Each of the
permittees is on a strict implementation schedule, and is closely monitored by EPA-Region ll. All permittees
are afforded the opportunity to comply with this condition using federal funds available through the FWPCA
(the Oean Water Act), and most have chosen this path. Examples of the technologies being considered or
currently being implemented are:
Camden
Middletown Township
Northeast Monmouth Composting
Linden-Roseile
D-20
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Nassau County
Bergen County
joint Meeting of
Essex and Union
Counties
Rahway Valley
Wayne Township
Lincoln Park
Pequannock Township
Pompton Plains
Oakland
Middlesex County
Glen Cove
New York Gty
Westchester County
Composting of sludge and use as landfill cover as an interim solution;
co-recovery with solid wastes as a long-term solution
Incineration
Multiple hearth incineration or starved air combustion
Co-incineration with solid wastes
Composting or landfilling of digested dewatered sludge as an interim
solution; utilization of other technology (pyroiysis, co-recovery, etc.) or
shipment out of the city area for composting as a long-term solution
Use of existing excess capacity in solid waste incinerators and com-
posting of remainder
D-21
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APPENDIX E
COMMENTS ON THE DRAFT EIS
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CONTENTS
Title
REVIEWERS OF THE DRAFT EIS E-2
LETTERS COMMENTING ON THE EIS % E-9
RESPONSES TO LETTERS .' E-79
HEARING RESPONSES E-103
E-iii
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APPENDIX E
COMMENTS ON THE DRAFT EIS
The draft EIS (DEIS) was issued on June 25, 1979 and a public hearing was
held on August 21, 1979 at Mercer County Community College, New Jersey. The
public was encouraged to participate in the hearing and to submit written
comments . This appendix contains copies of all verbal and written comments
received by EPA on the DEIS. There was a great variety of comments received,
thus EPA presents several levels of response:
• Comments correcting facts presented in the EIS, or providing
additional information, were incorporated into the text without
further response. Most of Du Font's and NCAA's comments were
handled in this manner.
• Specific comments, which were not appropriately treated as text
changes, were numbered in the margins of the letters, and responses
.prepared for each numbered item.
• Comments orginating at the public hearing were excerpted from the
hearing transcript, and responses prepared.
Some written comments were received after the end of the comment period and
the close of the public hearing record. In order to give every consideration
to public concerns, the Agency took all comments received up to the date of
final production of the final EIS under advisement.
The EPA sincerely thanks all those who commented on the draft EIS,
especially those who submitted detailed criticisms that reflected a thorough
analysis of the EIS.
E-l
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REVIEWERS OF THE DRAFT EIS
The following persons submitted written comments:
Edwin B. Forsythe
Ranking Minority Member
Subcommittee on Fisheries and Wildlife Conservation
and the Environment
U.S. House of Representatives
Committee on Merchant Marine and Fisheries
Room 1334 Longworth House Office Building
Washington, D.C. 20515
(August 24, 1979)
P.A. DeScenza
Chief, Engineering Division
U.S. Department of the Army
New York District, Corps of Engineers
26 Federal Plaza
New York, NY 10007
(August 2, 1979)
Sidney R. Caller
Deputy Assistant Secretary for Environmental Affairs
U.S. Department of Commerce
Assistant Secretary for Science and Technology
Washington, D.C. 20230
(August 31, 1979)
George C. Steinman
Chief, Environmental Activities Group
Office of Shipbuilding Costs
U.S. Department of Commerce
Maritime Administration
Washington, D.C. 20230
(July 26, 1979)
David W. Saxton
Center for Environmental Assessment Services
U.S. Department of Commerce
National Oceanic and Atmospheric Administration
Environmental Data and Information Service
Washington, D.C. 20235
(August 15, 1979)
E-2
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Allen E. Peterson, Jr.
U.S. Department of Commerce
National Oceanic and Atmospheric Administration
National Marine Fisheries Service
Federal Building, 14 Elm Street
Gloucester, MA 01930
(August 28, 1979)
P. Kilho Park
U.S. Department of Commerce
National Oceanic and Atmospheric Administration
National Ocean Survey
Rockville, MD 20852
(August 10, 1979)
Frank S. Lisella
Chief, Environmental Affairs Group
Environmental Health Services Division
Bureau of State Services
U.S. Department of Health, Education, and Welfare
Public Health Service
Center for Disease Control
Atlanta, GA 30333
(August 21, 1979)
Larry E. Meierotto
Assistant Secretary
U.S. Department of the Interior
Office of the Secretary
Washington, D.C. 20240
(September 14, 1979)
R.L. McFadden, LCDR
Chief, Surveillance and Monitoring Branch
U.S. Department of Transportation
U.S. Coast Guard
Washington, D.C. 20590
(August 13, 1979)
F.P. Schubert, Captain
Chief of Staff
U.S. Department of Transportation
U.S. Coast Guard
Third Coast Guard District
Governors Island
New York, NY 10004
(September 10, 1979)
E-3
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Nathan Hayward III
Director
Delaware, State of
Executive Department
Office of Management, Budget, and Planning
Dover, DE 19901
(August 6, 1979)
Edward H. White III
Development Officer
Maryland, State of
Department of Economic and Community Development
Division of Local and Regional Development
2535 Riva Road
Annapolis, MD 21401
(July 19, 1979)
Thomas A. Deming
Acting Assistant Attorney General
Council to Secretary
Maryland, State of
Office of the Attorney General
Department of Natural Resources
Tawes State Office Building
Annapolis, MD 21401
(August 21, 1979)
Lawrence Schmidt
Chief Office of Environmental Review
New Jersey, State of
Department of Environmental Protection
John Fitch Plaza
P.O. Box 1390
Trenton, NJ 08625
(September 21, 1979)
Marwan Sadat and Theresa Van Rixoort
New Jersey, State of
Department of Environmental Protection
Office of Sludge Management and Industrial Pretreatment
Trenton, NJ 08625
(August 21, 1979)
Sandra Ayres
Assistant Deputy
Public Advocate
New Jersey, State of
Department of the Public Advocate
520 E. State St.
Trenton, NJ 08625
E-4
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Terence P. Curran
Director
Division of Regulatory Affairs
New York, State of
Department of Environmental Conservation
50 Wolf Road
Albany, NY 12233
(September 6, 1979)
Richard A. Heiss
Supervisor
Pennsylvania, Commonwealth of
Pennsylvania State Clearinghouse
Governor's Office
Office of the Budget
P.O. Box 1323
Harrisburg, PA 17120
(August 24, 1979)
J.B. Jackson, Jr.
Administrator
Virginia, Commonwealth of
Council on the Environment
903 Ninth Street Office Building
Richmond, VA 23219
(August 8, 1979)
Dale E. Wright
Pollution Control Specialist
Bureau of Surveillance and Field Studies
Virginia, Commonwealth of
State Water Control Board
2111 Hamilton Street
P.O. Box 11143
Richmond, VA 23230
(August 2, 1979)
Robert D. Halsey
Director of County Planning
Monmouth County Planning Board
Court Street and LaFayette Place
Freehold, NJ 07728
(October 7, 1979)
Harry W. Kelley
Mayor
Ocean City, Town of
Mayor and City Council
Ocean City, MD 21842
(August 3, 1979)
E-5
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Martin Neat
Grantsman
Ocean City, Town of
Mayor and City Council
Ocean City, MD 21842
(July 24, 1979)
Gerald.M. Hansler
Executive Director
Delaware River Basin Commission
P.O. Box 7360
West Trenton, NJ 08628
(August 14, 1979)
H.W. McDowell
Environmental Coordinator
E.I. du Pont de Nemours & Company, Inc.
Grasselli Plant
Linden, NJ 07036
Chemical Dyes and Pigment Department
(August 24, 1979)
L.L. Falk
Engineering Service Division
E.I. du Pont de Nemours & Company, Inc.
Wilmington, DE 19898
Engineering Department
Louviers Building
(September 26, 1979)
Leon J. Sokol
Greenstone and Sokol
Counsellors at Law
39 Hudson Street
Hackensack, NJ 07601
(August 21, 1979)
Kathleen H. Rippere
Natural Resources Chairman
League of Women Voters
Monmouth County, NJ
934 Navesink River Road
Locust, NJ 07760
(August 10, 1979)
John C. Bryson
Executive Director
Mid-Atlantic Fishery Management Council
Room 2115 Federal Building
North and New Streets
Dover, DE 19901
(October 4, 1979)
E-6
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Kenneth S. Kamlet
Counsel, and Assistant Director
for Pollution and Toxic Substances
National Wildlife Federation
1412 16th St'., N.W.
Washington, D.C. 20036
(August 31, 1979)
The following persons attended the hearing held August 21, 1979 at Mercer
County Community College, New Jersey:
Thomas O'Connor
U.S. Department of Commerce
National Oceanic and Atmospheric Administration
National Ocean Survey
Rockville, MD 20852
Norma Hughes
U.S. Environmental Protection Agency
Oil and Special Materials Control Division
Marine Protection Branch
Washington, D.C. 20460
T. William Musser
U.S. Environmental Protection Agency
Oil and Special Materials Control Division
Marine Protection Branch
Washington, D.C. 20460
Barbara Ramsey
U.S. Environmental Protection Agency
Oil and Special Materials Control Division
Marine Protection Branch
Washington, D.C. 20460
Alan Hill
U.S. Environmental Protection Agency
Oil and Special Materials Control Division
Ocean Programs Branch
Washington, D.C. 20460
Peter W. Anderson
U.S. Environmental Protection Agency
Region II, Surveillance and Analysis Division
Edison, NJ 08817
I
Paul Birmingham
U.S. Environmental Protection Agency
Region II
New York, NY
E-7
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Theresa Van Rixoort
New Jersey, State of
Department of Environmental Protection
Office of Sludge Management and Industrial Pretreatment
Sandra T. Ayres
New Jersey, State of
Department of the Public Advocate
520 E. State Street
Trenton, NJ 08625
D.W. Bennett
American Littoral Society
Highlands, NJ 07732
William M. Dunstan
Interstate Electronics Corporation
1745 Jefferson Davis Highway, Suite 601
Arlington, VA 22202
Kathleen M. King
Interstate Electronics Corporation
707 E, Vermont Ave.
P.O. Box 3117
Anaheim, CA 92803
Kenneth S. Kamlet
National Wildlife Federation
1412 16th Street, N.W.
Washington, D.C. 20036
Phyllis Allen
Plainfield, NJ
E-8
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. .K.lo.iOf of
(Conmiillrr on
jllrtfljniil flUriiu nub jFiabcricf
oiti IJM. linguotib Bloui, COut limiti
JilaaljiUBlon. JD.C. 20515
August 24, 1071)
Mr. T. A. vJastJcr; Project Officer
U.S. Environmental Protection Agency
oil and Special Materials Control Division
Hurine Protection Branch
Washington, D.C. 20460
DEIS for 106-Mile Ocean Waste
Disposal Site Designation
w
Hear Mr. Wastlor:
[ wish to ccr.inend you for the exhaustive Draft Environmental
uipact Study Cor the 106-Mile Ocean Waste Disposal Site Designation.
As n nviitjor of the Merchant Marine and Fisheries Committee
which has legislative jurisdiction over the Marine Protection,
I'-escarch and Sanctuaries Act (Ocean Dunging Act) , I have ICIKJ been
(-•oncerned witli the practice of ocean dunping. The Ocean Dumping
Act authorization bill pending before the House of Representatives
jonti'tiiis an ^Diuncinont 1 offered to require the cessation of ocean
dumping of municipal waste by Decenber 31, 1981.
I am particularly concerned about the possibility of dumping
r-cwa-je sludge at the 106-Mile Duipsite. Ilie sensitivity of biota,
iho likely imxict on fisheries, the djfticulty of enforcenent, the
high p|-oLkibi lily of short dunps, and the almost-anpossible task of
(.horoujhly nojitoriricj adverse iiqwcts at the site clearly indicate
tlwt large-scale clunpiixj of sewage sludge at the 106-site could be
an eiivironnc-ntal nightmare.
I woul
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DEPARTMENT OP THE ARMY
N6W YORK DISTRICT. CORPS OP BNOINBER8
•• PKDCIUL PLAIA
MIW VQMt. M. V. IOOO?
NANEN'E
2 August 1979
Mr. Jo^n T. Rhett
Deputy Assistant Administrator
For Water Program Operations
U.S. Environmental Protection Agency
Oil and Special Materials Control Division
Marine Protection Branch
Washington, D.C. 20460
I
M
O
Dear Mr. Khett:
The New York District appreciates the opportunity to review the Draft
Environmental Impact Statement for the 106-Mile Ocean Water Disposal
Site Designation.
Hie Distric
counents co make at this time.
Sincerely yojrs.
f. A. DeSCENZ
Chief, Engineering Division
UNITED STATES DEPARTMENT OF COMMERCE
Th« Auisunt Secretary for Sctanra mod Technology
WuKinglon. D.C. 2O23O
12021377-jun 4335
August 31, 1979
Mr. John T. Rhett
Deputy Assistant Administrator for
Water Program Operations (WH-546)
Environmental Protection Agency
Washington, D. C. 20460
Dear Mr. Rhett:
This is in reference to your draft environmental Impact
statement entitled, "106-Mile Ocean Waste Disposal Site
Designation." The enclosed comments from the National
Oceanic and Atmospheric Administration and the Maritime
Administration are forwarded for your consideration.
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you. We
would appreciate receiving eight (8) copies of the final
environmental impact statement.
Sincerely,
Sdney R. Caller
Deputy Assistant Secretary
for Environmental Affairs
Enclosures
Memo3 from:
Mr. P. Kilho Park \J
National Ocean Survey -NOAA
Capt. George C. Stelnman
Chief. Environmental Activities
Group - MarAd
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UNITED STATES DEPARTMENT OF COMMERCE
Tna Aaaistant Sacratary lor Sclanca and Tachitnlofly
WuhinBton. 0 C 2OS30
12001 377XXH 4335
UNITED STATES DEPARTMENT OF COMMERCE
Maritime Administration
Washington. OC. 8O23O
September 11, 1979
Mr. John T. Rhett
Deputy Assistant Administrator for
Water Program Operations (WH-546)
Environmental Protection Agency
Washington, 0. C. 20460
Dear Mr. Rhett:
The Department of Commerce reviewed the draft environmental
statement by the Environmental Protection Agency relative to
the "106-Mile Ocean Waste Disposal Site Designation", and
forwarded comments to you in our letter of August 31, 1979.
Since that time, additional information has developed which
is pertinent to the project. This additional information is
offered for your consideration.
We are pleased to have been offered the opportunity to review
this statement.
Sincerely,
July 26, 1979
MEMORANDUM FOR:
.
Sidney R. (Jailer/
Deputy Assistantfecretary
for Environmental Affairs
Enclosure
Memo from:
Mr. Allen E. Peterson, Jr.
National Marine Fisheries
Service - NOAA if*
Dr. Sidney R. Caller
Deputy Assistant Secretary for Environmental
Affairs
Subject: EPA Draft Environmental Impact Statement for the
106-Mile Ocean Waste Disposal Site Designation
(June 1979)
The subject document has been reviewed, and the following
comments are submitted for your consideration:
5—1 !• Incineration at sea
It is noted on page 1-13 that one of the six types of ocean
dumping permits is the Incineration at Sea Permit. The subject
. discussion does not indicate whether the 106-Mile Disposal
Site will be used to incinerate toxic waste chemicals aboard
incinerator ships. Since proper incineration of many combustible
wastes would satisfy EPA's rigid marine environmental impact
criteria, it is recommended that this possible omission be
clarified.
2. International considerations, page I-1S
It is recommended that the discussion of the Ocean Dumping
Convention be expanded to indicate that the Convention has been
recently amended incorporating international regulations for the
control of/)incineration of wastes at sea to be enforced nationally.
(GEORGE t. STEINMAN
Chief, Environmental Activities Group
Office of Shipbuilding Costs
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w
N>
— 1
UNITED STATES DEPARTMENT OF COMMERCE
NMionil Oceanic and Atmospheric Administration
ENVIRONMENT At DATA AND INFORMATION SERVICE
Washington. O C 20235
Center for Environmental Assessment Services
August 15, 1979 OA/Dx61
TO: PP/EC - R. Lehman
PROM: OA/D2 - David Santa
SUBJECT: DEIS 7907.05 - 106-Mile Waste Disposal Sice Designation
Page A- 34, last sentence, paragraph three; The notion that silicate
is not ever a growth limiting nutrient in the marine environment Is
incorrect, (see F. A. Richards. J. Mar. Res.. 17, 449-465 (1958). see
also R. W. Eppley, et al.. Llnuiol. & Occanogr.. 18, 534-551 (1973)
(cap. pg. 543)).
The section on trace metals, pg. A- 30, should have Included the role
of phytoplankton in the cycling of cadmium in the sea (K. W. Bruland,
fct al. , l.imnol. & Oceanogr. . 23. 618-625 (1978) since this cycle may be
the firat of many phytoplankton-heavy metal cycles to be found. Further-
more, the Biochemical relationship between cadmium and phosphate in the
sea should have been discussed (E. Boyle and J. H. Edmond, Nature, 263,
42-44 (1976)) since it has implications for the primary productivity
Induced transfer of Cd to higher trophic levels.
Biological Chemistry, pg. A-40, paragraph onei The statement that
"The uptake of contaminants (e.g., trace metals) and their incorporation
into phytoplankton may have no apparent effect on the organisms" is
incorrect. My guess is that the authors have done an inadequate literature
survey. Cadmium, for example, decreases the growth rate of an Asterionella
species (J la Loin); whereas arsenic had no effect (H. L. Conway, J. Fish. Res.
Brd. of Canada, 35, 286-294 (1978). Other examples could surely be found
if an adequate literature survey was made.
Biological Chemistry, pg. A-40: Since petroleum concentrations are
discussed earlier (i.e., pg. A-36, A-37), the effects of petroleum on
phytoplankton should be discussed (for starters, see W, M. Duns tan, ct al. ,
Mar. Biol.. 31, 305 (1957); D. C. Gordon, Jr., and J. J. Prouse, Mar. Biol. ,
£2, 329 (1973); R. F. Lee and J. W, Anderson, Bull. Mar. Sci., 27, 127
(1977), W. M. Pulich, Jr.. etjiK , Mar. Biol.. 28, 87 (1974); C. Soto,
et al.. Can. J. Bot.. j>3, 118 (1975). K. Winters, et al., Mar. Biol.. 36,
269 (1976)). ~~
-2-
Pg. A-34, second paragraph, last sentence. Plants can also utilize
organic phosphorus, which is hydrolyzed by the plant to orthophosphate
(see, for example, E. T. Kuenzler and J. P. Perras, Biol. Bull.. 128, 271
(1965), E. R. S. Talpasayi, Biochem, Biophys. Acta.). 59. 710 (1962), and
Yentsch, ct al., Limnol. and Oceanogr.. 17. 772 (1970)). Note that the
implication of the Talpasayl paper is that the organic phosphorus hydro-
lyzing ability of algae can be Inhibited by trace metals.
Page A-34^ paragraph 1. The role of urea as a nitrogen source for
marine phytoplankton should have been mentioned. The urea cycle is a
phytoplankton/cooplankton/nekton medicated cycle, and oceanic and estuarine
concentrations of urea are often higher than the sum of nitrate plus nitrite.
A wide spectrum of marine phytoplankton are capable of growth on urea as a
6—2 sole nitrogen source. For example, see: D. S. Berns, et_ al., Science,
15, 1077-1078 (1966), S.A.M. Conover, Mar. Biol.. 32, 247-261 (1975). E.D.S.
Conner and A. G. Davis, Adv. Mar. Biol.. 9, 101-204 (1971), E.D.S. Conner
and B. S. Newell. Mar. Biol.. 47. 113-120 (1967), R. W. Eppley, et al..
Limnol. and Oceanogr.. 16, 741-751 (1971), R. W. Eppley, et al., Limnol.
and Oceanogr.. 14, 194-205 (1969). B. R. Grant, Aust. J. Mar. Fresh Wat.
Res., 18. 129-136. (1967), R. R. L. Guillard, in C. H. Oppenheimer (ed.).
Marine Microbiology. Thomas, pp. 93-104 (1963). C. D. Jeffries, Nature.
202. 930 (1964), J. W. Left ley and P. J. Syrett, J. Gen. Microbiol.. 77,
109-115 (1973), J. J. McCarthy. Limnol. and Oceanogr.. .15, 309-313 (1970),
C. C. Remsen. Limnol. and Oceanogr.. 16, 732-740 (1971), H. W. Smith,
J. Biol. Chem.. 81. 727-742. (1929).
Page _5-16_/ Survival of Pathogens. The discussion in this section is
too general and could be Improved. In particular, there is literature
which deals with the survival of pathogens in the marine environment,
particularly in shellfish. The absence of positive test results from
subsurface samples is not convincing. The dumping of sludge should
not be considered without intelligent research on pathogens. In particular,
shellfish should be examined for coliform bacteria in all seasons. Bacteria
D —J attached to small sludge particles could be eaten by zooplankton, so roo-
pLanktun in the region should be examined for pathogens, particularly since
these might be transmitted to other trophic levels. There is also some
literature on viral pathogens in the sea and their longevity. Some
laboratories are currently Involved in this research area. The possibility
of viral contamination or infection of shellfish, zooplankton, and nekton
should be dealt with, since viruses might be more stable in the marine
environment than bacteria, particularly In living organisms, and since the
human health hazards of viruses in shellfish may be as great as that from
bacteria.
AUG \ 6 1979
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UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Federal Building, 14 Elm Street
Gloucester, Massachusetts 01930 ^
flUt i S 1979
TO: EC - Richard Lehman
FROM: ffNE - Allen E. Peterson, Jr. j '
SUBJECT: Comments on Draft Environmental Impact Statement
106-Mile Ocean Waste Disposal Site Designation
(EPA) (DEIS 47907.05)
i^
The draft environmental impact statement for 106-Mile Ocean Waste
Disposal Site Designation that accompanied your memorandum of July 10, 1979,
has been received by the National Marine Fisheries Service for review and
comment.
The statement has been reviewed and the following comments are offered
for your consideration.
General Comments
We generally agree that chemical waste disposal at the 106-Mile Site
Is preferable to alternative ocean sites examined in the EIS. Deepwater areas
provide a greater potential for dilution and dispersion of wastes, and are
generally less biologically productive than nearshore coastal waters.
Me believe, however, that the potential adverse Impacts at site have
been understated. It has been assumed that because no significant Impacts
have been identified to date, that none have occurred. Data collection at
site has been inhibited because of the difficulty and expense associated
7*~ 1 with sampling deepwater areas. The situation has been further complicated
due to the complexity of circulation patterns at site. Consequently, we do
not believe that adequate data currently exist to warrant such a conclusion.
Furthermore, the biological effects of long-term, sub-lethal exposure to
contaminants cannot be adequately assessed with available data.
7 — 2 The EIS fails to discuss all potential alternatives to the proposed
action. Although relocating the 106-Mile dumpsite is thoroughly explored,
no consideration was given to limiting its size, such as restricting dumping
to less biologically productive areas.
Specific Comments
Specific comments, for the most part, have been limited to those sections
which address the subject dumpsite, the 106-Mile Site. Few remarks have
been made regarding deficiencies in descriptions pertaining to alternative
sites, since it is unlikely that they will replace the 106-Mile Site.
7-3
7-4
7-5
7-6
Chapter 3 AFFECTED ENVIRONMENT
THE PROPOSED 106-MILE SITE
Biological Conditions
Other than recognizing that plankton, fish, invertebrates, mammals,
and turtles exist at the 106-Mile Site, this section provides no biological
Information for the reader. The reader is not so much as referred to
Appendix A for additional information! Some description of basic biological
assemblages should be discussed. The reader Is given the impression that
Continental Slope areas In general, and the dumpsite in particular, are
biologically depauperate, which is not the case.
Page 3-7, para. 1; This paragraph does not describe the meroplankton
omponent of the planktonic community, which often contains the larval stages
f economically Important species. In the May 1974 Baseline Investigation
f Peepwater Dumpsite 106 (NOAA Dumpsite Evaluation Report 75-1), it was
eported that the larvae of several commercial flnflsh were collected;
arvae of shelf-spawning blueflsh and hake were particularly abundant.
Larval forms of economically important invertebrates, such as lobster, red
crab, and squid, are also expected to occur in the dump site and vicinity.
As stated on page 4-10, last paragraph, acid wastes can cause embryonic
malformations; therefore, some degree of impact to commercial species can
be anticipated.
Page 3-7f para. 4; The treatment of rare and endangered species Is
Inadequate and should be expanded. Some description of those species more
likely to occur at site should at least be Included. Some endangered species,
such as the right whale, survive in such low numbers that injury to an
individual could impact the entire population. Conceivably, the nature and
volume of discharges at the 106-mile site could detrimentally affect Individ-
uals of severely stressed species.
OTHER ACTIVITIES IN THE SITE VICINITY
Page 3-8. para. 4: The work of Wlgley et al. (1975)1 indicates that
red crabs found In deeper areas are young and migrate up-slope as they grow
older. Therefore, any red crabs found in and adjacent to the 106-Mile Site
would not be harvested in place, but would rather serve as recruits to com-
mercial populations in shallower waters. Since red crabs In or adjacent to
Wigley, Roland L., Roger B. Thcroux, and Harriett E. Murray. 1975.
Deep-sea red crab. Caryon quinquedens, survey off northeastern
United States. Marine Fisheries Review 37(8):1-21.
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td
7-7
the site would not normally comprise part of the harvest, the remarks
regarding the Inefficiency of a fishery at site are Inappropriate.
ALTERNATIVE SITES IN THE MEW YORK BIGHT
Biological Conditions
Page 3-14. para. 3: The ocean quahog must be regarded as a real, not
potential, fishery resource. The importance of this species has markedly
Increased following the mass mortality of surf clams in the New York Bight
during the summer of 1976. The 1978 ocean quahog harvest was more than
23.5 million pounds of meat; or nearly 40Z of the total sea clam harvest.
CHAPTER 4 EHVIROHMEHTM. CONSEQUENCES
Commercial and Recreational Fish and Shellfish
106-Mlte Site
Page 4-4. para. 2: We reiterate our former comment that red crabs
found in and adjacent to the 106-Mile Site are not expected to be harvested
in place, but are rather potential recruits to the fishery.
Furthermore, even if the red crab is not appreciably affected by the
discharge in its benthic node (as is surmised in the discussion), its
planktonic larvae most certainly could be impacted.
Effects on the Ecosystem
Page 4-9. para. 2: We concur that the "scenario" relative to the long-
term adverse effects resulting from chronic exposure to sub-lethal concen-
trations of toxic materials is overly simplified. It is impossible to deter-
mine whether or not such ijnpacts are developing at the 106-Mile Site.
The insidious nature of these impacts nakes detection, especially in the
short-term, extremely difficult. Once detected, associating a causative
agent to a symptom and identifying the source of that causative agent is
even more difficult. The current body of data for the dumpalte is not
extensive. That which does exist only demonstrates the complexity of the
system and our lack of understanding concerning its functioning. The impli-
cation made in this statement that Industrial discharges at the 106-Mile
Site will not affect human food resources is unfounded. Our present degree
of knowledge prohibits any credible prediction in this respect.
106-Mile Site
Page 4-11. para. 4; Statements made In this paragraph echo our previous
comments relative to the general lack of underatanding regarding the
ecological dynamics at the dumpslte. We believe greater emphasis should
have been placed on this deficiency and less placed on convincing the reader
that no significant Impacts will occur from discharging Industrial wastes
at the 106-Mile Site.
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8-1
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NAVIDNAI or;rAN iitinui Y
tlackvillit. MJ. cfOHS^
August 10, 1979
OA/C22:KP
TO: OA/C52x6 _ Judith Raines
FROM: OA/C22 - P. Kilho Park
SUBJECT: Reading of DEIS for 106-Mile Ocean Waste Disposal Site
Designation
The central issue in this DEIS is "whether or not the 106 site being
a good location for ocean dumping?" For this central issue, the two
reasons out of five given on page xi on Environmental Consequences are
appropriate. They are (1) high dilution and (3) low productivity. The
remaining three are either Irrelevant or do not require any extensive
discussion. The reason (2) of "lack of fisheries" at 106 site is a
simple fact, although Japanese are known to harvest squids from there.
The reason (4) of "much Is known about the site" being a good reason
for choosing it over another deep-site is not relevant on the selection
of 106 over the alternative shallow sites. Me will discuss it compre-
hensively in our specific comment sections. The. reason (5) of there
being "no non-dumping uses of the sites" Is a simple fact.
The present DEIS states heavily the general issues of whether the
ocean should be used for waste disposal. However, it is not the specific
Issue here and its extensive discussion is inappropriate. However, if it
Is the intent of EPA to deal with such a profound issue once in order to
educate the general public, let it be stated only once, not repeating
in the forthcoming 25 additional EIS' concerning ocean water disposal
site designations by EPA and IEC (Interstate Electronic Corporation).
The two good reasons, high dilution and low productivity, will be
discussed separately.
(1) High Dilution
The depth of the 106 site relative to all alternatives which are
shallower Is its greatest advantage. The objective of dumping waste
into the sea Is to achieve wide dispersion and, therefore, extensive
dilution. As long as waste is in the water column, it is subject to
horizontal dispersion. When It reaches the sea floor, it may persist
in one location and accumulation of waste is possible.
Horizontal mixing is not uniquely effective at the 106 site. Our
observation is that barge generated turbulence is very effective 1n
il fiPfa
1 6 1379
diluting waste by about a factor of 10 . Subsequent dilution Is due to
oceanic processes which may be slow so that waste concentrations in the
5 to 50 ppro range may persist for a long time, often over 60 hours.
Episodic events, I.e., storms, must be the mechanism for accelerated
waste dispersion.
Vertical mixing seems to be limited by the pycnocline. Even in
winter there Is a pycnocline in the deep ocean. At shallower sites the
ocean is homogeneous to the bottom in winter. Cross-pycnocllne mixing
Is not impossible: it Is just very slow. Haste Is, therefore, diluted
within the mixed layer at all sites. Waste concentrations are determined
by the rate of dumping (volume per length of dumping track), barge
generated turbulence, and oceanic processes. At shallow sites It can
accumulate on the bottom, thus affecting non-mobile benthic organisms
which may be of commercial value. The lack of a benthic effect at 106
Is probable and is a great advantage to Its use.
(2) Low Productivity
Since the standing crop of DUD-106 site often is less than that
of the on-shelf, the total damage done to the biota is smaller than
that of the on-shelf. However, on indigenous organisms we must con-
sider the degree of sensitivity between the oceanic and the shelf
organisms to assess their damage due to ocean dumping.
If there were no benthic effect at shallow sites, the choice
between those sites and 106 would have to be on the basis of possible
consequences to organisms in the mixed layer. In terms of commercial
fisheries, their apparent absence from 106 is in Its favor as a dump-
site. In terms of deep ocean waters being Inherently less productive,
less total damage is possible at 106. However, it has been shown that
oceanic phytoplankton are more sensitive to wastes than similar organisms
taken from heavily used coastal areas. Therefore, while it probably is
so that waste dilutions are extensive enough to minimize effects in the
mixed layer, effects are more likely at 106 than at alternative sites.
The fact that no effects have been demonstrated Is due to earlier
biological sampling not being done in recognition of the discrete nature
of waste distributions. Unless a storm occurs, a plume from a single
dump may contain waste at a maximum concentration of only 50 ppm but
It is only about 1 km wide, even a day or two after a dump. Biological
effects must be sought in these discrete plumes. Sampling at arbitrary
locations within the dumpsite will probably be futile because waste
will most likely not be encountered.
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7
Our specific conments follow:
Page vll, line 30: In accordance with PL 92-532. Section 201, NOAA Ocean
Dumping and Monitoring Division 1s conducting trend assessment sur-
vey at DWD-106 and other sites. NOAA has visited DWD-106 site 9
times. They are Hay 1974, July 1975. June 1976, August-September
1976. July 1977, January-February 1978, April 1978. June 1978.
April 1979. The next survey is scheduled for September 1979.
EPA works well with NOAA on dumps He trend assessment.
Page viii, line 11: Please give the location of "adjacent off-shelf
area" that has been evaluated.
Page ix, line 20-22: The sentence given here does not mean there Is
no impact. Biological sampling until now has not recognized well
a discrete distribution of waste. Obviously, arbitrary sampling
locations within the site are not useful. In addition, as it is
made clear in the report (Page 4-26), there are a number of reason-
able short-term ecological and physical impacts of dumping which
occur.
Page ix, line 22-24: This sentence exemplifies a misuse of grammatical
tone that appears many places in the report. The statement uses
the indicative mood, and says that the site is not highly productive
because it is oceanic. The statement would be of better scientific
form if phrased in the subjunctive mood. Something to the effect
of "The site is oceanic and, typical of surrounding waters, does
not appear to be highly productive.,." The site 1s probably never
very productive, particularly in comparison to nearby shelf waters,
but a conclusive data base demonstrating it is not given.
Page ix, paragraph 4, line 18-24: The paragraph given here should mention
that both ammunition and radioactive wastes were dumped in this
vicinity. For Instance, during 1951-56 and 1959-62, 14,300 drums
of radioactive wastes containing 41,400 curies of radioactivity
were dumped at latitude 38°30'N and 72°06'W, 10 nautical miles
south of the southern edge of the DWD-106. EPA and other concerned
Federal agencies have been carrying out a comprehensive ocean dump-
ing effect study of these radioactive wastes. Their work is still
continuing.
Page ix, footnote: The footnote given here is Incorrect. It is the
size of plumes and the frequency of dumping relative to the residence
time of water which minimizes the possibility of one waste plume mixing
with another. The geographic size of the site 1s not critical.
Page xi, line 8. bullet 1: Depth Is very important. Physical dispersion
is due to barge and oceanic processes. Horizontal dispersion is
not uniquely effective at DWD-106. The nature and magnitude of
the vertical diffusion and dispersion data at the site are yet to
be determined.
Page xi, line 19. bullet 3: According to Dr. Lynda Murphy of Woods Hole
Oceanographic Institution, phytoplankton from clean areas are more
susceptible to waste than from contaminated areas. The statement
of "...less likely to afffect indigenous organisms" Is not correct.
Page xi, line 21. bullet 4: The availability of data for predicting
future Impacts in the area may be overstated. Although a good bit
of information exists about DWD-106, scientifically accurate long-
term predictions of future Impacts of dumping at the site appear
premature.
Page vi, line 26, bullet 5: Good reason, though not critical. What
would be the relationship between the proposed use and the past
uses? For instance, would future dumpings facilitate the decay
fi—2 °f ttie radioactive waste drums by providing foods for deep-sea
bacteria?
Page xii, line 6-12: Organisms at DWD-106 may be more sensitive than
those at alternative sites. Nevertheless, observed dilution should
be adequate.
Page xij, line 22: Please elucidate "under certain restriction."
Page xiii, lines 3-5, bullets 1-2: Both these criteria would lessen
settling. On bullet 1, lines 3-4, density and size of solid
particles should be considered when settling Is considered.
Page xiii, line 7: DWD-106 site is deep. The use of demersal, bottom-
dwell ing, organisms does not appear applicable here.
Page xiii. lines 9-12, bullet 4: We have detected waste up to 60 hours
after dump and also at outside of the dumpsite. That does not
imply detrimental effect, but it reflects on precision of measure-
ment and on choice of appropriate waste indicators.
Page xiii, lines 26-27: NOAA is mandated to carry out, by PL 92-532,
a comprehensive monitoring program. It is not mandated to receive
EPA's approval. There is an interagency agreement, signed In 1975.
between EPA and NOAA to coordinate their respective mandates. See
page 1-6, lines 7-13.
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Page x(11, line 27 - Page xiy, line 2: Monitoring by permittees may
benefit from analyses of species composition but only if simultan-
o—3 eous measurements of oceanic waste concentrations are made. The
present 4-hour dispersion study may be too short.
Page xiii, lines 2-5: We agree that these studies should be carried out.
Page xx, lines 6-7: C and D are reversed.
Page 1-7. Table 1-1, lines 15-16: Add "Comprehensive ocean dumping
impact and short-term effect studies."
Page 1-8. between lines 10 and 11: Add "...short-term effects and
potential long-term effects of " The short-term effect
study is mandated by Section 201 of PL 92-532.
Page 1-8, lines 12-13: PL 92-532 gives the responsibility for conduct-
Ing field investigations for comprehensive studies of ocean disposal
effects to Department of Commerce, NOAA; it is not given to EPA.
EPA is responsible for Title I of the PL 92-532 which provides
a mechanisms for regulating ocean disposal of waste. This E1S
work is concerned with Title 1.specifically Section 102(c). For
the site designation work, EPA presently is carrying out field
investigations.
Page 1-12, lines 31-33: Suggested change - "Once a site is selected
and duly designated, permits for the use of the site can be Issued
by CE for dredged material dumping and by EPA for others."
Page 2-4, lines 12-15: How do the past uses of the site and its vicinity
for munition and radioactive waste dumping affect the monitorability
of the site. Is there any Inherent complexity and danger involved?
On line 14, 9 kilometers should be 18 km.
Page 2-4, lines 24-29: It is true that there 1s little, if any significant,
U.S. fishery operations in and near the dumpsite, but there has been
and possibly still Is significant foreign, including Japan and Poland,
fishing within the site Itself. Specifically, Japanese fish for
squids. It should be noted that squids migrate vertically in daily
rhythms and might possibly feed at depths where wastes have been
shown to accumulate.
Page 2-5, lines 1-2: Because we have not seen "long-term adverse
effects..." in our studies does not mean this is so. It would be
better stated, "Thus far, studies have shown no long-term effects...."
Page 2-5, line 21: Please quantify "... in deep water where currents are
strong...." It may not be "strong."
Page 2-7. lines 6-7: Sludges seen acoustically at 60 m were below the
seasonal pycnocllne at 15 m. Therefore, It appears that sludges
did penetrate the seasonal pycnocllne at 15 m.
Page 2-7, line 20-21: Please give the calculation to obtain "2 percent
additional nitrogen to the site." The conclusion given here appears
Q . correct, assuming the calculation is valid. However, in reality it
a—1* is impossible to distribute waste throughout the site. The residence
time of one waste plume within site Is in the order of one week or
less; the waste does not spread to 1600 km In that time.
Page 2-8, line 23: The weight of the waste given as "612 metric tons"
appears to be In error. Could it be "612,000 metric tons"?
Page 2-9, line 4: Change to "NOAA is responsible for comprehensive and
continuing monitoring." It is mandated by PL 92-532, Section 201.
Page 2-20, line 18: Add a new sentence, "Starting September 1979, EPA
and NOAA jointly monitor both the acid waste and sewage sludge
disposal sites which are nearby to each other."
Page 2-22. lines 22-23: Change sentence to "EPA Region III and NOAA
have a joint ongoing monitoring program...."
Page 2-23, lines 7-8: Although Pesch et a1_. (1977) indicate that the
Delaware Bay site has been contaminated by acid dumping (vanadium
being one indicator of this), there is a growing body of information
being gathered indicating that a major contributor to pollution
problems at this site is, in fact, sludge dumping at the nearby
Philadelphia sludge dumping site.
Page 2-30, lines 10-20, paragraph 2: If in future any other off the
continental shelf site is to be sought, it would be prudent for
us to avoid the old munition and radioactive waste dumpsites whose
impacts we have not studied thoroughly.
Page 2-31, lines 2-6: It appears that DWD-106 is the best choice
for dumping of the areas considered. Yet, overall adequacy of the
9—5 existing data base for predicting future Impacts is questionable.
In addition, the future DWD-106 site use should consider any probably
interaction with the previous munition and radioactive waste dumpings.
Page 2-31, lines 20-21: The key word here is "demonstrated." We never
can say that there are no effects. If effects occur, they must be
within discrete plumes, not everywhere. Unless we look for the
effects scientifically, with effective monitoring strategies, our
chance of the effects "demonstrating" themselves and perceived by
us is slim.
-------
oo
Page 2-31, line 23; Change "aqueous materials" to "wastes", for dispersion
of solids 1s enhanced also.
Pages 2-33 to 2-36. Table 2-3: Hell done summary evaluation of effects
at the sites In consideration. On page 2-35, line 3, In 106 mile
site column, delete "extremely slight" and substitute with "some
difficulty In monitoring "
Page 2-38, lines 23-26: Please consider the bottom, sea floor, surveillance
and monitoring in light of the past munition and radioactive waste
ocean dumping.
Page 2-39. line 12: Substitute "demonstrated" with "observed." If we
do not look for properly, we would not observe the effects of
current and previous discharges and dumping. Both munition and
radioactive waste dumpings that occured in the past should be
scrutinized before stating "no effects have been observed."
Page 2-41, lines 16-17, bullet 5: This is not the case now. Waste has
been found outside of the site. However, finding waste is not the
same as showing it to have environmental consequences.
Page 2-42, lines 1-15, paragraph 1: The statement given here is vague.
Assimilative capacity here must mean room for dilution without
mixing one waste with another. Here the mean transport of water
through the site is important. Mixing over 4 hours Is not dependent
on transport time.
Page 3-4, line 7: "20d meters" should be changed to "100 meters" since
this is actually what is shown In Appendix A, pages A-18 to A-20.
'...and for short-term impacts
Page 2-43, line g: The line should read,
by NOAA and environmental "
Page 2-43, lines 10-11: The sentence should read, "All
monitoring studies are subject to EPA approval."
Page 3-1, lines 26-30: Eastward migration of the Shelf/Slope Front
allows less dense Shelf Mater to overspread Slope Water, forming
a separate, relatively thin surface layer. Please note that "mixing"
would tend to erase these water masses of differing density and hence
the terra should not be used. "Overspreading" would be a much better
term.
Page 3-3, line 2: "other water" should be "shelf water."
Page 3-4, line 3: "forming layers of water...and density." should become
"forming a seasonal thermocllne," since the causative factor for the
phenomenon is warming of the surface waters in late spring, (page 304,
line 1).
Page 3-4, lines 11-16, paragraph 2:
than 0.2 knots should be used.
An approximate current speed of less
Page 3-4, lines 27 and 30: Hay we suggest "great diversity" (line 27)
and "high concentrations" (line 30) when their modifiers for "greater
than" and "higher than" are not stated. Regardless, semiquantlfica-
tion of these words will clarify their meanings.
Page 3-5, line 16: On the unit of dissolved oxygen, a preferred choice
may be volume over volume, ml/liter, or weight over weight, mg/kg,
not weight over volume, mg/liter, as used in DEIS.
Page 3-5, lines 19-22: There is continuous mixing in the ocean by either
large scale turbulent mixing or small scale eddy diffusion. The
permanent thermocline beginning around 200 m prevents large scale
mixing. However, small scale vertical diffusion does occur. Large
storms passing through the area will only temporarily disrupt this
feature if at all.
Cross thermocline mixing is slow but not impossible. One of the
NOAA study objectives is determining the mechanism and rate of each
mixing.
Page 3-6, lines 11-15: Difference in metal levels between continental
rise and shelf sediments is due partly to particle size difference.
Page 3-8, line 4: The sentence should start. "NOAA Ocean Dumping and
Monitoring Division and Ocean Pulse Program plan to continue
monitoring the 106-Mile site.
Page 3-10, line 22: Density is a function of temperature and salinity.
Perhaps the words "and density" should be changed to "hence density."
Page 3-39, lines 8-10: This sentence may be read "The toxic effects of
duPont's waste on were investigated by routine bioassays and
special tests." Please clarify "special tests."
Page 4-5, lines 25-30, paragraph 4: The Delaware Bay site summary is
welt done, but the authors may want to expand the discussion a bit
to Include the somewhat contradictory findings of Pesch (1977) on
one hand, and of Guarino and Almeida (1979, J. Water Pollution Con-
trol Fed. 51(4): 773-78) on the other hand.
Page 4-10, lines 23-27: General phytoplankton surveys will show natural
variations. We must do a time series study within waste plume to
understand the waste intact upon plankton.
-------
Page 4-11, lines 4 and'5;
data.
Delete lines 4 and 5. These are not laboratory
v£>
Page 4-11. between lines 19 and 20, between paragraphs 2 and 3: A para-
graph on phytoplankton may be placed here. Laboratory effect studies
carried out by Murphy of Hoods Hole Oceanographic Institution show
the susceptibility of the effect a function of source of organism.
Oceanic clones are more sensitive than those from polluted coastal
areas.
Page 4-11, lines 32-33: What has not been recognized in earlier biota
sampling is the discrete nature of waste distribution. Time series
of phytoplankton effect studies now can be done at sea.
Page 4-11, lines 28 (last line): On Hater and Sediment Quality organic
toxicant study description, such as on DDT and PCB, is lacking. It
should be added.
Page 4-12, lines 4 and 5: The statement "...that within four hours after
dumping the values are within normal values..." is not so totally.
Only those constituents which are at background levels after dilu-
tions of 10 are undetectable as being waste derived. Other con-
stituents have been identified and used as tracers of waste over
much longer times.
Page 4-17, lines 9-25: The quoted NOAA statement concerning metals was
correct in 1977. However since then duPont Edge Moor dumping has
added a large amount of iron to the site in comparison to normal
concentrations. This should be mentioned.
Page 4-17, line 27: Delete "not." NOAA investigations did detect elevated
concentrations above ambient conditions after the initial mixing
period.
Page 4-17, line 31: These "worst-case" models are misleading. However,
if the waste-driven metals are allowed to accumulate throughout an
eddy, we must use an area of an eddy, not the area of DUD-106, to
calculate models.
Page 4-19, lines 1-8: Contamination is a problem and must be considered.
It is not Insurmountable. The fact that metals are 1n ppb (parts per
billion) range does not mean they are not exerting a biological
effect. Effects depend on concentration and speciation of metal.
For copper, its concentration of 10 molar has been shown to
affect phytoplankton growth.
Page 4-26, line 24, bullet 2: Suggest the following revision - Rise
in the concentrations of waste constituents In the upper water
strata.
10
Page 4-27. lines 3-4: Delete lines 3-4, for DUD-106 Is deep, not shallow.
Page 4-27, line 21: The quoted "several years of studies" were not well
designed to elucidate the long-term effect.
Page 4-28, line 7: Please name the valuable metals.
Page 4-28, lines 10-13, bullet 3: If ocean dumping is less expensive
8—6 tnan land-based disposal, It is economical gain, not loss. Suggest
deleting lines 10-13, bullet 3.
Page 5-1, line 20: May we suggest that the sentence be read as follows:
"...alternatives are being developed and adequately field-tested."
It Is the Intention of the Ocean Dumping Act, PL 92-532, to protect
human health. Any unproven alternative method Is too risky to take.
Page 5-6. Table 5-2: The chemical concentrations listed have come from
the works of Professor Mueller and his coworkers. Since those data
must be valid scientifically and legally at court of law, it Is
important to give their accuracy and precision. For instance,
duPont Edge Moor waste is reported to have a pH range of 0.1-1.0
signifying the waste is highly acidic. However, in reality, the
duPont waste often contains 2 to 4 molar hydrochloric acid which
8-7 would give pH values of less than 0. Therefore, the pH range
given in Table 5-2 is theoretically erroneous. These discrepancies
will not withstand the scrutiny of the court of law should it become
an issue. In fact, this DEIS does not give any consideration on the
scientific data assurance. It should be dealt with to show to the
public the state of art of the scientific measurement, however crude
and ambiguous at present.
Page 5-7, lines 33-35: The first reason given here should consider that
the added sludge will increase biological productivity. However
sparce, phytoplankton can double its population once every several
• o_p hours. The reduced supply of nutrients, the reason given here, is
' not totally valid. In addition, there is no assurance that off-shelf
water is colder than shelf water. The reverse may be the case for
DUD-106 site.
Page 5-8, lines 9-10, bullet 1: Since DHD-106 site is farther than
other alternative sites considered, it may contaminate beaches less
than other sites.
Page 5-8, lines 11, bullet 2: Oceanic, scientific, budget calculation
is needed to understand whether or not deep-sea anaerobic environ-
ments can develop.
Page 5-9, line 10: Please insert "DWD-106 site" after "a Camden sludge dump.
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n
12
N]
o
Page 5-9, lines 17-18: It cannot be proven that secondary sludge would
be more rapidly dispersed than that of primary. If It were buoyant,
probably It would not be.
Page 5-10, lines 2-4: Please consider deleting "...could be viewed as "
Our reasoning Is that three-dimensional oceanic dispersion Is always
highly anisotropic, and horizontal dispersion is always many orders
of magnitude larger than vertical dispersion, particularly after
initial mixing. Our suggested change is "This 1^ an anisotropic "
Page 5-10, lines 5-15: It may be beneficial to add a statement on the
differences between speeds and residence time for wastes dumped in
slope currents vs. Gulf Stream eddies.
Page 5-13, Table 5-4: Please consider the accuracy and precision of
these metal concentrations.
Page 5-14, Table 5-5: Please consider the accuracy and precision of
these nutrient concentrations. For instance, as they are given, the
background nitrite pli£ nitrate concentration of 19.2 mg/liter implies
its relative precision of about 0.5 percent with a range of 19.15 -
19.24 mg/liter. If so, It should be spelled out. The same applies
to phosphate.
The nitrite plus nitrate/phosphate ratio given here is 19.2/124 « 0.17.
This ratio contradicts with the nitrogen/phosphorous ratio in the sea
of 15:1 given in Page A-34, line 14, by almost 90 times.
Page 5-15, line 11: May we suggest "desorb" in lieu of "deadsorb."
Page 5-16, lines 3-7: The second sentence on the page is too confusing to
interpret, and the information in the sentence should be supported
with a reference to its source. This matter of references to sources
of information applies to many sections of the DEIS. Although the
literature citations included in it are generally adequate, all
statements referring to specific factual information should Include
a reference to the original source of the facts.
Page 5-17, line 11: Substitute "the water column" with "seawater."
Sewage microorganisms die off quickly in seawater, not in the water
column.
Page 5-20, line 3: Please explain "...carefully controlled conditions...."
Page 7-9, line 6: '>g/l" should read "micrograms per liter" not "milligrams
per liter."
Page 7-12, lines 1-3: Hay we suggest the following pH definition, "A
term used to describe the hydrogen ion activity in minus logarithum.
Conventionally, pH 7 1s considered neutral, less than 7 acidic, and
greater than 7 alkaline."
Pages 7-17 to Pages 7-37: Extensive listing of pertinent scientific
references Is applauded. Please cite all of these references
precisely, so that they can be used by others. For Instance,
Dr. M. Orr's works cited as "Orr, 1977ab" can be cited exactly
by giving page numbers, sources, etc.
Page A-5, lines 8-18, paragraph 2: Please give a T-S diagram for the
shelf- and slope-waters and their adjacent water masses. They
will show to the readers how well these water masses are separated
and are identifiable.
Page A-6, lines 25-36, paragraph 3: The first sentence of this paragraph
should be clarified that there are high temperatures in the summer
and low temperatures in the winter. A clearer statement leading
into the "cool cell" is needed.
Page A-10, Figure A-2: Please give the description of horizontal and
vertical coordinates.
Page A-27, line 12: Oxygen is needed by aerobic not by anaerobic organisms.
And, there exists anoxic regions in the sea where these anaerobic
organisms live.
Page A-27, lines 25-27: The saturation level of dissolved oxygen with
respect to the atmospheric oxygen level in seawater is dependent
on the temperature, salinity, and barometric pressure of the wet
atmosphere at sea surface. At the great depth of the ocean, where
no atmospheric phase exists, its oxygen level is determined by the
temperature, salinity, and barometric pressure before that water
left the sea surface. Subsequent mixing among different water
masses and types and in-sltu biochemical alteration, both phyto-
synthesis and respiration, modify the oxygen content of the water
under study.
Page A-28, line 3: Substitute line 3 with "oxygen below the saturation
level suggests that biochemical oxidation, including respiration
and bacterial activity, is removing...."
Page A-28, Figure A-13 and Page A-29, line 9: Two oxygen units are used
in these two pages. They are "ml/liter" in Page A-28 and "rog/Hter"
in Page A-29. It would be better to use a single unit, either
volume/volume (ml/liter as shown in Page A-28). or weight/weight
(mg/kg).
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13
14
Is)
Page A-29, lines 9-10: There appears some unit discrepancy between
surface oxygen values of 4.9 and 7.5 tag/liter for August and
April respectively, given 1n Page A-29, with that of 4.9 and
7.5 ml/liter for the corresponding months given in Page A-28.
Does this imply that these two units (dig/liter and ml/liter)
are interchangeable? We calculate 1.00 mg/llter oxygen is
equivalent to 1.43 ml/liter oxygen.
Also, please show how you obtained the oxygen saturation values
of 104 and 113 percent respectively for August and for April.
Page A-30, lines '1-20, paragraph 2. This paragraph contains several
ambiguous and erroneous scientific statements. Hay we suggest
the following paragraph to be substituted in lieu of the DEIS,
Page A-30, lines 4-16 of paragraph 2.
"The expression pH is used conventionally to measure the acidity
or alkalinity of an aqueous solution. The scientific definition
is -log A , the minus logarithm! of hydrogen ion activity.
A neutral solution normally has a pH value of 7 at 25 C, while
acidic solutions lower than 7, and alkaline solutions higher than
7. The advantage of the pH scale is that its range is only from
0 to 14 from 1-molar.UCl to 1-molar NaOH, where hydrogen activity
varies from 1 to 10 . The pH scale can be smaller than 0 as
well as can be greater than 14 when HC1 concentration exceeds over
1 molar (duPont Edge Moor wastes have 2 to 4 molar HC1), and NaOH
over 1 molar concentration respectively.
Surface seawater pH is often 8.2 - 0.4, thus slightly alkaline.
This narrow range is maintained by the global and geochemical
silicate and carbonate mineral equilibria. At sea surface the
air-sea exchange of carbon dioxide tends to restore any perturba-
tion of pH value back to about 8.2.
The alkalinity of seawater is defined as the sum of anions of weak
acids ^resent in seawater plus hydroxide ion, OH", minus hydrogen
ion, H , concentrations. Alkalinity is important for fish and
other aquatic life because it buffers pH changes that occur in
nature, such as by photosynthesis and respiration and by ocean
dumping of acid and alkaline solutions. Two main weak acids in
seawater near the sea surface are carbonic and boric acids.
Alkalinity is Increased by the dissolution of carbonate minerals.
such as limestones, and decreased by the precipitation of carbonate
minerals, such as oolite deposition over the Bahama Bank. Most of
the time alkalinity of seawater can be calculated by the empirical
equation of alkalinity (milliequivalent/kg = 0.061 x salinity (g/kg).
Page A-30. line 14: According to Webster's New World Dictionary of the
American Language, Second Edition, 1976, the word "complex" is
either "adjective" or "noun", not "verb." Until the majority of
the American people use "complex" as verb, should we use it as
adjective or as noun?
Page A-30, pH and alkalinity: The pH values for the 106 site are given on
lines 21-23.Please give the site's alkalinity value since It Is
Important for marine life.
Page A-31, line 16: Substitute "complexatton" with "complex formation."
Page A-12, line 3: "complex" not "complexed"
Page A-34, line 14: The statement of the first sentence of paragraph 3
is not true. The nitrogen-phosphorus ration near sea surface varies
greatly. For Instance, the data given In Table 5-5, page 5-14,
yield N/P ratio of 0.17 which 1s 90 times different from the
ratio of 15:1. The changes In nitrogen compounds and phosphate
compounds concentrations may be approximately 15:1 as shown 1n
the classical work of Redfirled and his coworker at Woods Hole
Oceanograph Institution (cited by Richards, F. A., 1965, Anoxic
basins and fjords, p. 611-645. In J. P. Rile and G. Shirrow (eds.)
Chemical Oceanography, v. 1. Academic, London).
Page A-35, Table A-9: Please give the basic seasonal variation pattern
of the phosphate and nitrate distribution with illustrations. The
Table A-9 does not permit to examine the criticallty of nutrient
distribution at DWD-106 site.
Page A-38, line 22, Trace Metals: Please give the state of analytical
precision on the trace metal determination. The same applies to
Organics ("organic" is adjective not noun) section on Page A-39.
The issues of the precsion and accuracy on trace matter analyses
has been debated heatedly in many areas of science. How good are
we for DWD-106 site designation study?
Page B-1, lines 18 and 25; Page B-2. Figure B-l, line 2; Page B-3, Table
B-l; Page B-4, line 3, line 10, line 15; Page B-5, Table B-2. line 23:
"Metric ton" is a unit for weight, not for volume.
Page B-7, line 14: "196,820 liters (52,000 gallons)" waste release
rate regulation may be simplified to "200,000 liters per nautical
mile." In mathematics, one cannot attain five significant value
conversion (196.820 liters) from two significant value entity
(52.000). On Page B-8, last line, it is difficult to conceive
that duPont-Grasselli has disposed of 225.572 kg (six significant
numbers) of phenol at the 106-mile site.
Page B-12. Table B-8: The pH range for duPont Edge Moor, 0.1-1.0. does
not appear correct. If the duPont waste contained 2 to 4 molar HC1,
the lower value should be less than 0.
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DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE
PUBLIC HEALTH SERVICE
August 21, 1979
W
NJ
9-1
Mr. T. A. Wastler
Chief, Marine Protection Branch (WH-548)
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Wastler:
We have reviewed the draft environmental impact statement (EIS) for
the 106-Mile Ocean Waste Disposal Site Designation. We are responding
on behalf of the Public Health Service.
We believe continuing the selected 106-mile chemical waste disposal
site as proposed in this document will not pose any direct human health
effects. However, to avoid the accumulation of chemical contaminants
in the surrounding area, we feel a regular monitoring program should be
implemented around the site, especially after sludge or acid waste
disposals are made. In view of past monitoring data gathered by NOAA,
further studies involving cytotoxlc effects on fish eggs and histopatho-
logic lesions on fish in the vicinity of the site should be investigated.
Thank you fur the opportunity of reviewing this document. We would appre-
ciate receiving a copy of the final statement when it is issued.
Sincerely yours,
^
.£&
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Bureau of State Services
10
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
ER 79/676
SEp 1 4 1979
Mr. T. A. Wastler
Chief, Marine Protection
Branch (WH 548)
Environmental Protection Agency
Washington, D. C. 20460
Dear Mr. Wastler:
This Department has completed its review of the draft
environmental statement for the 106-Mile Ocean Waste Dis-
posal Site Designation la the Atlantic Ocean between Delaware
Bay and Long Island, New York.
This envi
the envir
continued
accordanc
based dis
at these
by-case b
statement
the propo
find that
not appea
of this D
documenta
TO—1 the pote
the Natio
ronmental statement provides the rationale for and
onmeut.al consequences of designating sites for
ocean dumping in cases where waste disposal is in
e with existing EPA requirements and for which land -^
posal is Infeasible. Individual permits for dumping
deepwater sites will be considered by EPA on a case- .
asls and the need for supplemental environmental
will be determined at that time. We have reviewed >
sed action and its environmental consequences and
these dump site designations and eventual use do
r to significantly affect the programs and missions
epartment. However, we recommend that environmental
tion of these future permit applications fully assess
tial for Impacting on existing or proposed units of
nal Park System in the study area.
We wish to thank you for the opportunity to review this impact
statement.
Sinc
Larry E. Meierotto
Assistant SECRETARY
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11
DEPARTMENT OF TRANSPORTATION
UNITED STATES COAST GUARD
MAILING A.
US COAST OUARO(G-WEP-5/ 73)
WASHINGTON. DC. SOMO
pMONe:(202)755-7938
10
U)
16471/9
AUG 1 3 1979
•Mr. T. A. Hastier
Chief, Marine Protection Branch (WH-548J
Environmental Protection Agency
Washington, DC 20460
Dear Mr. Hastieri
The Draft Environmental Impact Statement for the 106-Mile Ocean Waste
Disposal Site Designation dated June 1979 has been reviewed by my
staff. The following comments are submitted.
1. The use of shipriders is' not always a greater commitment
of manpower compared to other surveillance methods. Vessel
or aircraft patrols are more efficient at the close-in sites
primarily because they can observe more than one dumping
operation or more than one dumpaite due to their mobility.
Shipriders are restricted only to the vessel upon which they
are riding. Surveillance by shipriders at the 106 site,
while being the only method presently available, is also the
most efficient as wall. Approximately one dump occurs par
day at the 106 site. If vessels could be employed, they
would be less efficient in terms of manpower because the
number of personnel on board for the required number of hours
to conduct surveillance would exceed shiprider hours.
2. The recommendation concerning a surveillance permit pro-
vision found on page xiii is not a good recommendation for
several reasons. The Coast Guard has established a program
goal of observing 75% of all dumping operations at EPA's
industrial waste sites. One of the constraints of doing more
is the lack of additional resources* A permit provision
would commit the Coast Guard to conduct surveillance by
uhipriders. Coast Guard operations are multi-mission in
nature. Personnel who conduct shiprider missions one day may
be involved in pollution response or other high priority
operation the next. It would be a burden on the USCG to
require dumpers to have a shiprider for all dumping opera-
tions, or a burden on dumpers to delay the disposal mission
until one was available, ttie use of Coast Guard Auxiliary
personnel la also not warranted. Auxiliary operations nor-
mally augment search and rescue efforts. Auxlliarists have
no law enforcement capability and could not be used for sur-
veillance purposes. This recommendation would also restrict
surveillance to shipriders* when other methods may become
available in the near future. For example, the Ocean Dumping
Surveillance System (ODSS) may be Implemented within the next
year. This device would permit nearly 100% surveillance of
all dumping activities while at the same time relieve most of
the need for shipriders and patrols by vessels or aircraft*
I suggest this recommendation be dropped and a statement
included that the USCG should continue to strive for 75% sur-
veillance of dumps at the 106-mile site. These comments also
apply for any future sewage sludge dumping at the 106 site,
except that the level of surveillance would be 10%.
3. Page 1-5 discusses HPRSA regulation of transport via
vessels for dumping purposes. HPRSA does not specifically
address only vessels. I recommend the first sentence of the
section entitled MARINE PROTECTION, RESEARCH & SANCTUARIES
ACT be changed to, "The HPRSA regulates the transportation of
material for dumping and ultimate dumping of materials in
ocean waters."
4. Under Table 1-1 on p. 1-7 the DOT (USCG) responsibilities
should include surveillance and other necessary enforcement
acitivity, as well as authority to issue regulations and
review of permit applications.
5. The last paragraph of page 1-7 should indicate that the
Act assigns surveillance and other responsibilities to the
Secretary of the Department in which the Coast Guard is
operating and that these responsibilities have been delegated
to the Commandant of the Coast Guard by the Secretary of
Transportation (49 CPR 1.49(n)(5».
6. The second sentence on p 1-£ should be changed to read
"This system has been field-tested and evaluated by the USCG
for future use in routine surveillance."
7. The last sentence of the paragraph on Surveillance, p. 2-8,
should read "The USCG has stated that the program goal for
surveillance at industrial waste sites is 75% coverage of all
dumping missions.*
The comments in paragraph 1 of this letter also apply for
2-9.
9. On pp. 2-22, 2-25, 2-26, 2-28, and 2-29, comments are made
that the dunpeites are near or outside the limits of Coast
Guard vessel or aircraft range* This should be clarified by
55
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w
indicating they ore outside the range of helicopters and 82-
or 95* foot patrol boats normally used for ocean duping sur-
veillance* Many USCG aircraft and larger vessels do have the
range necessary for surveillance further offshore) however,
these resources are utilized primarily for fisheries enfor-
cement and other activities which necessitate use of longer-
range resources*
10. On pp. 2-25, 2-26, 2-28 and 2-29, comments on sur-
veillance and associated costs are somewhat misleading*
Shiprider surveillance would be easier because the distance,
and therefore total transit time would be much less for the
Northern or Southern sites. Shorter times means less
shiprider hours par mission, which in turn could result in
more missions covered with the same number of personnel as
compared to 106-mile site operations.
11. The comments in paragraph 2 of this letter also apply
for the recommendation found on page 2-43*
12. One point not discussed on page 4-7 concerning accidents
at the 106 site is that if dangor to life is involved, the
further distance offshore would result in longer search and
rescue response time than accidents closer to shore.
13. The fifth sentence on p. 4-25 should read "Twelve viola-
tions of permit provisions for alleged short dumping suf-
ficient to cause ... etc.* Many violations of permit
provisions during these five years have required follow-up
actioni the twelve were specific to short dumping.
14. While surveillance of sewage sludge dumping operations
at the 106-mile site Is feasible as indicated on page 5-18,
it is important to also indicate that it will place an addi-
tional burden on the Coast Guard which would require alloca-
tion of new personnel* This point was specifically made in
CDR MULLEH's Toms River Testimony.
15. The Coast Guard has imposed no five hour rate of
discharge for sewage sludge as described on p. 5-19. The
Third Coast Guard District did strongly suggest the total
amount of dumping time par day be restricted to five hours to
avoid vessel congestion in the dumpsite. The five hour
figure came from the fact that present sewage sludge dumping
had been averaging that amount per day and the Coast Guard
did not want to see it increase.
I want to thank you for the opportunity to review the draft CIS. I
hope these comments have been helpful.
Sincerely,
IU.MCMDDEN
icon, USCG
Chief. SmveiHanctand
Monitoring Briocb
By Offectloa of the Commandant
16* The comments in paragraph 2 of this letter also apply
for the recommendation on p. 5-20 except that the Coast Guard
has established a program goal of 10% surveillance over
materials like sewage sludge.
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12
M
KJ
Ln
DEPARTMENT OF TRANSPORTATION
UNITED STATES COAST GUARD
ILING ADDRESS
ZANDER (dpi)
(212) 668-7001
*16475.2/12-79
10 SEP B/9
JMr. T. A. Wastler
Chief, Marine Protection Branch (WH-548)
Environmental Protection Agency
Washington, D.C. 20460
Re: DEIS, 106-Mile Ocean Waste Disposal
Site Designation
Dear Mr. Wastler:
The Third Coast Guard District has reviewed the Draft Environmental Impact
Statement (DEIS) for 106-Mile Ocean Waste Disposal Site Designation, and we
offer the following comments for consideration in preparing the Final E1S:
Traffic Management
From a navigational safety standpoint, we consider the 106-Mile Site to be the
preferable alternative. Based on our observations, most transits consists of ocean-
going tugs towing chemical disposal barges in the 250-350 foot range. Most
transits are conducted from facilities in the Arthur Kill to sea via the less heavily
traveled southern route through Raritan Bay. Transits can thus be accomplished
using the outbound Hudson Canyon Traffic Lane without having to cross through
other traffic lanes for New York or Delaware, whereas the other alternative sites
would involve dumping in or near the inshore portions of other traffic lanes (see
Figure 3-10 in the EIS). Also, the other sites are smaller and closer inshore causing
more congestion and interference with a wide variety of commercial and recre-
ational activities. On a mathematical basis, the greater transit time poses a slight
increase in the statistical probability of collision, but the impact of a collision
involving a vessel laden with chemical waste would be greater closer inshore, as
would the real possibility of collision.
Disposal Surveillance
You recommended on page xiii of the EIS that 100% of future waste disposal
operations should be subject to shiprider surveillance by either the U.S. Coast
Guard or the USCG Auxiliary (the latter at the permittee's expense). The Coast
Guard's present Mission Performance Standards call for 75% and 10% surveillance
of toxic chemical and sewage sludge disposal operations, respectively, using Petty
Officers from the Regular Coast Guard, and on occasion, from the Coast Guard
Reserve (limitations on the use of the Reserve are discussed in Commander
MULLEN'S testimony on page D-12 of the EIS). This represents a considerable
expenditure of manpower, and, we feel, provides adequate surveillance. During
calendar year 1978, 7,247 man-hours were expended in providing shiprider surveil-
lance at the 106-Mile Site (this figure does not include considerable time shipriders
'were tied up awaiting departure due to frequent changes in departure time
resulting from mechanical failures or weather and tidal conditions). To achieve
100% surveillance, it would be necessary to remove personnel from other mission
areas, such a$ pollution prevention and response, where manpower shortages are
already critical. A requirement of 100% surveillance leaves no discretion for
performing other priority missions when conflicts arise. Moreover, your recom-
mendation restricts surveillance to shipriders, when other methods may soon be
available which could provide the USCG with significant manpower (i.e. shipriders)
savings. One such method is the Ocean Dumping Surveillance System (ODSS),
which you briefly mention in the EIS on page 1-8 and elsewhere. This automated
device could provide almost 100% surveillance without the aid of shipriders or
aircraft/vessel patrols. The ODSS has been successfully field-tested and may be
used in actual surveillance operations beginning next year. In view of the above,
we do not feel that this recommendation is justified and point out that nowhere in
the EIS is any justification put forth.
The use of the Coast Guard Auxiliary to provide shiprider surveillance (at the
permittee's expense) is not feasible. The Auxiliary is a voluntary organization of
citizens who are owners of motorboats, yachts or aircraft, whose primary mission
is to assist the Coast Guard in promoting safety at sea and efficiency in the
operation of motorboats and yachts, as well as fostering compliance with laws and
regulations governing the operation of motorboats and yachts. Members of the
Auxiliary are not vested with any law enforcement authority.
Pages xii, xiv and Section 5 of the EIS consider disposal of sewage sludge at the
106-Mile Site if adverse health or other environmental effects are produced from
disposal at the existing New York Bight Sewage Sludge Site. Use of the 106-Mile
Site is recommended on pages xiv and 5-20 on a case-by-case basis, provided that
certain conditions be met, one of which is that disposal surveillance be provided by
the Coast Guard or Coast Guard Auxiliary. As stated above, the Coast Guard has a
goal of 10% surveillance of sewage sludge disposal operations, and this standard
would be maintained regardless of the disposal site location. However, a shift to
the 106-Mile Site would probably necessitate the use of additional tugs to
compensate for the extra transit time to this site, requiring additional Coast Guard
shipriders with resulting strain on Coast Guard resources. These additional tugs
would also cause further traffic congestion in the 106-Mile Site area, posing a
greater risk of collision.
The current program of surveillance over near-shore dump sites benefits from the
synergism of our "Multi-mission" concept. However, it is important to point out
clearly that the extension of dump sites this far off shore must be accommodated
by new fully-dedicated resources. Thus, the incremental costs of providing
equivalent oversight of the dumping program will be much higher than may be
apparent to you at this juncture.
-------
Pages 2-16 and 2-18 mention that disposal surveillance at the Acid Site is normally
conducted by patrol boats and aircraft, not shipriders. It is also stated that
surveillance of possible additional waste discharges at this site "is not expected to
create problems" (p.2-16), and that the cost would be "relatively low" (p.2-18).
While surveillance would continue to be primarily by vessel or aircraft, we do not
agree that additional surveillance would be relatively problem-free and low-cost.
Any additional surveillance would require additional operating hours, fuel, and man
hours. We are preparing cost estimates for this additional activity and will forward
them to you upon completion.
Pages 2-25 and 2-28 refer to surveillance in the Southern and Northern areas,
respectively, indicating there would be no significant changes in the allocation of
USCG manpower over surveillance at the 106-Mile Site. Since the distance and
resultant travel time to the 106-Mile Site is almost twice that to either the
Southern or Northern area sites, we do not consider the statements made on these
pages to be accurate.
Sincerely,
13
F. P. SCHUBERT
Captain, U. S. Coast Guard
Chief of Staff
Third Coast Guard District-
OFFICE OF THE
DIRECTOR
STATE OF DELAWARE
EXECUTIVE DEPARTMENT
OFFICE OF MANAGEMENT. BUDGET. AND PLANNING
OOVEN. DELAWARE I 9SOI
PHONE: <3O2I 678-4271
August 6, 1979
Mr. T.A. Wastler
Chief
Marine Protection Branch (WH-458)
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Wastler:
RE: DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR 106 MILE OCEAN WASTE
DISPOSAL SITE DESIGNATION
The Office of Management, Budget and Planning, in its function as the
State Clearinghouse, has reviewed the subject EIS.
Please be informed that the Delaware State Clearinghouse supports this
EIS with the understanding that the exploration of alternatives to
ocean disposal will continue.
Sincerely,
Nathan Hayward III
Director
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14
TDepartmeniof
"" Economic &
Community
jvelopment
Division ol Local and Regional Developtngol
2525 Riva Road. Annapolis. Maryland 21401
30I-2G9-2I50
15
Marry Hughes
Governor
James 0. Roberson
Secretjry
July 19, 1979
•rCPHKN H. aACHS
OCOriGC *. NlkBON
CLIANOn M CAMCV
Thanas A. Darning, Acting
mcHAftD >. mci
MICHAKL J. •CI*IMICO. II
• KN BIALCK
PAMELA f. QUINN
DEPARTMENT OF NATURAL RESOURCES
TAWES STATE OFFICE DUILOINO
(SOU 269-22ftt
August 21, 1979
M
ro
Mr. T. A. Hastier. Project Officer1
U. S. Environmental Protection Agency
Oil and Special Materials Control Division
Marine Protection Branch
Washington, D. C. 20460
Dear Mr. Hastier:
I am in receipt of the Environmental Impact
Draft Statement (EIS) for 106-Mile Ocean Waste Disposal Site
Designation from the Department of State Planning of Maryland.
Ocean dumping is suicidal and EPA has never
regulated effectively, therefore. It Is not in the best 1n-
14-1 terests of the State of Maryland to allow this to continue.
It does conflict with present plans for economic development.
Sincerely,
Edward H. White III
Development Officer
EHW:rrs
State Clearinghouse
Department of State Planning
Mr. T.A. Hastier
Chief, Marine Protection Branch
(HH-548)
Environmental Protection Agency
401 H Street, S.H.
Washington, D.C. 20460
Dear Hr. Hastier:
I am writing on behalf of the State of Maryland to comment
on the draft Environmental Impact Statement concerning the
106-Mile Ocean Waste Disposal Site Designation. I regret that
my schedule prevented me from attending today's hearing in
Trenton. In lieu of the comments I would have made at the
hearing, I request that this letter be made part of the
administrative record concerning the 106-Mile Site designation.
Maryland is pleased that in the draft EIS EPA finally
has addressed the potential impacts of sewage sludge disposal
at the 106-Mile Site. Maryland was disturbed that so little
information was forthcoming at the Tom's River hearing two
years ago from NOAA's ongoing monitoring program concerning
impacts of ocean disposal at the 106 Site. And that, subsequent
to that hearing, EPA concluded that it could make no decision
on shifting sludge disposal to the 106 Site due to concern
for unknown, but possibly irreversible, impacts of ocean
disposal. Maryland had suggested that the 106-Mile Site
would be an acceptable, short-term, alternative location for
the disposal of sewage sludge which is presently dumped in
the ocean some 35 miles off Maryland's coast at the "Cape
May" dump site. It had been clearly established already
in numerous administrative proceedings before EPA, Region
III, that the Cape May dump site had suffered environmental
degradation as a result of sludge disposal. Specifically,
statistically significant higher levels of heavy metals had
been found in shellfish and in the sediment, visible evidence
An Equal Opportunity Employer
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oo
of material attributable to sludge had been observed on the
ocean bottom, shellfish in the area had been contaminated by
pathogenic organisms attributable to the sludge, pathogenic
organisms had been isolated from the water column, PCBs had
been isolated at the site, and as a result of these various
impacts a wide area around the Cape Hay dump site had been
closed to shellfishing. Information available at the time
indicated to Maryland that similar environmental impacts would
not, over the short term, degrade to any appreciable degree
the marine environment at the 106-Mile Site, which had
received highly toxic chemical wastes for years.
The adverse environmental and economic impacts of ocean
disposal at the Cape May site continue to this day. The
continuing shellfish ban has prevented harvest of an abundant
ocean quahog resource in the area of the dump site at a
time when the ocean quahog has virtually replaced the surf
clam as the economically important ocean shellfish of the
mid-Atlantic region, under the "Fishery Management Plan for
the Surf Clam and Ocean Quahog Fisheries" approved by the
Secretary of Commerce in November, 1977. Also continuing
to this day is a Congressional directive to EPA, in S102(a)(I)
of the Marine Protection, Research and Sanctuaries Act of
1972, that: "In designating recommended sites, the Administrator
shall utilize wherever feasible locations beyond the edge of the
Continental Shelf". It is regretable that Maryland must
petition a federal court to require EPA to now apply the
statutory mandate in the mid-Atlantic area, when that action
could and should have been taken by EPA years ago.
Even assuming that EPA continues to disagree with Maryland
over whether Philadelphia's sludge dumping should be shifted
to the 106-Mile Site immediately, Maryland would submit that
there are strong reasons why it would be appropriate for EPA
to now pursue whatever additional actions it feels are necessary
to authorize use of the 106-Mile Site for sludge disposal by the
City of Philadelphia. In his final decision of March 1, 1978,
on proposals to relocate sewage sludge dumping by Philadelphia
Assistant Administrator Jorling relied heavily on the fact
that Philadelphia dumping would be phased out by December 31,
1980. Thus he indicated at page 20 of that decision: "Certainly,
if there were any possibility that the City of Philadelphia would
be dumping its sewage sludge at this site for a longer period
of time, my conclusion might be very different". Maryland
would suggest that such a possibility does exist. First of
all, the U.S. v. Philadelphia Consent Decree does contemplate
extensions of ocean dumping beyond the December 31, 1980,
deadline, albeit with the likelihood of penalties attaching
to such an action. More disturbing is the General Accounting
-3-
15-1
Office's recommendation that the 1981 statutory deadline on
ocean disposal of sewage sludge be extended on a case-by-
case basis. While aimed primarily at New York, we could
expect pressures from the City of Philadelphia and its
Congressional delegation if the approach recommended by the
GAO were adopted by Congress. Therefore, Maryland is not at
all sanguine about the firmness of the ocean disposal deadline
for the City of Philadelphia, and we would strongly suggest
that EPA cannot be over confident about meeting this deadline.
EPA should designate the 106 disposal site for future
receipt of sewage sludge from any source, not just from
New York City as is suggested by the discussion in the draft
EIS. In this regard, it should be noted that the Tom's River
Hearing Officer recommended at page 107 of his report preparation
of an EIS "on the issue of relocating the sludge dumping sites^
to the 106 Mile Site" (emphasis supplied). And that. Assistant
Administrator Jorling directed, at page 36, that the EIS on
the 106-Mile Site should be prepared to "include the dumping
of sewage sludge", with no qualification that this dumping would
be limited to sewage sludge from New York City. Chapter V
of the draft EIS contains a highly competent discussion of the
NOAA monitoring information and addresses each of the concerns
raised during the Tom's River proceeding. The draft EIS
concludes that use of the 106-Mile Site for sewage sludge
disposal would be environmentally acceptable. There is no
reason to believe that this conclusion applies with any less
force to sludge from Philadelphia.
In conclusion, Maryland would respectfully request that
the final EIS and any subsequent regulatory action concerning
designation of the 106-Mile Site clearly indicate that the site
is suitable for disposal of municipal sewage sludge from the
City of Philadelphia, as a short-term alternative to the
Cape May dump site.
Yours' very truly,
Thomas A. Deming
TAD/elb
Senator Charles Mathias, Jr.
Senator Paul S. Sarbanes
Congressman Robert E. Bauman
Secretary James B. Coulter
George A. Nilson, Deputy Attorney
General
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16
Mr. Hastier
- 2 -
September 21, 1979
DEPARTMENT OP ENVIRONMENTAL PROTECTION
IOHN FITCH PLAZA, P. O. BOX IJ90. TRBNTON. N. ». 08623
September 21, 1979
Mr. T. A. Hastier
Chief, Marine Protection Branch
EPA
Washington, D. C. 20460
Re: Draft EIS, 106-Mile Ocean Haste Disposal Site Designation
Dear Mr. Hastier:
The State's Department of Enviromental Protection has complet-
ed its review of the Draft Environmental Impact Statement prepared
by the EPA with regard to the 106-Mile Ocean Haste Disposal Site.
As a result of this review, the comments received from several of the
Department's review agencies centered primarily on the issue of ocean
j dumping and land-based alternatives.
o Although the Draft EIS assesses the impact of sludge dumping
D at the 106 mile site, the broader issue of the relative impacts of
ocean dumping and land-based alternatives is unfortunately inadequ-
16—1 ate in this document. It is the New Jersey Department of Environ-
mental Protection's position that this Draft EIS is essentially
iincomplete without a comparison of the effects of ocean dumping and
the development of land-based alternatives. He believe that this
deficiency should be remedied in the Final EIS. Our own assessment
of this issue for New Jersey follows:
The review of sludge management studies prepared by
New Jersey's ocean dumpers has given us a reasonably accurate
assessment of the impact of the cessation of ocean dumping on
our State's environment. Estimates have been developed, for
example, that the proposed Elizabeth Joint Meeting incinerator
will effectively raise the lead content of the air above the
City of Elizabeth, another 10% to 20% over levels expected from
other sources, to a point where the ambient concentration will
be in excess of two thirds of the maximum allowable lead
concentration necessary for the protection of human health.
The cadmium level will also be high enough to be of major
conern. Furthermore the particulate load emitted to the
atmosphere from the operation of this incinerator might
preclude certain indust-rial development in the vicinity of the
plant. Some of the air pollution allocation allowed under the
Federal Clean Air Act will be used to provide the dilutive
capacity necessary to absorb the additional emissions from this
incinerator. In the case of Passaic Valley Sewer Authority,
the three quarters of a million tons of sludge, which will be
stored for a period of 4-6 years, will contain sufficient
mercury to effectively preclude their incineration under
today's standards. The amount of mercury emitted by inciner-
ating the sludge from PVSA would be approximately three times
the maximum allowable under law. The final environmental
assessment of incinerating this particular sludge has not been
completed yet. However, the foregoing statement on mercury is
based on the Authority's Heavey Metals Source Determination
Study, and therefore our assessment with respect to that
specific contaminant is accurate. The only way we can expect
to legally burn this material would be to dilute the stored
sludge with new, clean, pretreated sludges anticipated in the
1980's.
These examples make it clear that the implementation of the
Industrial Pretreatment Program is vital to environmentally sound
sludge disposal. It is equally clear that if industrial pretreat-
ment is not implemented. New Jersey could find itself in a complet-
ely intolerable enivornmental predicament. Should these interim
solutions to the 1981 ocean dumping ban, such as landfilling or
storage, become final, permanent solutions because sludge contam-
inant levels continue to prevent the use of selected long-term
solutions, a severe impact on the quality of life in New Jersey
would result. Even composting of sewage sludge, an alternative that
has been chosen by a number of sewerage authorities in New Jersey,
is dependent on a commitment to remove the heavy metal at the
source.
Hith the implementation of the Industrial Pretreatment Program,
one would expect a dramatic improvement in the water quality of the
Bight, which receives the effluent from the largest New Jersey and
New York Sewage treatment plants. Heavy metals surveys in New
Jersey have been partially completed £>y the Passaic Valley Sewerage
Commissioners, Rahway Valley Sewerage Authority, Elizabeth Joint
Meeting, and the Bergen County Utilities Authority. These surveys
indicate that, in general, a four-fold reduction in heavy metals is
achievable, for both effluent and sludge. He beleive that such
contaminant reductions may possibly eliminate the necessity for a
categorical ban on the dumping of sewage sludge in the ocean.
•*• Jrr\i-y /A An Equal Opportunity Empfaver
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Hr. Hastier
- 3 -
September 21, 1979
Ne would recommend that in order for us in New Jersey to
properly plan for the implementation of long-term sludge management
solutions:
16-2
16-3
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CO
o
16-4
1. That the USEPA immediately promulgate the industrial
pretreatment standards and undertake the full implementa-
tion of the program as mandated by Section 307 of the Clean
Water Act for the reasons presented above; and
2. that because of difficulties involved and the inadequacy
and insensitivity of the tests used, monitoring at the site
is unlikely to turn up long-term sublethel effects or to
detect possible bioaccumulation of organic compounds. This
does not mean that such sublethal effects or bioaccumula-
tion vould not occur. It is imperative therefore that
"environmental impact criteria", with regard to organics
and more particularly with regard to organo halogens, be
stricter than stated (see page 1-13 of draft EIS). Any
organic material with potential to bioaccumulate should be
prohibited. (The phase "must be less than is known to be
toxic to organisms" is not an adequate criteria in this
situation.)
3. That any permittee should provide an exhaustive and
complete organic analysis of its wastes.
We wish to express our appreciation to EPA for the opportunity
to reveiw the Drafts EIS. It is anticipated that these comments
will assist the EPA in their endeavor to make the Final EIS as
environmentally sound as possible. ~.
Since/ell,
Lawrence Schmidt
Chief Office of
Environmental Review
17 COMMENTS TO THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
CONCERNING THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR THE 106-MILE OCEAN WASTE DISPOSAL SITE DESIGNATION
Presented in Trenton, New Jersey
on
August 21, 1979
Prepared By:
Or. Mai-wan M. Sadat, Program Director
Theresa Van Rixoort, Program Development Specialist
Office of Sludge Management and Industrial
Pretreatment
Division of Mater Resources
New Jersey Department of Environmental Protection
LS/sje
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17-1
Mr. Birmingham, members of the panel:
Thank you for providing us with this opportunity to comment on the Draft
Environmental Impact Statement (EIS) concerning the suitability of the
106 mile site for the disposal of sewage sludge.
The New Jersey Department of Environmental Protection (DEP) congratulates
and commends the staff of the Agency on the detailed and comprehensive analysis
of the environmental and economic considerations for sludge dumping at the 106
mile site.
The Draft EIS clearly indicates that dumping of sewage sludge at the 106 mile
site will not significantly impact the area and that any environmental degrada-
tion will be immediate and temporary. The use of the 106 mile site has been
advocated by DEP since 1976. Clearly, the limited area and the shallow depth
of the existing 12 mile site make it unsuitable for the continuing
disposal of municipal sewage sludge. Even the most crude engineering computations
will leave little doubt that any increase in the sludge quantity being dumped
at the 12 mile site must inevitably result in anaerobic conditions in the benthic/
ocean boundary layer. The Department is very much concerned that any additional
sludge dumping in New York Bight will cause a violation of Water Quality Standards
on the New Jersey beaches. The proximity of the 12 mile site to the New Jersey
shore increases the likelihood of pathogen survival in quantities sufficient to
exceed the New Jersey Water Quality Standards for this area.
Although the Draft EIS thoroughly assesses the impact of sludge dumping at the
106 mile site, the broader issue of the impact of ocean dumping and land-based
alternatives is unfortunately absent from this document. It is the New Jersey
Department of Environmental Protection's position that this Draft EIS is essentially
incomplete without a comparison of the effects of ocean dumping and the development
of land-based alternatives. We believe that this deficiency should be remedied
in the final EIS. Our own assessment of this issue for New Jersey follows:
The review of sludge management studies prepared by New Jersey's ocean dumpers has
given us a reasonably accurate assessment of the impact of the cessation of
ocean dumping on our State's environment. Estimates have been developed, for
example, that the proposed Elizabeth Joint Meeting Incinerator will effectively
raise the lead content of the air above the City of Elizabeth, another 10! to 20%
over levels expected from other sources, to a point where the ambient concentration
will be in excess of two thirds of the maximum allowable lead concentration
necessary for the protection of human health. The cadmium level will also be high
enough to be of major concern. Furthermore the particulate load emitted to the
atmosphere from the operation of this incinerator might preclude certain industrial
development in the vicinity of the plant. Some of the air pollution allocation
allowed under the Federal Clean Air Act will be used to provide the dilutive
capacity necessary to absorb the additional emissions from this incinerator. In
the case of PVSC, the three quarters of a million tons of sludge, which will be
stored for a period of 4-6 years, will contain sufficient mercury to effectively
preclude their incineration under today's standards. The amount of mercury emitted
by Incinerating the sludge from PVSC would be approximately three times the
maximum allowable under law. The final environmental assessment of Incinerating
this particular sludge has not been completed yet. However, the foregoing state-
ment on mercury is based on the Authority's Heavy Metals Source Determination
Study, and therefore our assessment with respect to that specific contaminant
is accurate. The only way we can expect to legally burn this material would
be to dilute the stored sludge with new, clean, pretreated sludges anticipated
in the 1980's.
These examples make it clear that the implementation of the Industrial Pretreatment
Program is vital to environmentally sound sludge disposal. It is equally clear
that if industrial pretreatment is not implemented. New Jersey could find itself
in a completely intolerable environmental predicament. Should these interim
solutions to the 1981 ocean dumping ban, such as landfllling or storage, become
final, permanent solutions because sludge contaminant levels continue to prevent
the use of selected long-term solutions, a severe impact on the quality of life
in New Jersey would result. Even composting of sewage sludge, an alternative that
has been chosen by a number of sewerage authorities in New Jersey, is dependent
on a commitment to remove the heavy metals at the source. An absolute ban on the
ocean dumping of these highly contaminated sludges as of 1981 may, therefore, of
dangerous.
With the implementation of the Industrial Pretreatment Program, one would expect
a dramatic improvement In the water quality of the Bight, which receives the effluent
from the largest New Jersey and New York sewage treatment plants. Heavy metals
surveys in New Jersey have been partially completed by the Passaic Valley Sewerage
Commissioners, Rahway Valley Sewerage Authority, Elizabeth Joint Meeting, and the
Bergen County Utilities Authority. These surveys Indicate that, in general, a
four-fold reduction in heavy metals is achievable, for both effluent and sludge.
We believe that such contaminant reductions may even eliminate the necessity for a
categorical ban on the dumping of sewage sludge in the ocean.
Me would recommend to this panel that, in order for us in New Jersey to properly
plan for the implementation of long-term sludge management solutions:
1'""* 1. That the USEPA Immediately promulgate the Industrial pretreatment
standards and undertake the full implementation of the program as
mandated by Section 307 of the Clean Water Act for the reasons
presented above; and
17—3 2. That the USEPA recommend to Congress the consideration of continued
ocean dumping beyond 1981 in limited cases, under the following
conditions:
a) that the present dump site be banned from use.
b) that all future sludge dumping be allowed only at the Chemical
Waste Dump site, (Movement of the disposal area to the 106
mile site would remove the economic incentive to ocean dump since
the cost for dumping at the 106 mile site is approximately the
^ame as for the Implementation of long-term land-based alternatives
such as composting or incineration. Environmental improvement
would also result in the Inner New York Bight.) and
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19
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c) that the ocean dumping of sludge at the 106 mile site be
carefully studied by NOAA, the USEPA. and other federal
agencies in order to develop the necessary criteria to
properly manage this practice in terms of application methods
and rates. (In our opinion, an analogy can be drawn between
the carefully managed land application of sludge and the prudent
management of sludge disposal in the ocean to prevent over-
fertilization and to insure that pollutants are kept below
toxic levels.)
He believe that it is imperative that ocean dumping of sludge at the present
ocean dumping site cease as soon as possible. It certainly should not continue
past 1981. The amount of sludge that the site would then receive would be
approximately li million tons per year, which is a five-fold increase over the
amount it received in 1972. The assimilative capacity of the 12 mile site is
effectively exhausted. In our estimation, continued dumping at the site could lead to
violation of water quality standards on the New Jersey and Long Island shores. At
the same time, land-based disposal or storage of those sludges which are highly
contaminated at present may also pose a severe environmental threat, particularly
if the implementation of pretreatment is delayed. Me are further convinced that,
as stated in the draft EIS and with the proper management and controls, the ocean
dumping of sludge, at the 106 mile site or another appropriate site, may be a viable
and environmentally acceptable alternative for sludge disposal. It is our
opinion that the development of long-term environmentally sound sludge management
alternatives for those states which border the Atlantic and Pacific Oceans is
incomplete without the proper assessment of managed and controlled deep-waters
ocean disposal. Ue should not fear remaining objective and open-minded about the
possibility of some proper role being established for the ocean waters in our
management of society's waste.
New York State Department of Environmental Conservation
SO Wolf Road, Albany. New Vork 12233
Commissioner
Robert F. Flacke
September 6, 1979
Mr. T. A. Wastler
Marine Protection Branch (WH-548)
Oil 5 Special Materials Control Div.
U. S. Environmental Protection Agency
Washington, D.C. 20460
Environmental Impact Statement
(EIS) for 106-Mile Ocean Waste
Disposal Site Designation.
DEC 1012-006
Dear Mr. Wastler:
The Department of Environmental Conservation has completed
its review of the above noted project and has found the document
to be accurate in its treatment of the problems and solutions to
proper waste disposal.
The primary concern of this Department has always been to
ensure that hazardous wastes are disposed of properly. When
considering the various disposal alternatives currently available,
we feel that secure landburial sites represent a better solution
than ocean disposal. However, we do agree that the ocean dis-
posal should still be considered in special cases provided that
the operation is carefully scrutinized. Fortunately, beyond 1981
there will be only one company permitted to use the 106-Mile site
as a disposal area until they find a land based alternative.
This should simplify our waste management strategy in one sense.
Ocean disposal of sewage sludge is another area of particular
concern for New York St^te. Again we prefer to place our confidence
on land based treatment technology since we are experiencing marked
progress in this area. The quality of the Long Island beaches is
especially in need of proper safeguarding; therefore, any emergency
ocean disposal operation must be accomplished in a prudent manner.
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Mr. T. A. Wastier
2.
Ke must stress that it is the Department's goal to see that
all wastes are treated, stored or disposed of in New York State
using proper and practical methods; and it is our aim to cooperate
with other State and Federal agencies to accomplish this goal.
Thank you fur the opportunity for review. We request review
of the final document when available.
Very truly yours.
Terence P. Curran, Director
Division of Regulatory Affairs
20
PSC
Pennsylvania
Stale
Clearinghouse
P.O. BOX 1323 - HARRISBURQ. PA. 17120 - (7171 7874046
783-3133
OOVERNOB-B OFFICE
OFFICE OF THE BUDGET
August 24, 1979
U)
U)
TPC:BRM/scs
cc: G. Colvin
N. Nosenchuck
File
R. Persico
Marine Protection Branch
Oil and Special Materials Control Division
U. S. Environmental Protection Agency
Washington, D.C. 20460
Dear Sir:
The Pennsylvania State Clearinghouse has received
from your office a copy of the Draft Environmental Impact
Statement on the 106-Mile Ocean Waste Disposal Site Designation
and have no comments to make at this time.
Thank you for your cooperation.
Sincerely,
Richard A. Heiss
Supervisor
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CO
22
COMMONWEALTH of VIRQINIA
Council on the Environment
August 8, 1979
903 NINTH STHEET OFFICE BUILDING
RICHMOND 231(9
B04 786-45OO
COMMONWEALTH of VIRQINIA
STATE t'ATKR CO.\TROL BOARD
21II Hamilton Street
Mr. T. A. Hastier
Marine Protection Branch (HH-54B)
Oil and Special Materials Control Division
U. S. Environmental Protection Agency
Washington, D. C. 20460
SUBJECT: 106-Mile Ocean Haste Disposal Site Designation
Dear Mr. Hastier:
Thank you for the opportunity to review the subject Draft Environmental
Impact statement. On behalf of the Commonwealth of Virginia, the Council on
the Environment coordinated a review among pertinent agencies of the State.
The State Hater Control Board and the Virginia Institute of Marine Sciences
commented on the proposal.
The Commonwealth supports the designation of the Disposal Site for
continued ocean waste disposal. With the safeguards that EPA has built into
the proposal, the environmental impacts should be minimal.
Please find enclosed the comments and recommendations of the State
Hater Control Board, which we hope will be useful in your further considera-
tions of the action.
Do not hesitate to contact me if I can be of further assistance.
Sincerely,
JBJr:RFH/gcj
Enclosures
cc; The Honorable Maurice B. Rowe, Secretary of Commerce and Resources
Mr. Dale Wright, State Hater Control Board
Mr. Thomas Barnard, Jr., Virginia Institute of Marine Science
Po.C OKic* Bo. 11143
Richmond, Virginl* 23230
(8041 257-0056
August 2, 1979
Mr. Reginald F. Wallace
Environmental Impact Statement Coordinator
Governor's Council on the Environment
Ninth Street Office Building
Richmond, Virginia 23219
Dear Reggie:
RE: DEIS/106 Mile Ocean Waste Disposal Site
Our staff has reviewed the above-referenced DEIS and we have the following
comments:
A review of this draft indicates that the dumping of Aqueous Chemical
Wastes at the 106 mile disposal site would primarily have short term
effects. The following recommendations seem appropriate to protect
water quality and closely monitor long range effects of the dumpings.
1. Routine monitoring should be established to evaluate water
column dispersion and persistance of toxics and heavy metals.
2. Benthic accumulations and biota should also be routinely
monitored to closely define long range Impacts.
3. Another site beyond the shelf should also be established
so that a rotation pattern could be developed. This would
allow recovery of the dump sites.
4. Sewage sludge disposal at the site would facilitate a more
thorough scientific evaluation of the Impact at sites beyond
the continental shelf and though more expensive could be
beneficial in the recovery of the New York Bight and other
continental shelf disposal locations.
5. It has been emphasized that the cost of maintaining a routine
22 — 4 surveillance program would be expensive, surcharges should be
levied against those industries using the site to cover the
expense of these programs.
22-1
22-2
22-3
Continued.
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August 2, 1979
Mr. Reginald F. Wallace
23
flonmoutlf (Bounty Planning fiaarft
COURT STREET AND LAFAYETTE PLACE
FREEHOLD. NEW JERSEY O7728
VICE CHAIRMAN
ELWOOO L. BAXTER
SECRETARY
JOSEPH B. VUZZO
•OAAOOV
CHOSEN FUEEHOLDCM uout*
HAY KRAMER
Thank you for the opportunity to comment on this DEIS.
questions, please feel free to contact me.
If you have any
LESTER 3. OOtOSlEIN
fteptun* Township
ALBERT A. KERB. JR.
Rumon
TAYLOR PALMER. JR.
THOMAS J. LYNCH. JR
ALTERNATES
Hated A. Ganfertl. Elq.
PMIJ KMnun. Jf.
ale E. Wright
Pollution Control Specialist
Bureau of Surveillance
and Field Studies
/sec
0. H. Treacy-SMCB, Division of Ecological Studies
R. F. Jackson-SHCB, Tidewater Regional Office
EIS File
W
U>
Oi
23-1
201 . 431 7400
.
WIUIMmV. W. C
October 17, 1979
Hr. T. A. Was tier
Chief, Marine Protection Branch (WH-S'iB)
Environmental Protection Agency
Washington, DC 20460
RE:
Draft Environmental
Site Designation
Impact Statement for 106-mile Ocean Waste Disposal
Dear Mr. Wastler:
This Is to advise you that the Monmouth County Planning Board has re-
affirmed its support for a strict enforcement of the December 31, 1981, dead-
line for the termination of sludge dumping in the ocean. The Board took the
action after a report by the staff on the EPA's proposal to use the so-called
106-mile site off Southern New Jersey for the continued disposal of chemical
waste by DuPont and for an expanded sludge dumping program at that site If
continued disposal off Sandy Hook Is found unacceptable. While the Board does
not desire to comment on administrative decisions concerning chemical disposal
or case-by-case extensions to the deadline for sludge dumping, it does wish to
underscore its opposition to any sludge disposal in the New York Bight after
1981.
Robert D. Halsey
Director of County Planning
RDH/OM/ea
cc: Thomas O'Hara, Chairman MCPB
Elwood Jarmer, Chairman, Coastal Counties Committee
Sandra T. Ayres, NJ Division of Public Interest Advocacy
Or. Marwan Sadat, Director, Office of Sludge Management 6 Ind. Pretreatment
Kathleen Rippere, Chairman, Environmental Council
-------
24
TOWN OF OCEAN CITY
KPHONK 209-4221
p. a OOK tu
PI
OJ
24-1
25
MAYOR & CITY COUNCIL.
OF OCEAN CITY
MARYLAND
21842
August 3, 1979
Mr. T. A. Wastler
Chief, Marine Protection Branch
U. S. Environmental Protection Agency
Washington, D. C. 2O46O
RBi Draft EIS - Final Designation of 106 Mile
Chemical Water Ocean Disposal Site
Dear Mr. Vastieri
The Town of Ocean City and myself, as Mayor, has repeatedly
expressed its complete opposition to the continued pollution
of our oceans - whether by chemical cr sewage sludge disposal.
We reaffirm our feelings on this subject and again urge you
to force the development of alternate non-ocean means of
waste disposal.
Sincerely,
CNlMlllt It TKIMI'MI
25-1
HWK/js
CCi Mr. James T. McConnaughhay
Chief, State Clearing House
Maryland Department of State Planning
301 West Preston St.
Baltimore, Maryland 212O1
TOWN OF OCEAN CITY
MAYOR & CITY COUNCIL
OF OCEAN CITY
MARYLAND
2184]
July 24, 1979
Mr. T. A. Wastler
Marine Protection Branch
Oil 6 Special Materials Control Division
U. S. Environmental Protection Agency
Washington, D. C. 2O460
RE I Draft B.I.S. - Final Designation
of 106 Mile Chemical Water Ocean
Disposal Site
Dear Mr. WastlerI
I have reviewed the referenced summery which was received from
our State Clearinghouse. Because of the impact which such a use
might have upon a resort such as Ocean City, we are very in-
terested in this matter. Therefore. I am requesting that we be
provided a complete copy of the document:.
I might add that the time allowed us to review and comment on
the Proposal is very limited.
If you have any questions or comments, please contact me at
289-8221.
MaA
Orantsman
MN/js
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26
DELAWARE RIVER BASIN COMMISSION
P. O. BOX 73BO
WEST TRENTON. NEW JERSEY OBBSB
(GO9> BB3-9SaO
GERALD H. HANSLER
August 14, 1979.
as STATE POLICE DRIVE
WEST TRENTON.N. J
Dear Mr. Wastler:
The Delaware River Batln Commission ttaff has re-
viewed the Draft EIS far the 106-Mile Ocean Waste Disposal Site Designation and is
in general agreement with EPA's recommendation that this site receive final designa-
tion for continued industrial waste disposal, subject to EPA Ocean Dumping Regulations
and Criteria.
There are three options available for waste disposal
remaining after reuse, recycling and/or treatment to reduce waste volumes or to render
waste less active. They are land, air or water disposal. All of these options must be
considered in waste management. Each, with appropriate criteria, regulations and mon-
itoring, can provide environmentally acceptable means of waste disposal.
DRBC's position on the issue of ocean disposal is a
matter of record. In cases where no land-based disposal alternative is available and
when the only other alternative involves discharge of contaminants into a stream with
adverse Impact on the river and/or its estuary, DRBC has recommended ocean disposal
as the most acceptable option — provided it meets EPA's ocean disposal criteria.
We believe this position il especially valid in a situa-
tion where the wastes discharged to the ocean have no demonstrable adverse impact on
the marine environment and In which the treatment of the effluent would produce a
residue for which no satisfactory land disposal facility is available. An example would
be a waste which when treated would produce large volumes of sludge, land disposal
of some sludge could cause measurable environmental degradation. With proper controls,
disposal at the 106-mile site would be the most acceptable alternative.
We recognize that numerous studies on the effects of
various types of wastes on the marine environment are Incomplete and that much of the
data they have generated are Inconclusive. Such studies should be continual. The
adverse impact on around and surface water of inadequately handled land disposal,
however, has been clearly established, as is that of the direct discharge of waste
materials to fresh or brackish surface water sources. Therefore, when confronted with
- 2 -
options - one set of which poses a throat of contaminated land, ground water or
surface water with Its Immedfal* impact on society; the other Involving an Impact
of insignificant consequences, short-term or long-term, on a distant tract of ocean -
the Commission support! the ocean disposal option.
We believe that this position has increased validity
when applied to ocean disposal as an option for a discharge until such time as alterna-
tives can be researched arid practical permanent solutions can be found.
Sincerely,
Gerald M. Hornier
Mr. T. A. Wastler, Chief
Marine Protection Branch
U.S. Environmental Protection Agency
Washington, D. C. 20460
-------
27 _
E. I. DU PONT DE NEMOURS S COMPANY
WILMINGTON, DELAWARE 19898
CO
oo
CC: Dr. P. H. Anderson - EPA - Region II
Dr. W. M. Duns tan - Interstate
Electronics Corp.
Ms. Kathleen King - Interstate
Electronics Corp.
ENGINEERING OEPAR1
LOUVIER3 BUILDING
September 26, 1979
Mr. T. A. Hastier
Chief, Marine Protection Branch (HH-548)
Environmental Protection Agency
Washington, DC 20460
Dear Mr. Hastier:
This is in response to a request for comments on "Environmental
Impact Draft Statement (EIS) for 106-Mile Ocean Haste Disposal site
Designation." He are encouraged to note the conclusion, that no
significant adverse effects have been demonstrated at the site
because of waste disposal.
Our detailed comments are attached herewith.
to us are:
Of particular concern
• Incorrect data on bioassays and other characteristics of
Du Pont wastewaters given in Table 5-2 (page 5-6) and on
pages B-12 and B-13.
• The implication on page 2-23 that the Delaware Bay Acid Waste
Disposal Site was closed to shell fishing because of previous
use of that site by Du Pont.
• Certain recommendations (pages xiii and 2-41) on industrial
wastewater characteristics which, if adopted, would exclude
the use of ocean disposal for Du Pont wastewaters. These
recommendations need modification so that the site can con-
tinue to be used for disposal of wastes which have no signifi-
cant environmental impact.
He appreciate the opportunity to comment on the draft EIS.
Very truly yours,
ENGINEERING SERVICE DIVISION
COMMENTS OP E. I. DU PONT OE NEMOURS & CO.
ON ENVIRONMENTAL IMPACT DRAFT
STATEMENT (EIS) FOR 106-MILE
OCEAN HASTE DISPOSAL SITE DESIGNATION
Comments
The statement is made that "the disposal of chemical
wastes, in combination with other types of material,
is generally an undesirable practice.* Since, in
general, chemical wastes have not been disposed of with
other types of material, there has been no experience
on which to base such a statement. The reasons for
this statement should be presented.
xiii, 2-41 The EIS recommends several characteristics which indus-
trial wastes should have for disposal at the 106-mile
site.
The first recommendation is that concentrations of
solids should generally be less than 1 percent. The
text does not specify what kind of solids are referred
to, nor the basis for the recommendation. The 106-mile
site is deep (1500-2700 meters) and has excellent
dispersing characteristics for wastes which contain
even several percent suspended solids (eg, sewage
sludge per pages 5-8 through 5-11). In addition,
dispersal of wastewater containing several percent of
dissolved solids, such as Du Pont-Grasselli's, is
also quite rapid as the EIS points out on pages B-14
through B-16.
He suggest that the first recommendation be modified
to state that suspended or dissolved solids concen-
trations should not be high enough to interfere
significantly with the dispersion of wastewater con-
stituents.
L. L. Falk
LLF:rbw
Atch
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- 2 -
- 3 -
RJ
CO
Page Comments
The second recommendation is that the wastewaters be
neutrally or slightly negatively buoyant in seawater.
As we interpret this recommendation, it means the
wastewaters should have a specific gravity equal to
or greater than that of seawater. Might that not be
a better way to state this recommendation?
The third recommendation is that the wastewater char-
acteristics "demonstrate low toxicity to representative
planktonic and demersal marine organisms." The toxic
effect of a wastewater is a function of its concentra-
tion. Therefore, the toxic effect of wastewater dis-
posed of in the ocean depends on the dilution achieved,
a function of the rate of release and barge speed (ie,
tons released per unit of distance traveled.) Falk and
Gibson (1977) and Palk and Phillips (1977) demonstrated,
for both Du Pont-Grasselli and Du Pont-Edge Moor wastes,
that a time-concentration curve can be developed by
proper release rate such that concentrations at any
time after release can be kept below the corresponding
toxic effects concentration for the same time. (See
EIS reference list, p. 7-21, EIS page 2-6, 2nd para-
graph, and EIS pages B-13 and B-17).
The same concept can be applied to any wastewater of
almost any toxicity by use of an appropriate release
rate. The higher the toxicity, the lower the release
rate. Therefore, the logistics and economics of ocean
disposal become the determinants. The recommendation
that the wastes have low toxicity is not relevant.
What is relevant is that the toxicity be mitigated by
proper dispersion practices. Therefore, we suggest
that the third recommendation be modified to provide
for demonstrating low toxicity to representative
Page
xiii-xiv,
2-43
1-5
2-4
Comments
planktonic and demersal marine organisms at waste-
water concentrations achieved after dispersion (see
EPA regulations, 40 CFR Part 227, Subpart B).
The fifth recommendation deals with certain constituents
which should not be detectable above ambient levels
outside the site within 4 hours after discharge. We
suggest this recommendation be clarified. For
example, does it literally mean outside the entire
106-mile site 4 hours after release? What kinds of
. constituents are being referred to?
Five numbered additional recommendations are made:
The second of these indicates that monitoring (at
permittees' expense) for short-term impacts should be
by "environmental contractors." If a permittee is
qualified to do the monitoring, the permittee should be
allowed to do it.
Correct the last word in the second recommendation
from "waste" to "waste-sea-water mixture."
The first lines indicate the CWA of 1977 (PL 95-217)
replaced earlier legislation and established a regu-
latory program for controlling discharges to navigable
waters from outfalls. Actually, such a program was
established at the Federal level by PL 92-500 when the
Federal Water Pollution Control Act was amended in 1972.
Further, most States had such regulatory programs for
many years prior to 1972.
The text indicates the 106-mile site is located 167 km
(90 n. mi) east of Cape Henlopen, Delaware. Scaling
the western boundary of the site on Figure 2-1 shows it
is 232 km (.126 n. mi) east of Cape Henlopen. The site
is farther from Cape Henlopen than it is from Ambrose
Light.
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- 4 -
- 5 -
Page
2-14
2-20
2-23
->
O
Comments
Re lines 18 through 23, Mueller, et al. did not report
on sodium sulfate and calcium chloride entering the
New York Bight Apex. Those probably do come from land
runoff (eg, street salting) and other sources in the
metropolitan area.
In the second paragraph, change "sulfide" to "sulfate."
In the first paragraph is the statement: "Preliminary
work by Pesch et al. (1977) indicates that previous
acid waste disposal has contaminated scallops near the
Site. At this time, the Site is still closed to shell-
fishing by FDA."
We strongly object to the first sentence in the quote
as well as the implication of the second. The second
sentence implies that FDA closed the area because of
contamination of shellfish from the previous acid waste
disposal. Actually, closure was because of bacterial
contamination at a nearby sewage disposal site.
Further, Pesch et al. did not state that scallops were
"contaminated" by acid wastes. They indicated that
certain waste constituents, eg, vanadium, provided a
tag for the acid waste. They found locations of
statistically higher vanadium concentrations in sea
scallops south of both the Delaware Bay Acid Waste Site
and the nearby Philadelphia Sewage Sludge Site as well
as in the latter site (see their Figure 6). Those
authors, however, made no statement that the scallops
were "contaminated" such that closing to shellfish
harvesting was needed.
He urge that the EIS specify the basis upon which FDA
closed the Site to shellfishing, both here and on
page 4-5.
Page
2-37
2-38
3-13
3-17
3-21, 3-22
3-35
3-38
Comments
The last line of the second paragraph indicates the
point of land nearest to the northwest corner of the
106-mile site is 200 km (110 n. mi) away. If the
nearest point is scaled off from Figure 2-1 (p. 2-5),
the correct distance is 167 km (90 n. mi).
The 200 km (110 n. mi) distance should be corrected as
shown above.
What evidence exists to show that organic carbon acts
as a trap and transport agent for toxic substances (2nd
paragraph)? This may be true of suspended particles,
but they do not have to be "organic carbon."
The longitude boundaries given for the New York Bight
Acid Wastes Site should be 73°36' W to 73°40'W.
Table 3-4 should show the loads as "metric tons/year."
The first line on page 3-21 should begin: "The total
mass loads of several trace metals released annually
into ...."
The EIS says Mueller et al. (1976) did not report iron.
They did (see their Table 38), at 230 metric tons/day
of which 79 percent is from barging (see their Table 39).
The last paragraph indicates that there is a large flow
of fresh water out of Delaware Bay in springtime. It
would be more accurate to speak of "lower salinity
water" because the Bay supports marine organisms which
could not survive "fresh water."
In line 6, change "sulfide" to "sulfate."
In line 8, the waste is described as 30 percent hydro-
chloric acid. This is incorrect. The waste's total
acidity during 1976 was generally between 100,000 and
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- 6 -
- 7 -
3-39
W
220,000 mg CaCOj/kg. vttiB ia equivalent to a range of
7.3 to 16 percent acid (expressed as hydrochloric).
Table 3-8 shows abnormally high loads of nickel and
zinc in 1976. This is believed caused by including
anomalously high analyses for those metals in certain
barge samples. To be specific, the nickel concentra-
tions in barge 6-48 (and the composite from barges 6-39
to 6-48) are more than two orders of magnitude greater
than any other samples during 1976. The zinc concen-
tration in the composite from barges 6-59 to 6-68 is
about 10 times that from the next highest 10-barge
composite.
The 1976 nickel and zinc loads should be calculated
without those high anomalous values. If so done, the
1976 nickel load will be 5.8 and the zinc load 41
metric tons.
The text should state that Pesch et al. (1977) con-
sidered vanadium as a tag for Du Pont wastes. However,
they did not prove that "past waste disposal at the
Site caused elevated vanadium levels in scallops from
the area." They had no data on vanadium levels in
scallops prior to the start of disposal. Furthermore,
examination of their Figure 6 (vanadium distribution)
does not rule out that the higher vanadium values were
from causes other than ocean disposal of titanium
dioxide wastewater. EPA should be contacted to learn
if vanadium levels have decreased since Du Pont ceased
use of the Delaware Bay Acid Waste Site. If levels
have not declined, then causes other than industrial
waste disposal should be sought.
Page
4-16
5-6
Comments
Examination of Figures 2-6 of Pesch et al. 11977) indi-
cates elevated concentrations of several metals in sea
scallops well away from both the Delaware Bay Acid
Waste Site and the Philadelphia Sewage Sludge Site.
Further, comparison of the figures shows significantly
different patterns. Compare Figure 5 for cadmium with
the others. This indicates industrial waste disposal
is not the sole cause of elevated metal levels.
He should point out that the presence of both acid and
sewage sludge (two entirely different wastes) in the
area studied by Pesch et al. does obscure the effects
of waste disposal, contrary to item (3) listed in the
paragraph on p. 4-16.
Table 5-2 contains several misleading values:
1. The range for copper concentrations of Du Pont-
Grasselli wastewater is given as 25 - 154,700 ug/1.
The maximum value is in error because of a faulty
analysis. EPA-Region 11 had been provided a
correct value. Therefore, the maximum value
observed since 1974 should be shown as 1470 ug/1.
Consequently, the mean value should be changed
from 3000 to 330 ug/1 (1974-1978 analyses).
2. The range of 96-hour LC50 values for Grasselli
wastewater to the Atlantic silversides (M. menidia)
is given as 1.8 - 6950 rag/kg. The asterisk indi-
cates the source of the data is Mueller et al.
(1976). Data submitted to EPA-Region II beginning
with monthly wastewater samples taken in January,
1976 show that the range for aerated M^ roenidia
96-hour LC50 was 750 - 6950 ul/1. We believe the
1.8 mg/kg reported as the lowest value in Table 5-2
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- 8 -
7-2
Comments
nay have come about because bioassay data for a
standard toxicant was taken as wastewater
toxicity. The toxicity of sodium lauryl sulfate
is determined each time a test is run. Its
toxicity to M^ roenidia is in the range of 0.87 -
3. SO mg/1, averaging 1.6.
Me have examined Mueller et al. (1976) and find
no reference to bioassays of Grasselli wastewater
to M menidia.
3. The range of 96-hour LC50 values to
costatum
for Grasselli wastewater is given as 29 - 8600
"rag/kg." Reports submitted to EPA beginning in
1976 show a range of EC50 values as 160 - 8600
"ul/1."
4. For the Edge Moor wastewater, the average vanadium
value is given in ug/1 but the range is given in
mg/1. The two should be shown in the same units.
5. Mueller et al. (1976) give no data for LC50 values
to M. menidia for Edge Moor wastewater.
6. Does NO mean "not detected" or "not determined"?
BOD is incompletely defined. It is the amount of
oxygen consumed by microbiological organisms while
assimilating and oxidizing organic (and some nitro-
genous) materials in water or wastewater under speci-
fied environmental conditions and time periods.
A "chronic effect" does not necessarily reduce survivor-
ship. It is conceivable that a substance could have
a chronic effect which does not affect survivorship or
might even increase it. The whole process of evolution
could be considered to result from series of "chronic
effects."
Page Comments
7-11 The abbreviation for "parts per thousand" should be
"0/00," not "0/000."
7-21 Falk, et al., 1974 can be referenced as EPA-600/2-77-112
(NTIS PB 2681S7).
A-33 In Table A-8, should the concentrations be shown as
ug/1 rather than mg/1?
A-40, A-72 In Tables A-10 and A-16, is the data accuracy suf-
ficient to show averages to 4 and 5 significant
figures?
B-l, B-4 Page B-l states there were 66 permittees in 1973.
Page B-4 states there were 61 permittees + 3 previously
mentioned = 64 total. Are these statements incon-
sistent?
B-7 In the last paragraph, the EIS discusses the compo-
sition of the "organic phase" of Grasselli wastewater.
The words "organic portion" would be more accurate
since there is only one phase.
B-12 Bioassay data given for M. menidia is incorrect, as
noted above in comments for Table 5-2 on page 5-6.
The correct range should be 1250 to 6950 ppm for aerated
tests and 660 to 6170 ppm for nonaerated 96-hour LC50
lie, TL50) tests during 1977 and 1978. Similarly,
bioassays on S, coataturo for the same period showed
96-hour ECSO's ranged from 160 to 8600 ppm.
The low values of 1.8 and 1.65 ppm shown for 96-hour
LCSO values for M_^ menidia are possibly the misquotation
of the toxicity of the standard toxicant used for quality
control during the bioassays.
-------
28 „..,.,.
7
*-
U)
28-1
29
GREENSTONE AND SOKOL
E. I. ou PONT DC NEMOURS & COMPANY
GHASSEIUJ PLANT
LINDEN. NEW JERSEY O7O36
Dr. Peter W. Anderson
Marine Protection Program
U.S. Environmental Protection Agency
Region II
Edison, New Jersey 08817
Dear Dr. Anderson:
39 HUDSON STREET
(2OI) 488-3930
August 24, 1979
JAY W. CREENSTONEMJAMD
LEON J. SOKOLwt AM>HA.tAU
KENNETH H. MACK
JOSEPH F. BE HOT. JR.
CAROL W. MCCRACKEN
8581 v. UCNAB ROAD
TAMARAC, FLORIDA 33321
(305)722-O430
ALAN PR1CAL (N. Y. N. J.
AND FLA. BAR) OF COUNSEL
Draft Environmental Impact
Statement (EIS) for 106 -
Mile Ocean Waste Disposal
Site Designation - Public
Hearing, August 21, 1979
As we discussed via telephone, we wish to comment on the 96-hour
TL50 values from the bioassays with Atlantic silversides (Menida menida).
These values are reported on pages B-12 and B-13 of the draft EIS and
were alluded to by Ken Kamlet in his comments at the public hearing- on
August 21st.
We believe that the preparer of the draft EIS (Interstate Electronics
Corporation) either made a typographical error or reported the TL50 values
for the standard toxicant in reporting the range of 96-hour ?L$Q values.
The lower range values 1.8 ppm for aerated tests and 1.6S ppm for non-
aerated tests are not correct. Our data indicate the lowest TL5Q value
to be three orders of magnitude or about 1000 times higher than the values
above.
We plan to submit -these and other comments to Interstate Electronics
Corporation relative to the draft EIS.
Very truly yours.
29-1
oj J&
H. H. McDowell
Environmental Coordinator
August 21, 1979
HWM/jhw
United States Environmental Protection Agency
Marine Protection Branch
Washington, D.C. 20460
Att: Mr. T.A. Hastier, Chief, Marine Protection Branch
(WH-548)
He: DRAFT ENVIRONMENTAL IMPACT STATEMENT
for 106-Mile Ocean Waste Disposal Site Designation
Dear Mr. Wastler:
On behalf of the Bergen County Utilities Authority, the following
comments are offered on the aforementioned draft proposal regarding
the 106-mile Ocean Haste Disposal Site.
1. He suggest that your study include the environmental
impact of a pipeline to the site which would carry sludge from
secondary treatment plants. This study should include the economics
of such a pipeline, and if the economics can be made more favorable
by having a large number of sewer treatment plants utilize the pipeline.
A preliminary calculation by our staff of a pipeline which would
be utilized by the major sewer authorities in Northern New Jersey in-
dicates that disposal costs could be as low as $62.00 per dry ton
including the amortization of the cost of the pipeline which is es-
timated to be well in excess of one billion dollars. This estimate
assumes a substantial Federal subsidy, and a summary of the estimate
is attached hereto as Appendix "A".
Be recognize that the notion of a pipeline is farfetched to some
at this time, but we believe that all possibilities should be explored
in such a comprehensive study.
29—2 2. The draft notes that the economics of transporting
-------
GREENSTONE AND SOKOL
United States Environmental Protection Agency Page 2 August 21, 1979
f f'e N O/r "A "
sewerage sludge to the 106-mile site are almost prohibitive because
of the substantial increase in costs compounded by the limited number
of ships which can travel to that location. He would, therefore,
ask that an additional study be made of potential means of trans-
portation which are less expensive.
For example, can ocean-going vessels be somehow utilized to
transport sludge beyond the 106-mile site? Can the sludge be towed
in disposal containers, or can it be taken on board as either ballast
or in empty storage compartments? If any of these ideas are feasible,
is there sufficient ocean-going traffic to handle the volume of sewerage
sludge generated in this area?
3. Can industrial pretreatment requirements be relaxed
if an economically feasible method of disposal at the 106-mile site
can be developed? This could have serious economic consequences for
29—3 for this region since in some cases, the requirement of industrial
fit pretreatment places an onerous burden on small and medium sized
I businesses. This makes it additionally difficult for this area to
•£•• compete for new business investment, and we would note that this
•£* area has continued to experience a net outflow of industrial jobs over
the past 20 years.
If we can maintain an environmentally sound method of disposal
which is ultimately less costly in the aggregate, including cost to
the Authority as well as well as cost to industrial users, then the
plan could be very attractive. In any event, we would like to have
more data available for evaluation.
Very truly yours,
GREENSTONE & EOKOL
LJSicy
cc: Dr. Peter Anderson
Enclosure
cc: John G. Costello
James J. Craffey
TABLE 1
BERGEN COUNTY UTILITIES AUTHORITY
106-MILE DUMP SITE
Sludge Pumping
Cost Estimate
In Million $
Case 1
Present Worth BCUA & PVSC
Capital Cost $ 1,050.0
Operation & Maintenance 3.1
Present Worth - Operation &
Maintenance (20 years, 6-5/8X) 33.5
Total Present Worth $ 1,083.5
Annuallied Cost 99.3
Cost Per Dry Ton (In $) 625
Local Costs
Capital Costs $ 1,050.00
Less Grants 690.00
Local Share 360.00
Debt Service (30 years, 7Z) 29.0
Operation & Maintenance 3.1
Total Annual Costs . 32.1
Cos Per Dry Ton (In $) 202
$ 1,050.00
690.00
360.00
29.0
15.9
44.9
62
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TABLE 2
BERGEN COUNTY UTILITIES AUTHORITY
COMPARISON OF SLUDGE DISPOSAL ALTERNATIVES
Present Worth
Annuallzed $ Costs
Cose Per
in million $ Dry Ton
30 /
E
U)
Alternative
106-Mile Pumping:
Case 1 BCUA & FVSC 99.3
Case 2 Regional 112.2
106-Mile Barging - BCUA Only:
Fuel @$0.60/gal ($8.00
wet ton) 3.7
Fuel @$.090/gal ($10.76
wet ton) 4.9
Thickening & 106-Mile Barging - BCUA Only:
Fuel «$0.60/gal 2.5
Fuel £$0.90/gal 3.1
Local Costs i
Annual $Cost Per '
Cost • Dry Ton
In million $
Land Based - BCUA Facility Plan
BCUA Only:
3.2
62S
154
230
310
155
194
201
32.1
44.9
1.3
1.6
1.95
202
62
3.7 230
/*-\ 4.9 310
123
146
123
LEAGUE OF WOMEN VOTERS
Of MOMMOUTM COUKTV. KJ.
August 10. 1979
Mr. T. A. Waatler
Chief, Marine Protection Branch (WH-548)
Environmental Protection Agency
'Washington. D. C. 20460
Sei Draft EIS for 106-Mile Ocean Waste Disposal Site Designation
Ihe League of Women Voters of Honmouth County has been actively
concerned with the problems relating to ocean dumping since 1970 when
sludge dumping was first called to the attention of the citizens of
the county. It affected us deeply since Monmouth is the northernmost
county in Hew Jersey with an ocean shore. It is in closest proximity ;
to the Kew York Bight and our extensive northern shore faces the bays
and harbors behind Sandy Hook.
The Monmouth League's last participation in the discussion of ocean
dumping was for the hearing in 1977, which we did not attend, but to
which we sent written testimony (apparently, not recorded by iPA). Our
statement strongly opposed moving the sludge dump site to the edge of
the Continental Shelf. Our grounds included the "out of sight, out of
mind" factor, the cost for monitoring and adequate shipping which we
felt would prevent expenditures for alternate disposal methods, the
difficulty of monitoring the deepwater 3ite, and the fact that sewage
sludge appears to play a. relatively s.nall part in pollution of the
Bight. V/e stressed the need to cease use of the ocean for wastes com-
pletely. This testimony was in response to the proposal of an alternate
northern or southern site, but was also in answer to locally generated
arguments favoring moving municipal sludge to the 106-mile site.
Basically, we continue to hold this same position. However, we
appreciate the fact that a good deal of advance has beer, made toward
eliminating the two types of ocean dumping covered in the 213 and that
some concrete knowledge has been gained about the lOc-mile site through
monitoring the effects of actual dumping there. We also appreciate the
fact that some alternative to land application or to continued disposal
in the Bight is necessary for emergency use.
Based on research which has shown relatively little commercially
valuable benthic life in the area and because it is believed that fish
in passing through are sufficiently mobile to avoid a polluted environ-
ment, we feel it necessary to approve the 106-mile site in preference
to either the northern or southern alternatives on the more sensitive
and productive Continental Shelf.
However, it is obvious that continuing problems exist with this
alternative. Aost readily understood is the cost of providing adequate
shipping and surveillance. It was some time ago in a session called by
Assemblyman Villane at Sandy Hook that the Coast Guard testified to its
need for electronic surveillance of ships traveling any distance to
sea. It is disappointing that this condition still e;:ists although the
proposal to authorize ships to use the 106-mile site is again under
-------
League of Women Voters of Honmouth County -2 \
consideration.
It seems obvious under existing conditions of an inadequate
fleet and inadequate monitoring facilities that to transport all
sewage sludge to the 106-mile site would be not only costly, Cut
extremely wasteful if the operation is to be carried out only on an
interim basis. Consequently, we must return to the position frequently
expressed at the 1977 hearings that transfer of dumping to the 106-
mile site must be considered only if conditions in the Bight become
extremely hazardous and only if the sewage sludge can be pinpointed
as a major contributor to the condition. Interim use alone should
not call for the kind of expense involved in long-term dumping. It
seems essential that some sort of cooperative arrangement should be
planned in advance so that such expenditures would in no way be en-
couraged. Otherwise, the difficulties of enforcing the 1981 deadline
will become virtually insurmountable.
The need to consider the energy requirements to transport sludge
to the 106-mile site reinforces the view that it must be used only
on an interim basis.
On the other hand, it must be recognized
mile site only on an interim basis and as an a.
other areas (land or New York Bight) will mean
Coast Guard monitoring abilities will, presuma
This obviously leaves the question of how to p
du.T.ps and, ever, more difficult, how to monitor
regulations governing separation of wastes and
Here., again, the answer remains to hold as cloi
the 1981 schedule for total cessation of ocean
that use of the 106-
Iternate to use of
that upgrading of
bly, not take place.
revent habitual short
compliance with the
methods of disposal.
ely as possible to
dumping of sludge.
As far as the cost of monitoring by KuAA is concerned, we feel
that this expense is necessary regardless of what occurs in the
future. There remain enough, unanswered questions and enough potential
threats at the- 106-;uile site regarding the ultimate fate of wastes
dumped there and their combination with other components to require
careful and continual monitoring. It is too easy to recall that
dumping in the New York Sight went on for years without monitoring
and until the resulting unhealthy condition became too obvious to
ignore, no open acknowledgement of the probable causes of the prob-
lem v.-us made, let alone any efforts to determine exactly how serious
the contamination had become or from what source it originated. V.'e
were well involved in a virtually irreversible disaster before most
of us knew we were there. This must not be allowed to happen as a
result of use of the 106-mile site and it is impossible to feel that
the potential for a repetition it- not there.
As far as the acid dumps are conoex-ncd, we art extremely grati-
fied to note the progress -i?A in making toward land treatment of
industrial wastes. '.Vii:h the ultimate removal of large dischargers
cuch ac Jupor:1;-ild-^e y.cor, American 'jyanarnid and .;orcl. some improve-
ment should be;:ir: to tecome noticeable ai.d it should :ua>:e uor.forni.ty
by smaller co.iii'ar.ie': easier to enforce. Correcting the lar^e co~pani( s
i'irct iu ur. ai'viaablo approach.
i] thu r-e.-noval of hazardous pollutants, we
League of \'o.;ien Voters of Mor.'iouth Cour.ty
-3
are extremely pleased to see c:nphasi£ on the need to reuse wastes as
far as possible. This v/ill obviously become increasingly necessary as
basic elements are depleted and, as with most environmental problems.
that we are just beginning to attac:':, the tine to start reclamatior.
is already well past. ?he imiat-diacy of the need to alter past procedures
is apparent.
V/ith the progress apparently being made, we feel thr.t pressure
should continue en Dupont-Orassolli at whatever cost to the~i to seeJi
r.eans of waste treat:aent other than oqcan dumping. We have lor.?; be-
lieved that there will be an adverse economic reaction to alteratior
of the habits that industry has been allowed to follow in this country
(and following our lead, now, in many others). Ultimately this will
have to be considered unavoidable. However, it nus t not be allowed
under any circumstances to influence us to return to 'the habits we are
just beginning to abandon, or, at some point, the whole process of
environmental cleanup will have to begin over from a far worse posi-
tior. than we are presently in. V,'e do not believe the economic effects
will be permanent. Other methods and technologies will mean different,
but not fewer jobs, as they are already providing. We need to set or.
with facing the facts and doir.g something about them. V.'e trust that
KPA v;ill :-;ot permit itself to weaken stands already taken. Your guide-
lines for moving sludge to the 106-mile site and for handling indus-
trial wastes are excellent I? they car. be enforced. This we feel they
must be, again, at whatever cost.
V/e would appreciate having this testimony read into the record
of the hearing to be held or. August 21 so that in the future vie can
receive pertinent material for comment.
Sincerely,
Iftithleen H. Ripper
r.'atural Resources Chairman
93^ Mavesink River Road
Locust, r;. j. 07760
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31
MID-ATLANTIC FISHERY MANAGEMENT COUNCIL
_1
•*•
31—2
ROOM 2115 FEDERAL BUILDING
NORTH 4 NEW STREETS
DOVER. DELAWARE 1990)
DAV10 H. MART
TiLCPHONE: »847«-£nt
JOHN C. MvaOM. M.
October 4, 1979
Mr. John Rhett
Deputy Assistant Administrator for
Water Program Operations (WH-S46)
U.S. Environmental Protection Agency
Washington, DC 20460
Dear Mr. Rhett:
The Mid-Atlantic Fishery Management Council is very concerned
about the chemical dumping in area 106. We finally were able to
obtain a copy of the EIS on September 5, 1979. We note a hearing
was held on August 21, 1979 in Trenton, New Jersey.
Although we have previously expressed concern over the
potential Impact on fisheries by ocean dumping and have requested
to be Informed of proposed changes we still do not seem to be on
the mailing list. I trust you can notify the proper personnel
so this may be corrected.
According to the EIS, routine bioassay will be performed using
appropriate sensitive marine organisms. May we receive Information
and/or copies of these bloassays.
The report also states the probability of fish accumulating
toxic levels of contaminants from the 106 area is extremely remote due
to the high migratory nature of the fish. This would seem to depend
on concentrations In the area and the extent of the migrations.
I gather from the report that since we do not know the extent
of fisheries In the 106 area due to the lack of surveys that you
assume a problem will not exist, yet we are advised that species
such as blueflsh move to deep water during the winter as well as
migrate to the south. Are we sure area 106 is outside Important
fishery areas or merely taking a lack of knowledge as a means to
appease the chemical and other toxic waste disposers who want a
cheap disposal technique.
Page 2
Shark are becoming a more Important species for the
US. We surely don't expect the shark not to be In area 106. We
can reasonably expect tuna and swordflsh to be In the area.
Since swordflsh are already contamlnanted this should be a signal
for greater caution.
In order that we may evaluate the EIS more properly we
request a 11st of all contaminants being dumped In area 106 and
a copy of the bloassays that have been completed to date.
We are enclosing a table from the NOAA evaluation of area 106
that show the species that we can expect to be In the area.
We will take particular interest In the bloassays on those
species highlighted as they are very Important to the fishery
of the Mid-Atlantic Area.
Sincerely,
JCB/nbw
enclosure
John C. Bryson
-------
Table 2. Lilt of Fish Species
ih Species Caught on Longlli
DUD 106* 38 -408H. 71°-73W
line In and around
Family
Lamnldae
Carcharhlnldae
Sphymldae
Squall dae
Dasyatldae
Aleplsaurldae
Lamprldae
Branchlostegldae
Pomatoroldae
Coryphaenldae
Sparldae
Gempyltdae
Scoobrldae
XIphHdae
Istlophorldae
Holldae
Common name
White shark
Shortfln nato
Porbeagle
Silky shark
Blacktlp shark
Oceanic wMtettp shark
Sandbar shark
Dusky shark
Tiger shark
Blue shark
Scalloped haunter-head
Unidentified hannerheads
Spiny dogfish
Unidentified sharks
"Stingrays"
Shortnose lancetflsh
Longnose lancetflsh
Unidentified lancetflsh
Opah
Tlleftsh
Blueftsh
Dolphin
Sea Bream
Escolar
Ollflsh
Uahoo
Little tunny
Albacore
Yellowfln tuna
Blgeye tuna
Bluefln tuna
Unidentified tuna
Swordflsh
Blue marl In
Uhlte marl In
Unidentified marl In
Ocean sunflsh
Scientific name
Carcharodon carcharlas
Isurui oxyrlnchus
Laona nasus
Carcharhlnus falclfonals
C. Unbatus
C. longlmanus
C. nllbertl
C. obscurus
Galeocerdo cuvlert
Prlonace glauca
Sphyrna lewlnl
Sphyrna ssp.
Squalus acanthlas
Aleplsaurus brevlrostrls
A. ferox
Aleplsaurus ssp.
LampHs reglus
Lopholatllus chamaeleontlceps
Pomatomus saltatrlx
Coryphaena hlppurus
Archosargus rhomtaoldalts
Lepldocyblum flavobrunneum
Ruvettus pretlosus
Acanthpcyblum solanderl
Euthyn'nus alletteratus
Thunnus alalunga
T. albacares
T. obesus I
T. thynnus i
Xlphlas gladius
Nakalra nlgrlcans
Tetrapturus albldus
Hoi a roola
32
National Wildlife Federation
1412 16TH SI., N.W., WASHINGTON, D.C 20016 2O2—797-6800
August 31, 1979
Miscellaneous catch: Atlantic loggerhead turtle, unidentified turtles, "hake"
Mr. T.A. Hastier
Chief, Marine Protection Branch (HR-548)
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Rei NWF Comments on DEIS for 106-Mile Ocean
Haste Site Designation
Dear Mr. Hastier!
Attached are the National Wildlife Federation's ("NHF')
formal comments in response to the subject Draft Environmental
Impact Statement. The substance of these comments coincides
closely with that of NWF'a statement at the August 21, 1979,
public hearing in Trenton, N.J. The present comments provide
additional details and make several new points not raised in
Trenton, however.
The thrust of our reaction to the DEIS is that it does a
very poor job of conveying useful information. He do not, how-
ever, oppose formal designation of the 106-Site for continued
use (provided adequate justification for such designation is
presented in the Final EIS). Since the EIS for the 106-Site
will inevitably be used as a model by IEC and others in preparing
Site Designation EIS's for the dozens of remaining dumpsites
still to be studied, we are particularly anxious to ensure that
the present EIS is worthy of emulation.
I trust that the Final BIS will address (and resolve) all
of the various concerns raised in the attached comments and in
the appended Exhibits.
*Data from all sources.
320
Sincerely,
4 fcl*
Attachments
Kenneth S. Kamlet
Counsel, and Assistant
Director for Pollution
and Toxic Substances
Dr. Peter Anderson
Dr. Thomas O'Connor
-------
Mr. T.A. Hastier
August 31, 1979
Page Two
Dr. P. Kilho Park
Paul Birmingham, Esq.
Mr. Bill Mansfield
Dr. William Dunstan
Dr. Joel O'Connor
National Wildlife Federation
1412 16TM ST., N.W., WASHINGTON, D.C 20036
7
*•
VO
32-1
COMMENTS OP THE NATIONAL WILDLIFE FEDERATION ON
THE DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR
106-MILE OCEAN WASTE DISPOSAL SITE DESIGNATION
JUNE 1979
The Draft Environmental Impact Statement ("DEIS*) proposes
the designation for continuing use of the 106-Mile Chemical Haste
Disposal Site located approximately 90 n.mi. east of Cape Henlopen,
Delaware. The Site has been used for ocean disposal since 1961
(p. B-l), primarily for the disposal of industrial chemical wastes.
Although not mentioned in the DEIS, low-level radioactive wastes
and high explosives have also historically been dumped at the
Site. See, Interstate Electronics Corporation. 1973. Ocean
Haste Disposal in Selected Geographic Areas. Rept. 4460C1541.
Currently, only four chemical waste dumpers continue to use the
106 Sitei American Cyanamid (Linden, N.J.), E. I. duPont de
Nemours ( Co. (Edge Moor, Del. and Linden, N.J.), and Merck & Co.
(Rahway, N.J.). Three of the four current permittees (all but
duPont-Grasselli) will cease ocean disposal within the next two
years (p. 1-2) . The other one may be allowed to continue dumping
at the 106 Site beyond 1981, if it can continue to demonstrate
compliance with the Ocean Dumping Criteria—including an adequate
need to dump and non-availability of land-based alternatives.
The Site covers portions of the Continental Slope and
Continental Rise and is very large. Hater depths within the Site
range from 1,500 meters in the northwest corner to approximately
2,725 meters in the southeast corner. • The Site is "immense* in
surface area (p. ix, fn.) and, in fact, is larger than the whole
New York Bight Apex. The DEIS, however, provides no quantitative
information on the Site's surface area.
The purpose of the DEIS is to evaluate the suitability of
the Site for continued use as an ocean dumpsite. The Site was
approved for dumping on an interim basis in January 1977 "pending
completion of baseline or trend assessment surveys and designation
for continuing use or termination of use." 40 C.F.R. 5 228.12(a).
By the terms of the current Ocean Dumping Criteria, this interim
approved status "will remain in force for a period not to exceed
three years [expiring in January 1980]..., except for those
sites approved for continuing use or disapproved for use by
promulgation in this Part during that period of time." Id. By
the terms of the Criteria, site designation "will be made based
-------
-2-
-3-
W
Ul
O
on environmental studies of each site, regions adjacent to the
site, and on historical knowledge of the Impact of waste disposal
on areas similar to such sites ...." with "(a]11 studies for the
evaluation and potential selection of dumping sites [to] be con-
ducted in accordance with the requirements of SS 228.5 and 228.6."
: '40 C.F.R. S 228.4(b). Among the general site selection criteria,
specified in S 228.5, .Is the requirement that "(t]he sizes of
ocean disposal sites will be limited in order to localize for
identification and control any Immediate adverse impacts and
permit the Implementation of effective monitoring and surveillance
programs to prevent adverse long-range impacts.* 40 C.F.R.
S 228.5(d). "The size, configuration, and location of any disposal
site [is to) be determined as a part of the disposal site evalua-
tion or designation study." Id. Among the specific site selection
criteria, prescribed by S 228.Z~are: consideration of the
1 "(feasibility of surveillance and monitoring") and " (e)xlstence
and effects of current and previous discharges and dumping in the
i area (including cumulative effects)." 40 C.F.R. SS 228.6(a)(5),
(a)(7).
The DEIS, unfortunately, does not adequately discuss the
32—2 legal framework of the proposed action.
Our specific criticisms of the DEIS follow:
1. THE DEIS DOES HOT ADEQUATELY SYNTHESIZE, ANALYZE, AND
EVALUATE THE INFORMATION PRESENTED !
The National Wildlife Federation regards the DEIS as a very
poor document of only the most limited value to decisionmakers
and to public and interagency reviewers. In our view, it falls
far short of fulfilling the informational requirements of an EIS
32—3 in general and of a site designation EIS in particular. Specifi-
cally, although the DEIS contains much descriptive information,
it reflects little effort to synthesize and digest this informa-
• tion in a manner capable of aiding the decisionmaker or enlighten-
32r4 ing the public. For example, while the DEIS makes repeated
reference to the notion that deep dumpsites make good dumps!tes
(see, e.g., pp. xi, 2-6, 3-1, 5-15), there is absolutely no
mention or discussion of the premise that waste dispersal is
32—5 preferable to waste containment as a waste management technique.
This is an issue which is the subject of wide debate in the
scientific community and should have at least been touched upon
in the DEIS. Similarly, although Appendix B is a compilation of
information on contaminant inputs to the 106-Mile Chemical Haste
32-6 Site, little of this information is integrated into the text of
the EIS, and virtually no effort is made to discuss such
pertinent questions as: possible interactions of wastes dumped
at the site) cumulative effects of interacting wastes; frequency
of dumping in relation to persistence of particular waste con-
32—7 stltuents; total quantities dumped on a cumulative basis since
the inception of dumping; how much of particular wastes the Site is
capable of assimilating or accommodating under worst-case condi-
tions, etc.
32-p
32-lp
in short, given the choice between conclusory assertions
and documented statements, between undigested information and
careful analysis and evaluation, and between blanket generaliza-
tions and precise discussion, the DEIS seemed to always choose
the less informative alternative.
2. THE DEIS'S DISCUSSION OF THE POTENTIAL ADVERSE IMPACTS
OF HASTE DISPOSAL AT THE SITE IS INCOMPLETE AND INCONSISTENT
The DEIS is deficient, for example, in failing to adequately
address—especially in its discussion of industrial waste dumping —
the factors which led EPA Assistant Administrator Tom Jorling at
" the Toms River hearing in 1978 to reject the designation of the
106 Site for sewage sludge disposal. Many of these factors are
equally applicable to many of the industrial wastes presently and
potentially dumped at the 106 Site, and should have been discussed
in the DEIS.
Specifically, while the EIS emphasizes the waste dispersal
mechanisms said to be in operation at the 106 Site, it gives
exceedingly short shrift to waste concentrating mechanisms which
also operate at the Site and which could result in toxic constitu-
ents entering biological systems, potentially including human
seafood, in dangerous amounts. Examples of such concentrating
mechanisms—some of which are briefly alluded to in passing in
scattered sections of the EIS—are:
a) Concentration of lipophilic organic waste constituents,
including toxic constituents, in monomolecular surface films of
oil and grease present at the 106 Site (see, EIS, pp. 2-15, 4-11,
A-36, A-37).
b) Concentration of toxic metale and organic constituents
by adsorption to and complexation with the massive ferric hydroxide
floe formed as a result of the huge quantities of DuPont Edge Moor
titanium dioxide wastes dumped at the site. This floe, dumped on
the average every four days (DEIS, at B-4), is known to persist
for periods of 3-4 days, making the presence of an almost continu-
ous floe a very real possibility.
c) Concentration of toxic waste constituents and prolonged
persistence of these constituents and of pathogenic microorganisms
through their association with floating organic particles—
especially if sewage sludge additions to the site are increased.
d) Potential bioconcentration of toxic waste constituents
as a result of the known attraction of many species of fish to
ocean dumping activities—a fact that the EIS itself acknowledges
in other contexts (see, DEIS, at 3-23, 2-19, 4-4, 4-13, 4-26).
e) Concentration by build-up of toxic waste constituents
at the seasonal or permanent thermocline—a factor Implicitly
discussed only in the context of sewage sludge (DEIS, at S-13).
-------
'Ul
-4-
Not only is this concern not discussed in connection with
industrial wastes, but the assumption is made that trapping of
constituents at the thermocline will avoid concentration of
toxic wastes by preventing significant deposition on the ocean
bottom. (See, DEIS, at 5-9, 5-11; xi, 2-6, 4-15, C-3).
f) Bioconcentration as a result of the vertical
migration of fish (DEIS, at 2-30, A-63-A-66) and zooplankton
through the thermocline—potentially bioconcentrating contam-
inants accumulated there.
g) Concentration as a result of current-mediated
transport of contaminants in dissolved, particulate, and
precipitate form to onshelf and offshelf fishery areas where
bioaccumulation may occur (DEIS, at 2-10, 2-30, 3-6, 2-4, xi,
3-14, 3-16, 2-21, 2-33, 2-39, 2-3, 4-3 - 4-4, 4-27, 3-10, 2-31,
3-25, A-75).
h) Concentration and enhancement of persistence and
toxicity of toxic organic constituents as a result of diminished
biodegradation in the deep ocean. Could be a problem, for
example, for the organophosphate pesticides dumped by American
Cyanamid (DEIS, at 2-7, A-29; cf., Ch. 5).
i) Concentration as a result of the horizontal migra-
tion of fish in and out of the dumping areas (DEIS, at 2-30, A-75).
j) Concentration as a result of the gradual settling
of participates to the ocean bottom, coupled with the enhanced
food-gathering capabilities of deep-sea organisms (DEIS, at B-15).
k) Possible concentration through the operation of
•loop currents* similar to those in the Gulf of Mexico which may
entrain hydrophobia and particle-bound contaminants and partially
counteract otherwise operative dispersive tendencies. The
possible role of Gulf stream eddies in such a phenomenon needs
to be discussed (DEIS, at 3-3, A-5, A-7).
i
1) Concentration in the vicinity of Important fisheries
as a result of short-dumping (the frequency of which increases
with increasing distance to the dump site) in the New York Bight
and at other on-Shelf locations (DEIS, pp. 4-25, 2-10, 2-30, 3-14,
: 3-16, 2-21, 2-33, 2-39).
• It should be noted that Assistant Administrator Jorling,
in his Toms River decision, specifically concluded (p. 12) that
•the feasibility of using an off-the-shelf site for the disposal
32—11 °f sewage sludge should be based on a consideration of at least
six major factorst known environmental acceptability; ability to
monitor impact; surveillance of dumping activities; economic
burden; logistics; and the effect of utilizing such a site on
the ability of dumpers to meet the December 31, 1981, deadline for
-5-
32-12
32^
"the termination of harmful sewage sludge dumping.• It is
incomprehensible to us that the present DEIS could undertake
to consider the feasibility and suitability of the 106-Site,
for either sludge or industrial chemicals, without at least
attempting to address the six major factors that were central j
to EPA's 1978 decision—especially, since that decision appears
to conflict with the present proposed action.
Similarly, the Report of the Bearing Officer at the
Toms River hearing (September 22, 1977) discusses at great
length the general apprehensiveness of the scientific community :
knowledgeable concerning processes in deep ocean environments
about the environmental impacts of 'dumping wastes containing
solid materials into deep ocean waters.* Among the reasons
cited for being wary of ocean disposal in the deep sea were:
its relatively very low biological decomposition rates; its
great constancy with respect to the physical-chemical environ-
ment, and the resultant sensitivity of fauna living there to
small environmental changes] and the minimal opportunities to
alter the course of events if deleterious effects occur in the
deep sea. I append as EXHIBIT 1, pp. 75-87 of the Hearing
Officer's Report as an illustration of the kinds of issues the
present DEIS should have addressed, but largely failed to deal
with. I append as EXHIBIT 2, a copy of the National Wildlife
Federation's testimony at tFe Toms River Rearing, pages 3-25 of
which discuss the arguments both for and against use of the
106 Site.
The Final EIS must address these concerns.
3. THE PETS PAILS TO EVALUATE THE 106-SITE IN LIGHT OF
THE PROPERTIES OF THE SPECIFIC WASTE CONSTITUENTS PRESENTLY
DUMPED THERE AND IN RELATION TO THE SITE'S OVERALL CAPACITY TO
ASSIMILATE OR ACCOMMODATE WASTES PRESENTLY AND POTENTIALLY
DUMPED THERE
A third basic shortcoming of the DEIS is its failure to
evaluate contaminant inputs to the Site in light of the Site's
capacity to receive and accommodate them. For example, although
Appendix B purports to describe contaminant inputs to the Site,
it contains little in the way of critical analysis and no
attempt is made to integrate the contaminants data found in the
Appendix into the body of the EIS. It seems to have been tacked
on as a reluctant afterthought. In fact, it is impossible to
properly evaluate the suitability of a site for ocean dumping
without providing an in-depth evaluation of the fate and effects
of dumping particular wastes at that site. (DEIS, at 2-38.)
This the DEIS woefully fails to do. Although the Impact State-
ment tacitly assumes that the 106 Site is large enough, and
Individual dumping operations conducted there are segregated
enough, to avoid or minimize significant interactions among
different wastes dumped at the Site, this is far from self-evident
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-7-
, and needs to be documented In detail. Such documentation is
; especially necessary in light of the large volume and high
: frequency of ocean dumping (nearly a dump 'a day) taking place at
I the Site (DEIS, at B-4). Among other things, the Final BIS
! neede to discuss how far apart different wastes must be dumped
! in relation to how far the wastes can reasonably travel, in
: order to avoid undesirable waste interactions (DEIS, at 2-42,
4-7, 5-20).
The Final BIS needs to discuss the properties of all
significant waste constituents expected to be dumped at the
32-14 1°6 Site. How toxic are they? How persistent will they be
under worst-case dumpsite conditions? How susceptible are they
• to bioaccumulatlon? And so forth.
The Final EIS also needs to assess the overall assimila-
tive capacity of the 106 site and how close present and planned
dumping practices will approach this limit—based upon worst-case
assumptions. The DEIS's flat assertion that the "total
• assimilative capacity of the Site is unknown* (at 2-42) is an
32—J.5 unacceptable cop-out—particularly since scientists convened
by NCAA earlier this month In Crystal Mountain, Washington,
were able to readily estimate what they regarded as the Site's
minimum assimilative capacity.
The potential for and consequences of waste interactions
• at the Site and cumulative impacts must also be considered
32-16 (DEIS, at 2-41, B-4) cf., at 5-15)—including possible inter-
actions with an incineration area planned to be designated to
the south of the Site (p. 3-8).
' One of the most serious shortcominga of the Draft State-
ment's discussion of contaminant inputs to the 106 Site is its
failure to discuss the toxicity of these inputs on anything
approaching a worst-case basis. For example, although the DEIS
1 Itself contains data indicating that DuPont-Grasselli waste can
32—17 kill half of a population of Atlantic sllversides in 4 days
'; at concentrations as low as 1 to 2 parts per million, which
translates into a 'limiting permissible concentration* in the
range of 10 to 20 ppb (DEIS, at B-12-B-13, 5-6), the DEIS blithely
1 accepts for discussion purposes Company bioassay results on
1 opposum shrimp and sheepsead minnows which yielded limiting con-
' centrations forty thousand times higher (DEIS, at B-13, B-16).
; The DEIS also fails to point out, in discussing these toxicity
[ tests, that deep-sea organisms are likely to be much more
sensitive to ocean-dumped toxicants than are the estuarine or
nearshore organisms typically used for bioassay testing purposes.
This means that the bioassays relied on in the DEIS are likely
to greatly understate the potential Impacts on resident organisms.
Toxicity test results are also mis-used in the discussion
of the potential use of the 106 Site for sludge dumping. The
32-191
32-20
toxicity of sewage sludge, a multi-phase waste with solid and
particulate components, is inappropriately compared to that of
liquid industrial wastes strictly on the basis of 96-hour
particulate-phase bioassays. An accurate assessment of the
toxicity of ocean-dumped sewage sludge can only be obtained
based on the results of 10-day solid-phase bioassays, as
specified in the ocean dumping criteria—but lacking in the
DEIS (at 5-16)..
4. MISCELLANEOUS COMMENTS
The DEIS is inconsistent in a number of places. For
example, it provides three different figures, ranging from 100
meters to 250 meters (DEIS, pp. A-9, 3-4, 5-9, 2-7), as the
depth of the permanent thermocline. It also gives three
different distances of the Site from shore (at least two of
which are stated to be the distance to nearest land), ranging
from 90 to 110 miles (DEIS, Summary Sheet, p. 1, pp. 2-4, 2-37).
The Final EIS should use the closest-to-shore distance uniformly
and consistently.
Another inconsistency, already alluded to, is the quite
different mode of analysis of potential sludge dumping impacts
at the 106 Site than of industrial waste dumping impacts at
the Site. One can only assume that EPA is more interested in
| avoiding the appearance of inconsistency between its 1978 Toms
! River decision and subsequent EIS and the present EIS which
I reached opposite conclusions regarding the suitability of the
106 Site for sludge than it is in avoiding the inconsistent
I evaluation of sludge and industrial waste dumping within the
! same document in the present EIS.
< The Draft EIS also fails to adequately consider the
! alternative of not redesignating the 106 Site for continued use—
| in light of the fact that come 1981 only one industrial dumper
| . will still be using the 106 Site, the DuPont-Grasselli plant
I (DEIS, at 1-2, 2-3, 2-19). Nor does the EIS adequately explain
• its assertion that DuPont-Grasselli cannot develop land-based
alternatives and so must be allowed to continue its ocean
32—21 dumping. (DEIS, at 2-2, 1-2, B-5.) And, although we do not
''. take the position that site designation EIS's generally need to
address in detail the circumstances of individual ocean-dumpers,
' ! it does seem essential in this case, in considering the need
I for permanent designation of the 106 Site, for the EIS to
; address (in a non-conelusory way) the need for continued ocean
i dumping on the part of the solitary dumper known to probably
, want to continue using the Site beyond 1981.
i Finally, the DEIS fails to adequately evaluate the
32—22 suitability of the 106 Site as an ocean dumpsite in light of the
requirement of the ocean dumping criteria that an important
factor in evaluating a dumpsite is the feasibility of conducting
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Ln
CJ
surveillance and monitoring at the Site. (DEIS, at 1-10, 2-7,
2-8, 2-9, 2-27, 2-16, 4-10). The difficulty of carrying out
adequate surveillance, and particularly monitoring, at the
Site (DEIS, at xii), is one of the strongest arguments against
perpetuating use of that Site for ocean dumping. As was noted
above, monitoring difficulties were one of the principal
concerns of EPA at the Toms River hearing. The Final EIS
should give greater attention to this criterion factor.
• Additional comments and concerns!
(a) The Final EIS must justify the designation of an
enormous dumpsite like the 106 Site—its actual surface area
in square miles should be given, along with an indication of
how this area compares with that of whole New York Bight—in
32—23 light of the explicit requirement of the Ocean Dumping Criteria
(S 228.5(d))—noted briefly without discussion on pp. 1-9 and
2-32 of the DEIS—that disposal site sizes 'will be limited in
order to localize for identification and control any ijnmediate
adverse impacts and permit the implementation of effective
, monitoring and surveillance programs to prevent adverse long-
range impacts."
(b) The DEIS refers in several places to the 'con-
tinuing need to have available for use a site of known environ-
mental characteristics for the disposal of some wastes under
emergency conditions ....• Rhett transnittal letter, p. 2
(see also, DEIS, pp. iii, 1-2). The Final EIS should discuss
the Intent of this statement in light of the statutory prohibi-
tion against "emergency* ocean dumping except "in an emergency
to safeguard life at sea." Section 105(h)i 33 U.S.C. S 1415(h).
(c) The DEIS erroneously refers to a March 1977 amend-
ment of the HPRSA as bringing U.S. legislation into full com-
pliance with the international Convention (p. vii). In fact,
as correctly noted elsewhere in the DEIS (p. 1-9), the amendment
designed to achieve conformity with the Convention was adopted
in March 1974.
(d) The DEIS erroneously refers to the Corps of
Engineers as holders of special ocean dumping permits (p. 1-14).
The distinction between "special" and "interim" ocean dumping
permits applies only to dumping under EPA as opposed to Corps
of Engineer jurisdiction. (Only for international law purposes,
would dumping approval for the Corps be considered "special"
permits—as opposed to "general" permits.)
(e) The Final EIS should, in keeping with SS 226.7
and 22S.8, specify conditions on the future use of the 106 Site,
including constraints on the dumping there of significant
quantities of persistent, toxic wastes. It should indicate,
in other words, what waste types the 106 Site may be suited for
and what waste types it is clearly unsuited for. For example,
should the 106 Site be considered for the dumping of barge-loads
of organo-arsenical wastes?
(f) The Final EIS should attempt to explain why it was
deemed necessary to again consider the possibility of using the
106 Site for the dumping of sewage sludge, after EPA repeatedly
rejected the idea (i) at Toms River, (11) in a 1978 EIS on
sludge dumping alternatives, and (ill) in a 1979 redesignation
of the present sludge dumping site (and an alternative 60-mile
area) for future sewage sludge ocean dumping.
(g) Among the DEIS's numerous undocumented assertions
which require elaboration and explanation in the Final EIS are
statements on the following pages i 3-6, 3-13, 3-32, 4-5, 4-18,
4-21, 4-23, 4-24, 4-25, 5-15.
(h) The DEIS fails to discuss the heavy metal content
of ML Industries' ocean-dumped waste. Numerous heavy metals are
present in small, but significant, concentrations. The data
should be provided.
(i) The reference on p. 3-23 to "NOAA-NMFS (1972)". is
not reflected in the bibliography.
(j) The index to the DEIS, on p. xx, mislabels
Appendices C and D.
(k) The DEIS states (p. 3-28) that the "sport catch
[of fish in the New York Bight] often equals or surpasses the
commercial landings of certain species ...." In fact, a recent
NOAA Workshop in New York City indicated that the recreational
catch may exceed the commercial catch by a factor of 5 (check this
with the NOAA New York Bight Project office). The implications
of this in terms of at least short dumping impacts should be
addressed. (I.e., the fact that certain areas in the Bight may
be closed by the FDA to commercial shellfishing does not afford
much protection to recreational fishermen.)
(1) The DEIS unjustifiably minimizes the problem of
PCB contamination of sewage sludge (p. 5-4), especially where
sludge particulates are concerned. A NOAA-funded study by West
and Hatcher indicates that the heaviest PCB contamination of
bottom sediments in the New York Bight is associated with sewage
sludge dumping.
(m) Of all aspects of NWF's testimony at the Toms River
hearing, the DEIS chose to cite the least pertinent (p. 5-19).
(n) The DEIS does not explain the significance of its
reference (p. A-37) to dissolved and particulate aliphatic
hydrocarbon levels.
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-11-
5. CONCLUSION
The National Wildlife Federation does not necessarily
oppose continued use of the 106 Site for certain industrial
chemicals—provided such use is adequately justified. We are,
however, irrevocably committed to ensuring the integrity and
adequacy of the Site Designation process. The present DEIS is
the first of a long series to be prepared by the Interstate
32 — 24 Electronics Corporation on literally dozens of ocean dumpsites
all around the country. At least some of these other sites make
very poor ocean dumpsites and should not be redesignated. We
are concerned that the site designation BIS for the 106 Site,
since it will inevitably be looked upon as a model for future
site designations, be a model worthy of being imitated. The
present DEIS is a poor model indeed.
In rewriting this EIS, the purposes of such documents,
as articulated by a succession of Federal courts, should be kept
in mind:
•The 'detailed statement1 required by
S4332(2)(C) serves at least three purposes.
First, it permits the court to ascertain
pj whether the agency has made a good faith
| effort to take into account the values NEPA
1st seeks to safeguard. To that end it must
-P- 'explicate fully its course of inquiry, its
analysis and its reasoning.' Ely v. Velde,
451 F.2d 1130, 1139 (4th Cir. T9T1T;
Appalachian Power Co. v. EPA, 477 F2d 495,
5Vf (4th Cir. 1973). See~aTso Natural .
Resources Defense Council v. E.P.A., 4*78
F.2d 873 (1st Cir. 1973); Environmental Defense
Fund v. Ruckelshaus, 142 U.S. App. D.C. 74,
TT5~F.2d S84 [2 ERC 1114] (1971). Second, it
serves as an environmental full disclosure law,
providing information which Congress thought
the public should have concerning the particular
environmental costs involved in a project. To
that end, it 'must be written in language that
is understandable to nontechnical minds and
yet contain enough scientific reasoning to alert
specialists to particular problems within the
field of their expertise." Environmental Defense
Fund v. Corps of Engineers, 348 F.Supp. 916, 933
(W.D. Miss. 1972). It cannot be composed of state-
ments 'too vague, too general and too conclusory. *'
Environmental Defense Fund v. Froehlke, 473 F.2d
346, 348 (8th Cir. 1972). Finally, and perhaps
most substantively, the requirement of a detailed
statement helps insure the integrity of the
process of decision by precluding stubborn
problems or serious criticism from being
swept under the rug. A conclusory statement
'unsupported by empirical or experimental
data, scientific authorities, or explanatory
information of any kind' not only fails to
crystallize issues, Natural Resources Defense
Council v. Grant, 355 F.Supp. 280,287(E.D.N.C.
1973), but 'affords no basis for a comparison
of the problems involved with the proposed
project and the difficulties involved in the
alternatives.' Monroe County Conservation
Council v. Volpe, 472 F.2d 693, 697(2d Cir.
1972). Roreover, where comments from responsible
experts or sister agencies disclose new or
conflicting data or opinions that cause concern
that the agency may not have fully evaluated
the project and its alternatives, these comments
may not simply be ignored. There must be good
faith, reasoned analysis in response.'
Massachusetts v. Andrus, 12 ERC 1801, 1810-11 (1st Cir. Feb. 20,
1979).
The present Draft EIS, unfortunately, is a collection of
statements which are "too vague, too general and too conclusory"
and it fails to contain "enough scientific reasoning to alert
specialists to particular problems within the field of their
expertise."
He trust the Final EIS will do better.
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75
MR 81978
Public Hearing on Relocating Sewage Sludge,. , -- r-< 11
Ocean Dumping Sites " "--"•""•=•=•,
Toms River, N. J.
May 31-June 1. 1977
r
Report of the Hearing Officer
Sints out Uial weail muhugs *iu .Ojmiaant in the area, bat th'ij
resource potectial in comparison to surf clams has i
e£ined(si-5-8-r. p. 128).
The major economic Impact associated with the use at this site
I the Increased cost of transportation of sewage sludge for dump-
g at
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76
77
w
t_n
environmental Impacts of damping wastes containing solid materials
into deep ocean waters. At a 1971 ocean disposal conference,
co-sponsored by the Woods Bole Oceanographlc Institute (WHOI)
and the COE, the panel on biological effects stated:
"Disposal should not occur la the deep sea. i.e., beyond the
continental shelf. A fundamental reason for this suggestion
is the following. The deep sea is an area where biological de-
composition rates are apparently very low in comparison with
other ocean regions. It is an area of great constancy with
respect to the physical-chemical environment and it is thought
that the fauna living there is finely tuned to small environmental
changes. Thus, the fauna may be quite susceptible to large
environmental perturbations such as might be expected with the
introduction of dredge spoils. If deleterious effects occur in the
deep sea, the opportunities to alter the course of events are minimal.
We, therefore, suggest that deep sea should be ot'f limits for disposal
activities at least until other information is brought to bear which
•*-oulc render the possible dangers non-existent.
"A similar view was expressed at a 1974 workshop at Woods
Hole, sponsored by the National Academy of sciences (NAS): Data
for the evaluation of the deep sea as a disposal site are inadequate.
This is due to: difficulties in conducting bioassays; slow rates of
mixing and diffusion potentially resulting in anaerobic conditions;
slow organic degradation; and narrow tolerance ranges for sensitive
assemblages of organisms. Although the area is relatively stable
in comparison to the shelf and nearshore, the much greater scientific
uncertainty, and consequently increased risk associated with off-shelf
disposal, dictate that any but the most Innocuous use of the area
should be approached with extreme caution'T.E-S-6-r, p. 65-66).
The National Oceanic and Atmospheric Administration (NOAA)
has also expressed opposition to moving dumpers to the 106-mile
site without knowledge of the impacts at the 106-mile site (MR, 125).
NOAA points out that, in comparison to shelf waters:
"... the environmental effects of disposal in deeper waters are
correspondingly more difficult to measure, and hence, to
predict. This is due to factors such as the greater depths of
water and distances from shore, involving cumbersome sampling
techniques in many instances and problems in geographic positions,
and also to the general paucity of environmental and biological
information in the off-the-shore areas.
"In the case of DWD-106 this situation is further compli-
cated by the interaction of major water masses. Shelf Water,
Slope Water and Gulf Stream Zddies.
"The DWD-106 is, therefore, an exceedingly complex
oceanographic area in which to assess environmental conditions
and external Impact upon those conditions." (RR, 132-133)
Dr. Carol Lichfield, a marine microbiologist. expressed concern
about the survival in the deep ocean of micro-organisms contained
in sewage sludge:
"Unfortunately, there is very little information on the
survival of coli/orms in deeper waters.
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78
'It has been shown, however* that decreased temperatures aid the
survival of coliform bacteria in the increased salinities and slightly in-
creased pressures that they would encounter at the deeper dump site.
therefore, automatically assuming that deeper waters will "take care of"
potential pathogens more efficiently than that which occurs at the present
location, could lead to a very false sense of security. " (HR. 3S5)
The statement of the National Wildlife Federation (NWF) Includes as ex-
hibits statements and published articles of a number of highly respected marine
scientists who have made significant scientific contributions to our understand-
ing of deep ocean environments (E-ll-16. p. 329-837). The NWF statement
summarizes Its concerns about the environmental impact of deep ocean dumping
in this fashion.
"As little as we know about the marine environment for aearshore
continental shelf areas, and the fate and effects of pollutants In it, we
know even less for deep ocean areas off the edge of the continental shel/.
"For example:
(a) Sewage sludge organic matter may have a totally different be-
havior off than on the continental shelf—to the extent such organic matter
finds its way into water below a few hundred feet from the surface, there
is good reason to expect its rate of biodegradation to be greatly diminished.
The possible consequences of such a reduction In mlcrbbial
decompostion rates are unknown. Extensive studies by Dr. Holger Jannasch
and his associates "at Woods Hole (see. Exhibits A-l - A-4) have consistently
demonstrated that the in situ microblal response to enrichment of deep sea
water and sediments with various organic substrates was between one to
three orders of magnitude lower than in the controls, (Exhibits A-3. p. 675)
that the use of the deep sea as a dumping site for organic wastes is "very
79
inefficient" as a means of either disposing of or recycling these
wastes, aa well as being an approach resulting In the "rather
uncontrollable" accumulation of waste materials or decomposition
products on the ocean bottom.
Jannasch has also expressed the view (Exhibit A-2) - that
"In the deep sea, organic wastes... could accumulate for years
and years and then float up undecayed" to contaminate seas and
beaches. Conversely, as expressed by Dr. Bump's of Woods
Hole (see Exhibits B-4 and C-5). "There is the possibility of
creating anaerobic deep sea environments from the dumping of
organic materials, "depending "on the rate of introduction of
organic materials and the strength of the advective processes, "
as well as on the rates of biodegradation.
(b) Deep sea marine organisms may be far more sensitive
to ocean dumping impacts than their nearer shore counterparts—
As noted by Dr. Howard Sanders of the Woods Hole Oceanographlc
Institution, (See, Exhibit C-l, p. 3), the ocean floor below the
thermocline is "a region of remarkable stability" In which
'(t)emperature, salinity, oxygen conditions, and other factors in
contrast to shallower waters are essentially unvarying and have
changed little over many thousand and even millions of years.'
"Under these "conditions of constancy and predictability over
geological long periods of time there have evolved in the deep sea
a delicately attunned, highly sensitive assemblage of organisms
with a very narrow range of tolerances. " which "can be expected
to be most fragile". "As a consequence, a perturbation or stress
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80
Ui
oo
that might hare little significance In the variable and less predic-
table shallow waters could have severe and perhaps catastropic
implications in the deep sea."
This concern Is shared by Dr. P. H. Wiebe of Woods Hole
(Exhibit B-l. p. 1-5), although he acknowledges that "we doo't
(really) know-that deep sea populations are fragile."
(c) The artificial transport of heavy metals and other
undesirable sludge constituents Into the open ocean off the edge
of the shelf through ocean dumping constitutes a new major
source of such constituents In these wastes, the consequences of
which are unknown.
As pointed out by Or. Ralph Vaccaro (Exhibit. B-2). "the
heavy metal load transported into marine coastal areas by rivers
and streams is quickly precipitated out of the column, becomes
bound to the sediments and is effectively excluded from the ocean
realm. " making atmospheric "fall-out" the only major natural path-
way for the deposition of many heavy metals In the open ocean.
The direct introduction of such metals and other chemicals.
as well as of microorganisms, into this environment as a result
of ocean dumping could have severe and perhaps catastrophic
consequences.
(d) Sludge particles and associated contaminants could
become entrained In the Gulf Stream (which impinges on the 106-
mile site) and be transported to fishing grounds as far away as
Newfoundland.
81
"(e) The nature and effects of possible interactions between
sewage sludge and the various toxic chemicals presently dumped
at the 106-mile site are essentially unknown. " (HR. 290-294)
• It should be noted, however, that in the proceedings leaning to the
moving of Camden to the 106-mile aite, ten affidavits by EPA and FDA
staff members recommended moving Camden from the Philadelphia
site to the 106-mile site. These affidavits were based on the presence
of fecal micro-organisms in the Camden sludge which might possibly
affect shellfisheries and beaches and on the presumed greater oppor-
tunities for dilution and dispersion at the 106-mile site (E-6-7-a>.
None of these affidavits addressed the questions of survival of pathogens
in the deep ocean, the lower rates of decomposition of materials in
deep ocean environments, and the possibility of severe damage to biota
accustomed to a very stable environment, which are the major concerns
expressed by the marine scientists familiar with deep ocean environments.
It can be concluded from these statements that there is agreement
among experienced marine scientists that deep ocean disposal of wastes.
particularly wastes containing solid materials, has the potential for
""causing- severe environmental impacts. The types of impacts that
could occur could result In subtle, long-range adverse effects which
might not be detectable until trends leading to severe Irreversible
damage had already begun. The dumping of sewage sludge at the
106-mile site would, therefore, be regarded as having high potential
for causing severe, if unknown, adverse environmental Impacts.
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83
Ul
VO
b. Economic
There are no known shellfisheries in the area of this site.
However, certain wind conditions In the area could cause waste
materials to drift onto the upper slope, where the developing red
crab fishery would be active or even to the outer shelf where there
are several seasonally active fisheries (flounder, porgy, butter-
fish, lobster by IT. S. fishermen) (E-19-11. p. 63). There is.
therefore, a potential adverse economic Impact associated with the
use of this site, although It is not quantifiable at the present time.
The National Fisheries Institute has expressed opposition to moving
dumpsites from their present locations because of increased con-
taminantion of other areas (S-49).
The greatest economic impact of moving sludge dumping to the
106-mile site would be in the added cost of transporting the' sludge
to the 106-mile site for dumping. To do this would require the
addition of carrying capacity in the New York Metropolitan Area.
primarily by the City of New York (HR, 243-246). There is socr.e
disagreement as to what would be the most economical way to
accomplish this (HR. 247-249; 256-257) and the basis on which
the estimates made by the City of New York were made. Supple-
mentary Information supplied for the record indicated an annual cost
of $19,200, 000 per year if no constraints were placed on the rate
of discharge (£-15-15). These figures are based on amortizing the
new carrying capacity over a four-year period; without this, the
total annual cost is estimated at $17,200, 000. The basis on which
the operating costs are estimated la consistent with the figures used
by EPA Region n in estimating overall costs for barging to the 106-
mile site (E-5-6-r; p. 68-69).
The cost of moving all New York Metropolitan area sludge dump-
ing to the 106-mile site is estimated by EPA Region n at between
$35.0 million and 43. 8 million dollars annually, as opposed to the
present $5.4 million, assuming a constant sludge volume between
now and 1981 (E-5-8-r, p. 70). This estimate does not include the
cost of monitoring the site or the cost of Coast Guard surveillance
of dumping.
The City of Philadelphia has estimated its costs for moving to
the 106-mile site at $5. 210, 650 over a 3. 5-year period. This is an
annual average cost of $1, 490, 000 (E-16-26). These are based on
estimates provided by their present hauling contractor.
Moving sludge dumping to the 106-mile site would also have
an economic impact on the cost of surveillance of dumping operations.
The Coast Guard has stated that surveillance would have to be done
by shiprider until their automated surveillance system becomes oper-
ational, and that this will require :he use of additional personnel,
with added costs for salaries and training. No estimate is avail-
able as to what these costs might be
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84
To develop and implement an effective monitoring program
at the 106-mile site would have a significant economic Impact. No
information Is available as to what this would be, but typical
baseline cruises cost $200,000-5300,000 each, based oa EPA and
NOAA costs. If four seasonal cruises were regarded as an ade-
quate monitoring program, the total cost would be about $1. 000, 000
per year. It should be noted, however, that baseline cruises of this
nature would aot be capable of detecting the types of environmental
effects which have been indicated to be of importance by responsible
marine scientists, as indicated in the previous section (HR. 297-198).
In summary, the available information indicates that the total
additional economic burden of moving sludge dumping to the 106-mile
sits would be well In excess of $30 million per year. The bulk of
this cost would be borne by the communities now dumping sludge.
Several municipalities pointed cut the difficulties they might have
in obtaining the additional funds necessary to barge to the 106-mile
site as well as implement alternatives by 1981 (HP.. 245-246. 254-
255. 448-449, 493). The- WCS-comments that any significant incre-
ment between now and the end of 1981 in the cost of sewage sludge
disposal could as easily discourage as encourage the expedited
phase-out of sludge dumping if it had the effect of diverting into
—continued ocean dumping limited funds 'which would otherwise be
available 10 implement a dumping phase-cut (HR, 278).
65
= . Public Health
It is unlikely that sludge dumping at the 106-mile site would have
any conceivable impact on shorelines and beaches. Concern was
expressed, however, concerning the increased frequency of short
dumping expected to be attendant upon a. move of sludge dumping
to the 106-mile site, as a result of adverse weather conditions and
possibly willful misconduct by haulers (HR, 304-306, 492; E-5-6-r,
p. 70). The probability of such occurrences has not been estimated.
Since, however, the barge paths would cross highly productive shell-
fish areas on the continental shelf, any short dumping could result
in contamination of shellfish by pathogens. Unless these corridors
were closed to shellfishing by the FDA, there could be contamina-
tion of some shellfish from time to time, and the concomitant risk
of harvesting them. The results of the EPA Region Ul studies at
the Philadelphia dumpsite suggest that fecal micro-organisms can
persist in the marine environment for long enough periods of time
to move great distances (E-18-7, p. 161-163). If this is the case,
then there could be a hazard to public health of unknown proportions
from short dumping en route to the 106-mile site.
d. Social
Concern has been expressed in several statements about the
general public reaction of moving sludge dumping from the present
sites to the 106-mile site. These concerns are based on the belief
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that there may be an "out of sight - out of mind" reaction (HR 16,
37; S-49). It is also felt that moving sludge dumping to the 106-
mile site —aid Increase pressure to permit an indefinite continu-
ation of ocean dumping (HR, 37, 287-289). The difficulty of
detecting adverse Impacts at this site as well as reduced public
concern are cited as reasons that this may occur.
Summary
60-mile site
ne environmental damage to the site would be expected^
it is unlilcbly that there would be significant adverse effeptS on
commercial fisheries, shorelines or beaches. Thejre would be a
significant adverse economic impact in that thescost of barging to
this site would be about .$8xniilllon per year^inore than costs for
barging to the present site.
106-mile site
There is agreement amoo^knowleMgeable marine scientists that
the dumping of wastes containing solid materials, such as sewage
sludge, into the deepydcean could cause severe iamage to the marine
environment. Tly^primary concern is for long-rairge, undetectable
until irrever&mle. adverse effects on marine biota. TXere is no
likelihood/of signttlcahradVerse- effects on shorelines and^aches
fromiduxnping at this site; there is, however, some possibilityN
nd
National Wildlife Federation
1412 16TH ST., N.W., WASHINGTON, D-C. 20036
Ptton* 202— 797*800
STATEMENT OF KENNETH S. KAMLET
ON BEHALF OF THE NATIONAL WILDLIFE FEDERATION
AT PUBLIC REARING BEFORE THE U.S. ENVIRONMENTAL PROTECTION AGENCY
ON THE DESIRABILITY OF RELOCATING OCEAN DUMPSITES
FOR THE DISPOSAL OF MUNICIPAL SEWAGE SLUDGE,
TOMS RIVER, NEW JERSEY,
MAY 31 - JUNE I, 1977
verse impa
i Continental Slope and She
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INDEX
Text of Statement
Pages
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I. Introduction 1-2
II. Basic Assumptions . 2
III. Arguments in Support of Relocation to the 106 Site
1. MPRSA requires off-Shelf dumping, wherever
feasible 3
2. Greater productivity and density of marine
life on the Shelf 4
3. Hill permit restoration of commercial shell-
fishing at sites closed by FDA •.' 5
4. Will increase cost of ocean dumping and provide
dumpers with incentive to expedite land-based
alternatives 7
5. Hill help avoid future fishkills and beach
closings .. ..... 9
6. Hill, in the Philadelphia case, reduce human
health impacts associated with shellfish
contamination 12
7. Ocean dumping criteria require relocation
because of 'Category I* impacts at present
sites 13
IV. Arguments Against Relocation of the 106 Site
1. Hill appreciably increase the risk that
current phaseout deadlines will not be met . 14
2. Will result in unknown and possibly serious
environmental consequences ... 15
3. Hill preclude monitoring and corrective
measures ..-.. 20
4. Hill increase the likelihood of undesirable
short dumping 24
V. Considerations Relevant to the 60-Mile Site . . 26
VI. Conclusions and Recommendations 27
Footnotes
List of Exhibits
Exhibits
STATEMENT
Introduction
My name is Kenneth S. Kamlet. I am counsel to (and also a
biologist with) the National Wildlife Federation CNWF"), which is
by far the nation's largest private conservation organization. The
Federation's longstanding efforts to strengthen federal regulation of
ocean dumping practices, and to promote the phase-out of harmful
or potentially harmful ocean dumping in favor of suitable land-based
alternatives, are well-known. He are here today to comment on the
desirability of relocating two sewage sludge ocean dumps!tes, which
together contribute some 4.1 million wet tons per year of sludge
and associated contaminants to coastal waters located off the shores
of Maryland and Delaware in the case of the Philadelphia site, and
of New Jersey and New York in the case of the New York Bight Site.
The two present sites are located 40 miles and 11 miles offshore,
respectively. The primary candidates for use as alternative sites
are the so-called '60 mile site,* located about 33 miles south of
Long Island, and the so-called '106-mile site," located about 90 miles
due east of Cape Henlopen, Delaware.
In a nutshell, for the reasons discussed below, NWF recommends
against any change in sludge dumping locations under present conditions.
The May 6, 1977 Federal Register notice (42 Fed.Reg_. 23164-65)
which announced the holding of these hearings, listed five questions
as to which EPA was interested in receiving comment and quantitative
information. The notice also solicited comments on the relative
advantages and disadvantages of sewage sludge dumping at each of the
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existing and candidate sites, in light of the eleven evaluation
factors listed in S 228.6(a) of the revised ocean dumping criteria.
He will touch on and discuss several of these questions and
factors on the comments which follow, but will approach the matter
from a somewhat different conceptual framework, since we don't believe
that selection of an alternative site in which to relocate existing
dumping activities should be treated the same as Initial site
selection for a brand-new ocean dumping activity or that the
choice of a site for interim use for 3 or 4 years pending a dumping
phase-out should be treated the same as selection of a site for use
over much longer periods.
Basic Assumptions
The analysis which follows, and our conclusion that neither
sludge dumpsite should be relocated at the present time, are based
upon the following basic assumptions:
1) That the sewage sludge under consideration does not and
cannot (in the foreseeable future) meet the ocean dumping criteria and
is, in fact, harmful to the "marine environment, and that, therefore,
its continued ocean dumping is undesirable;
2) That the deadlines currently In force for the termination
of sewage sludge ocean dumping are reasonable (if not generous) and
should not be relaxed for anything short of the most dire emergency;
3) That any change in the location or conditions of sewage
sludge ocean dumping which would lead or contribute to a real (or
imagined) inability to meet current phase-out deadlines is undesirable;
4) That the current sewage sludge dumpsites should not be
relocated unless there" is a reasonable basis for believing that the
potential for adverse impacts Is appreciably less with use of new as
opposed to old dumpsites;
S) That the ocean dumping of sewage sludge at a previously
undegraded location should not be Initiated absent clear and convincing
evidence that abandonment of previously utilized sites will yield
at least equivalent benefits; and
6) That the ocean dumping of sewage sludge should not be
initiated at sites as to which the consequences of such dumping cannot
be reasonably predicted and monitored.
Arguments In Support of Relocation to the 106 Site
1. The statute requires the Administrator, "wherever feasible,"
to designate ocean dumpsites located beyond the edge of the Continental
Shelf; the two existing sludge dumpsites are on the Shelf, the 106
Site Is off the edge of the Shelf.
This statutory directive appears in section 102(a)(I) of the
Marine Protection, Research, and Sanctuaries Act (MPRSA"). It is re-
iterated In S 228.5(e) of the revised ocean dumping criteria. What-
ever its basis or justification, it must be heeded as the law of the
land.
Comment: The statute does not make use of off-Shelf dumpsites an
absolute requirement; such sites must be used only where "feasible."
It is necessary and appropriate in considering use of the 106 site
(or other off-Shelf site) for sewage sludge to evaluate its
"feasibility* in terms of each of the following: (a) incremental cost
relative to existing practices, (b) ability to properly evaluate,
monitor, and control dumping occurring at this site, and (c) effect
of such a move on the ultimate phase-out of sewage sludge ocean dumping.
Section 228.5(e) of the criteria, moreover, recognizes that the
appropriateness of using off-Shelf dumpsites may be greater for brand-
new than for existing dumping sources, in specifying that EPA "will,
wherever feasible, designate ocean dumping Bites beyond the edge of
the continental shelf and other such sites that have been historically
used." (Emphasis added).
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2. The productivity and density of important marine
species is far greater on the Shelf than off, with a correspondingly
greater likelihood on the Shelf than off that ocean dumping will
produce undesirable consequences.
A public Affairs Office brochure on the MPRSA, published by EPA
in December 1972, describes the statutory encouragement of off-Shelf
dumping as *a vital provision since about 90 percent of known marine
life is concentrated above the Continental Shelf.* Drs. Vaccaro, Grice,
Rowe, and Wlebe of the Hoods Hole Oceanographic Institution
(Exhibit c-3) have questioned the accuracy of this statistic "as
given,* although they acknowledge that "it probably holds [true]
for the productivity (a rate function) of economically useful marine
species or for the relative concentration of biomass (biomass per unit
volume) present at these diverse locations." Rachel Carson, in The
Sea Around Us, described the continental shelves, "Of all the parts
of the sea...[as) perhaps most directly important to man as a source
of material things," pointing out for example that most of the "great
fisheries of the world... are confined to the relatively shallow
waters over the continental shelves.* In short, it seems apparent that
on-Shelf ocean dumping, all things being equal, would be more likely
to encounter (and potentially adversely impact) economically
important marine species on the Shelf than off it.
Comment; As has been pointed out by Vaccaro, et al. (Exhibit C-3),
"Here one to integrate the entire water column [at off-Shelf locations),
along with the attendant bottom, our expectation is that the
quantities of biomass would not differ as markedly [relative to on-
Shelf locations]" as productivity and density considerations would
suggest. In terms of potential impacts on the organisms, one cannot
assume that the extent of these Impacts will be determined solely on
the basis of relative organism densities. As Vaccaro, et al. also
point out (id.), "Even if damage is substantiated [for nearshore ocean
dumping] there is no a priori certainty that transporting a particular
waste further out to sea would entail a less damaging effect.*
Nor can one assume that all things are otherwise equal on and off the
Shelf. For example, differences in organism sensitivities to sludge
contaminants, differences in, sludge persistence, differences in
current patterns, differences in "short dumping* frequencies, and
differences in the ability to track the fate and effects of ocean-dumped
sludge,'may all operate to offset any apparent advantage in favor of
off-Shelf dumping based upon relative organism densities alone. It
is important to consider organism' densities, but this factor alone
should not be determinative. (The problem of seafood contamination
is addressed in section 6 of this part).
3. The relocation of sludge dumping from the present sites,
both of which have been closed by the Food and Drug Administration to
commercial shellfishing, to either the 60-mile site or the 106-site,
will permit recovery of those sites and restoration of active
commercial fishing.
As documented at the EPA adjudicatory hearing on ocean dumping of
sewage sludge by the City of Philadelphia, the "main band* of the
U.S. sea clam (also known as the "Surf Clam*) "ranges from Long
Island to approximately Cape Hatteras [in] a band about 20 miles wide
from the coast out to approximately the 100 foot depth level.* The
sea clam industry, moreover, "accounts for approximately 43 percent
of... all clams and cysters and mussels... harvested in the United
States today,* the entire industry being 'virtually limited" to the
area from Long Island to Cape Hatteras. I/
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Because of ocean dumping In the Hew York Bight, the Food and
Drug Administration in 1970, closed to shellfishing a circular area
o£ over 113 square miles in size, encompassing the sewage sludge
dumpsite. Another nearly 100 square miles were added to this closure
area in 1974 to encompass sources of Long Island and New Jersey sewage
effluent. In December 1976, the FDA closed to shellfishing a 71-square
mile area encompassing the Philadelphia dumpsite, along with another
area of equal size surrounding the DuPont acid waste dumpsita. 2/
The fact that the "Delaware Bay Dump Site* formerly used for
Philadelphia sewage sludge had recovered sufficiently from the effects
of dumping to be reopened to shellfishing on January 1, 1975, less than
2 years after the cessation of dumping at that site (in May 1973),
after having been declared off-limits to shellfishing in Hay 1970, 3/
gives rise to some hope that relocating the present dumpsites may
allow resumption of some currently suspended shellfishing activities.
Comment: In point of fact relocation of the sludge durapsites
would yield little or no benefit to commercial shellfishermen. In
the first place, the closure of the New York Bight site would remain
in effect even with relocation of sludge dumping activities, due to
continued discharges of shore-based sewage. In the second place,
relocation of sludge dumping to the 106-site, would probably result
in closure by the FDA of a new 20-mile long, 4-mlle wide (i.e., 80
square mile) corridor representing the overlap between the route of
barge travel from Ambrose Light to the 106-site and the distribution
of commercially significant populations of the ocean quahog. 4/
Such a corridor would be establihhed to guard against seafood con-
tamination due to short dumping enroute to the assigned dumpsite.
(Relocation to the 60-mile site would be even worse, since commercially
important quahog populations exist in the immediate vicinity of
that site.) And, in the third place, even if sludge dumping at the
Philadelphia site were halted almost Immediately (i.e., it was re-
located to another area), and even if recovery and reopening of the
site to shellfishing could all be completed within a year to a year-and-
a-half (i.e., by July to December, 1978), at best, 2 to 2-1/2 years
of shellfishing use would be gained before the dumping is scheduled
to be phased-out entirely anyway (i.e., by the end of 1980). So, it
might be possible to reopen a 70-square mile area for 2-1/2 years;
but it might be necessary in exchange to close down for up to 4-1/2
years (i.e., the period from the changeover to the end of 1981)a brand-
new 80-square mile area.
4. The relocation of sludge dumping to more distant off-
shore dumpsites would significantly increase the cost of continued
ocean dumping and would, therefore, provide an incentive to sludge
dumping municipalities to accelerate and intensify their efforts to
develop and implement land-based alternatives.
Table 30 and Figure 41 of the Draft Environmental Impact State-
ment on the Ocean Dumping of Sewage Sludge in the New York Bight
(February 1976) ("DEIS"), pp. 244-45, indicate that relocating New
York and New Jersey sludge dumpers from the present 11-mile site to
the proposed 60-mile site would increase sludge hauling costs between
1976 and 1981 by nearly $33 million or some 69 percent. If the
shift were made to the 106-mile site, sludge hauling costs by
commercial barges or tankers would not significantly increase
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(according to the DEIS) beyond the incremental cost of moving
out to the 60-mile site. The cost for New York City tankers to move
out to the 106-site would be about double that of moving to the 60-
mile site. WestChester County barges would not be cost-effective at
any distance beyond the existing dump site. Since ocean dumping as
currently practiced is significantly less costly than land-based
alternatives (see,e.g., DEIS Table 31, p. 252), economic incentives
now exist for sludge dumping municipalities to prolong the continuation
of ocean dumping to the extent possible. If the costs of ocean
dumping could be increased by relocating the dumpsites and increasing
haul distances, the additional cost increment necessary to accomplish
land treatment or disposal would be reduced or eliminated, along with
the disincentive to expedite implementation of land-based
alternatives.
Comment: In the first place, any significant increment between
now and the end of 1981 (the deadline for completing the phase-out of
sewage sludge ocean dumping) in the cost of sewage sludge disposal
could as easily discourage as encourage the expedited phase-out of
sludge dumping, if it had the effect of diverting Into continued
ocean dumping limited funds which would otherwise be available to
implement a dumping phase-out. In the second place, if the cost
increment for relocating the dumps!te were not substantial enough
to jeopardize the Implementation of land-based alternatives, chances
are they would also not be substantial enough to provide much if any
incentive to accelerate a dumping phase-out. In fact, a total
(maximum) cost increment of $5 or $6 million a year—$33 million
divided by six years, see DEIS Table 30—for 4 million (present) or
even 8 million (projected for 1981) wet tons of sewage sludge
(which would correspond, based on a solids content of 5%, to 200,000
to 400,000 dry tons per year), would give rise to a maximum annual
cost increment of $30 per dry ton. While this might make land-based
disposal attractive for at least some bargers relative to incineration,
pyrolysis, or drying and sale, it would not add significantly to the
economic attractiveness of land application, and for some bargers would
still leave ocean dumping as the most cost-effective alternative. See,
DEIS Table 31, p. 252. Indeed, if the "mother-ship" or large tanker
approach advocated by some proves feasible, the incremental cost of
sludge hauling to a more distant ocean dumpsite could be substantially
less than $30 per dry ton. This would further reduce any spur to
accelerate the implementation of land-based alternatives.
5. The relocation of sludge dumping to more distant off-
shore dumpsites would reduce the risk of repetition of the conditions
which led to beach closings in New York and fish kills off New Jersey
last summer.
It is a commonly held popular view in New York and New Jersey
that the beach closing and fish kill incidents of last summer were
attributable to the ocean dumping of sewage sludge at the 11-mile
New York Bight site. To the extent that this belief has a factual
foundation, the further offshore one can move the dumping, the
better, and the less likely will be a repetition of last summer's
unfortunate occurrences. Even if sludge dumping did not cause last
suraier's fish kills and beach foulings, it could do so in the future,
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particularly as the quantity of sewage sludge ocean-dumped doubles
between now and 1981. So, whether it is regarded as a remedial or
merely a precautionary measure, it makes sense to move sludge dumping
activities as far from the coastline as possible.
Comment: The various investigative bodies which have looked
into the causes of last summer's incidents, uniformly regard factors
other than sludge dumping as the primary if not sole factors respon-
sible for these incidents. For example, a National Science Foundation
workshop held in October 1976,_5_/ concluded that "the anoxic (low
oxygen) condition that existed during the summer and fall of 1976
[and which was responsible for the reported fish kills) was the
combined result of meteorological conditions, shelf water circulation,
and the degradation of organic matter, including an extensive algal
bloom." (p. ix). In terms of organic matter degradation, the
evidence presented to the workshop indicated (pp. 68-69) that ocean-
dumped sewage sludge could account for less than 6 percent of the
organic carbon inputs and less than 11 percent of the nutrient inputs
with phytoplankton production contributing far more than both sludge
dumping and estuarine input. The oxygen demand associated with these
sludge inputs makes up a far smaller proportion of the total. While
"a prudent person would assume that urban waste and runoff had some
significant effect" (p. 81), the contribution of ocean-dumped sewage
sludge seems quite small.
An October 1976 report by the New Jersey Department of
Environmental Protection_6_/ concluded that "the overwhelming proportion
of the shore pollution (associated with dead fish washing ashore in
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connection with the fish kill incident] was associated with the algal
bloom and decay process," and that the "black tide" alleged by some
to be sewage sludge was, in fact, decaying algae. A rough estimation
of annual nitrogen loadings in New Jersey coastal waters (Table 1,
p. 13) attributed only 8 percent of the total to sewage sludge.
Finally, a February 1977 report on the Long Island beach closing
incidents_7_/ by NOAA's MESA ("Marine Ecosystems Analysis") program,
concluded that the floating litter that inundated Long Island's south
shore beaches in June 1976 could have come from a variety of sources
(pp. 54-55), but that the sewage sludge dump site must be considered
a "relatively minor" source of floatables (p. 55). In terms of oil
and grease contributed to the New York Bight, for example, sewage sludge
contributes only 2.6 percent of the total (p. 38).
Whether or not the 50-year practice of dumping sewage sludge has
produced a stable distribution pattern of sludge-associated bottom
muds, it is no longer being contended that ocean-dumped sewage sludge
is steadily creeping toward New York's beaches. 8/
Thus, there would appear to be no compelling short-term need,
based upon prevention of future beach fouling and fishkill incidents,
to require a sudden relocation of sludge dumping activities to sites
located further offshore—particularly, if such a step would in any
way compromise efforts to totally eliminate the practice of sewage sludge
ocean dumping within the next 4-1/2 years. If, as the quantities of
sludge increase over the next several years, the complicity of sludge
dumping becomes more significant, it may be appropriate to re-evaluate
the relocation of such dumping activities. But, that time has not yet
'arrived.
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6. The relocation of sludge dumping by the City of
Philadelphia to K>re distant offshore dumpsites would reduce the risks
to human health of shellfish contamination by sludge-associated micro-
organisms in fisheries in the vicinity of the present dumpsite.
EPA Region III has amassed data demonstrating incipient bacterial
contamination of shellfish and the beginnings of detectable bottom
accumulations of sludge (within which the viability of harmful micro-
organisms might be increased) in the vicinity of the Philadelphia
sludge dumpsite. Although fecal contamination of shellfish has
apparently not yet progressed to the point that a serious public health
threat presently exists, continued ocean dumping at the 40-mile site
could well give rise to such a threat between now and the scheduled
cessation of Philadelphia's dumping 3-1/2 years from now. Inasmuch as
it could take a year or more to implement a decision to relocate the
dumpsite, and in view of the potential public health threat, procedures
to relocate the Philadelphia dumpsite should be initiated immediately.
Comment; The possibility of human food chain contamination as a
result of continued sludge dumping at the Philadelphia site is the most
compelling argument in favor of relocation, at least for this one
site. (In the case of the New York Bight site, the New York Bight
apex is already so badly contaminated, not only as result of sludge
dumping, but because of other dumping and discharge activities, that
edible shellfish populations are few and far between in this part of
the Bight, and even those that are present would likely be unfit for
human consumption even if sludge dumping were moved off the Shelf).
However, there is a better way to minimize the food chain risk than
simply to transfer the dumping from one place to another; namely, to
take steps to reduce the microorganism content of the sludge, with
resort being made to a dumpsite shift only if these steps fail to bring
the contamination problem under control. We understand that efforts
are currently underway to reduce the microorganism levels of
Philadelphia sludge through modifications in the digestion process,
as well as through aging of the sludge. While we would support and
encourage immediate efforts to lay the groundwork for a possible later
dumpsite relocation (if that were to prove necessary) we are not
persuaded that a final decision to relocate should be made at this time.
7. The ocean dumping criteria require relocation of the
current sewage sludge, ocean dumpsites by virtue of "Category I"
impacts observed at these dumpsites.
Section 228.11(c) of the revised ocean dumping criteria requires
the EPA Administrator to place necessary limitations on the use of
dumpsites which display Category I impacts, so as to reduce the impacts
to acceptable levels. Both the 11-mile site and the 40-mile site
appear to show Category I impacts, based upon conditions (i), (ii),
and (v) of S 228.10(c) of the criteria. Short of a total dumping phase-
out (not possible immediately), the only practicable measure capable of
reducing impacts at these sites to acceptable levels is dumpsite
relocation.
Comment: In the case of the 11-mile site, relocation of sludge
dumping cannot reasonably be expected to restore the environment to
an acceptable condition, as long as dredge spoil and other dumping
continue nearby, and as long as inadequately treated sewage wastewater
continues to pour into the New York Bight from land-based outfalls.
Substantial upgrading of sewage treatment in New York and New Jersey
at about the time of the scheduled sludge dumping phase-out, will
hopefully make cessation of sludge dumping in the Bight meaningful
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(in terms of yielding visible improvement in the condition of the
Bight) by the end of 1981. Mere relocation now won't do much good
in the Bight, and may merely relocate some of the harm from one site
to another. As far as the Philadelphia dumpsite is concerned, relocation
of sludge dumping to another area might improve conditions in the
present dumpsite area for an extra couple of years, but at the expense
of the alternative dumpsite. If microbial contamination of edible
shellfish is the primary documentable concern, efforts to reduce such
impacts by reducing the microbial contamination would seem the more
reasonable approach. If these efforts were unsuccessful, relocation
might then be appropriate.
Arguments Against Relocation to the 106 Site
1. A shift from the present duirpsites, at which harm to
the environment can be documented, to sites further offshore at which
such harm may be more difficult to detect and demonstrate, may
appreciably increase the risk that current phaseout deadlines will not
be met.
Although the present sludge dumpers are subject to phase-out
deadlines and implementation schedules as part of their ocean dumping
permits, and although the revised ocean dumping regulations (S 220.3(d))
specify an essentially rigid end-of-1981 phase-out deadline for
sludge which fails to meet the criteria, a relocation of sludge dumping
to the 10e-site may well increase the pressure to modify these
requirements, and/or undercut EPA's ability (and perhaps desire) to
strictly enforce them. This is so for two reasons, one practical, one
legal: first, if the sludge is moved out of the "backyard" of tt.e
coastal states from New York to Maryland, much of the political and
public pressure and support for a rapid phase-out of ocean dumping
may evaporate; second, and even more critically, a shift to the 106-
site may greatly increase the difficulty of detecting and demonstrat-
ing harm to the marine environment as a result of continued ocean
dumping. This in turn could increase a federal judge's reluctance to
order a recalcitrant sludge dumper to adhere to the terms of its
phase-out schedule. It certainly could increase the inclination of
such dumpers to be recalcitrant and to gamble on the unwillingness
of a court to enforce an EPA phase-out order under conditions of
uncertain environmental consequences. (A shift to more costly alter-
native sites might also deplete the funds otherwise available to
expedite the implementation of land-based alternatives) . A
significant risk of slippage in existing phase-out deadlines is more
than ample justification for rejecting a dumpsite relocation of un-
certain need and of unknown consequences.
Comment; EPA would contend that it intends to adhere firmly to
existing deadlines, regardless of the location of dumping, and that a
federal judge could and would enforce existing administrative require-
ments, without regard to the ability to demonstrate specific ocean
dumping impacts. Perhaps, but perhaps not.
2. The consequences of relocating current sludge dumping
practices to the 106-site are largely, if not totally, unknown.
As little as we know about the marine environment for near-
shore continental shelf areas, and the fate and effects of pollutants
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in it, we know even less for deep ocean areas off the edge of the
continental shelf. For example;
(a) Sewage sludge organic matter may have a totally different
behavior off than on the continental shelf—to the extent such organic
matter finds its way into water below a few hundred feet from the
surface, there is good reason to expect its rate of biodegradation to
be greatly diminished. The possible consequences of such a reduction
in microbial decomposition rates are unknown. Extensive studies by
Or. Holger Jannasch and his associates at Hoods Hole (see. Exhibits
A-l - A-4) have consistently demonstrated that "the in situ microbial
response to enrichment of deep-sea water and sediments with various
organic substrates was between one to three orders of magnitude lower
than in the controls." (Exhibit A-3, p. 642). This led Jannasch, et
al. to conclude (Exhibit A-J_, p. 675) that the use of the deep sea as
a dumping site for organic wastes is "very inefficient1* as a means of
either disposing of or recycling these wastes, as well as being an
approach resulting in the "rather uncontrollable" accumulation of waste
materials or decomposition products on the ocean bottom. Jannasch has
also expressed the view (Exhibit A-2) that "in the deep sea, organic
waste... could accumulate for years and years and then float up un-
decayed" to contaminate seas and beaches. Conversely, as expressed
by Dr. Bumpus of Woods Hole (see. Exhibits B-4 and C-5), "There is
the possibility of creating anaerobic deep sea environments from the
dumping of organic materials," depending "on the rate of introduction
of organic materials and the strength of the advective processes," as
well as on the rates of biodegradation.
(b) Deep sea marine organisms may be far more sensitive
to ocean dumping impacts than their nearer shore counterparts—As
noted by Dr. Howard Sanders of the Woods Hole Oceanographic
Institution, (see. Exhibit C-l, p. 3), the ocean floor below the
thermocline is "a region of remarkable stability" in which
•(tjemperature, salinity, oxygen conditions, and other factors in
contrast to shallower waters are essentially unvarying and have
changed little over many thousands and even millions of years."
Under these "conditions of constancy and predictability over
geologically long periods of time there have evolved in the deep
sea a delicately attuned, highly sensitive assemblage of organisms
with a very narrow range of tolerances," which "can be expected
to be most fragile." "As a consequence, a perturbation or stress
that might have little significance in the variable and less
predictable shallow waters could have severe and perhaps catastrophic
implications in the deep sea." This concern is shared by Dr.
P.H. Wiebe of Woods Hole (Exhibit B-l, pp.1, 5), although he
acknowledges that "we don't [really] know that the deep sea
populations are fragile."
(c) The artificial transport of heavy metals and other
undesirable sludge constituents into the open ocean off the edge
of the shelf through ocean dumping constitutes a new major source
of such constituents in these waters, the consequences of which are
unknown. As pointed out by Dr. Ralph Vaccaro (Exhibit, B-2),
"the heavy metal load transported into marine coastal areas by
rivers and streams is quickly precipitated out of the water column,
becomes bound to the sediments and is effectively excluded from the
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W
oceanic realm," making atmospheric "fall-out" the only major
natural pathway for the depoaition of many heavy metals in the open
ocean. The direct introduction of such metals and other chemicals,
ae well as of microorganisms, into this environment as a result
of ocean dumping could have severe and perhaps catastrophic
consequences.
(d) Sludge particles and associated contaminants could
become entrained in the Gulf Stream (which impinges on the 106-Site)
and be transported to fishing grounds as far away as Newfoundland.
(e) The nature and effects of possible interactions
between sewage sludge and the various toxic chemicals presently
dumped at the 106-Site are essentially unknown.
comment; (a) As far as inhibition of biodegradation is
concerned, whether or not it is relevant to ocean-dumped sewage
sludge will depend on how long it takes sludge organic matter to
settle to the ocean bottom. Based on a sedimentation rate for
particulate organic matter of."from several weeks to more than a
year per 1000 m of depth" (Exhibit A-3, p. 643), it could take
quite some time for sludge to make it to the bottom of the 2,000-
meter (i.e., 6,000 feet) deep 106-Site. By that time, it could
have already been biodegraded. It is really impossible to say for
certain whether enough sludge will penetrate sufficiently deep to
make inhibition of biodegradation likely. Moreover, we can't be
sure that inhibition of biodegradation, even if it occurred, really
is a problem.
(b) with regard to the greater sensitivity of deep
sea organisms, Drs. Vaccaro, Grice, Rowe, and Wiebe of Noods Bole
(Exhibit c-3) have cautioned against "an over commitment to the
Sanders' hypothesis," because "ttlhe book is not yet closed on
this subject." They do recognize, however, that the Sanders'
hypothesis "is consistent with [the] rather static (physical)
regimes... [present] at great oceanic depths."
(c) In relation to atmospheric fall-out and existing
toxic chemical dumping taking place at the 106-Site, the additional
heavy metals which would be introduced into the deep-ocean environ-
ment by the commencement of substantial sludge dumping may not be
very significant (although the metals coming in with the toxic
chemicals and the fall-out are probably largely present in soluble
dilutable form, whereas the metals coming in with sludge would come
in as non-soluble particulates—this could make for different fates
and impacts). Of perhaps greater concern is the introduction of
alien microorganisms into an environment unaccustomed to them.
(The ocean dumping criteria, in S 227.7(c), reflect this concern by
prohibiting the ocean dumping of "wastes containing living organisms"
which would endanger human health or other organisms by extending
the range of pathogens, degrading uninfected areas, or introducing
viable species not indigenous to an area). The potential impacts
of introducing these microorganisms are unknown. (The fact that
relatively small amounts of Camden sludge will have been dumped at
the 106-Site for a relatively short period prior to the initiation
of intensive and extensive sludge dumping by Philadelphia and New
York by no means suggests that adding these new sludge dumpers wouldn't
do substantial incremental damage).
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w
--J
to
(d) and (e) Such effects are conjectural. The large
size of the 106-Site and its great depth should tend to minimize the
occurrence of extensive waste interactions.
3. Relocation of sludge dumping to the 106-Site would
essentially deny the opportunity to monitor the situation and render
it virtually impossible to alter the course of events should
corrective action be necessary.
This concern has several components:
(a) Denial of the opportunity to monitor— This is a
frequently cited concern. For example, at the EPA workshop on
"Evaluation of Ocean Dumping Criteria," convened at Airlie House,
August 31-September 1, 1973, a group chaired by Dr. Edward D.
Goldberg, and including among others, Drs. Dean F. Bumpus, Gilbert
T. Rowe, and David Menzel, concluded that, although off-Shelf
dumpsite locations "would be amenable to mixing of liquids, it is
not possible to predict the effect and fate of solids at great
depths and it would be difficult to monitor their effects" (Exhibit
B-5, p. 2). Dr. llolger Jannasch (Exhibit C-2) has pointed out that
"the feasibility of short-term studies [on deep-sea biodegradationj
is very limited," and that, for this and other reasons, "it will
probably be difficult or impossible 'to show harm'—not because
there will be no harm..., {but because] [s}cicntific evidence for
or against such an effect will be very difficult, to obtain." These
limitations of relatively quick scientific evidence in offshore
marine pollution bear the danger, if scientific proof is over-
emphasized, that ocean dumping becomes a cheap and unrestricted
practice leading to a continued waste of national resources by
short-term economic considerations and taking the pressure off from
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developing procedures for controlled waste recycling." (Id.)
Drs. Vaccaro, Grice, Rowe, and Wiebe (Exhibit C-3) have suggested,
in addition, that "an Increased number of dump sites especially in
the deep ocean is not necessarily a responsible alternative at this
time," because "(a]s additional sites are created surveillance
problems also increase proportionately." (Notei in our case, since
the 106-Site is an existing site, any increased "surveillance*
problems would have to do with the possibly greater difficulty of
conducting surveillance at sites increasingly distant from shore].
See, also Exhibits B-2, B-3, and C-2, for the views of Drs. Vaccaro,
Bumpus, and Jannasch. The greater expense and difficulty of deep-sea
than of nearer-shore monitoring surveys is another factor to consider,
although less insurmountable (see. Exhibit D) than the inherent
difficulty of detecting pollutant fates and effects under deep-sea
conditions. For example, it is obviously a lot easier to coordinate
survey efforts with dumping activities and weather conditions at
near-shore sites than at sites further from shore. Moreover, previous
use of the 106-Site for the dumping of undetonated explosives, may
makp hottcm-sampling at that location not only difficult but potentially
dangerous.
(b) Inability to take corrective action— Vaccaro, et
al. (Exhibit C-3) make the argument that "highly toxic wastes, not
readily attenuated, should be restricted to point sources favoring
deposition within a restricted area of the sea bottom*.., because
[f)or a shallow water column such a procedure facilitates corrective
action should it become necessary to contend with an unforeseen
emergency..., (whereas] [cjonversely, less toxic substances, such as
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M
CO
rich organic concentrates, which ultimately respond to biological
degradation, are more logical candidates for dispersal whereby
the environmental consequences are effectively diminished by maximum
dilution." The heavily contaminated urban sludges being considered
for relocation to the 106-Site must be regarded as toxic substances,
as to which ocean dumping practices should be "containment" rather
than "dispersal" oriented. (Even if they were deemed "rich organic
concentrates," however, and as such appropriate candidates for
dispersal, it makes no sense to disperse them off the Shelf where
biodegradation may be inhibited than to do so in shallower, nearer-
shore waters]. The EPA adjudicatory hearing on Philadelphia sewage
sludge likewise concluded that containment rather than dispersal
should be the objective for ocean dumping of dirty sludges like
Philadelphia's. See, also Exhibits B-l and B-2 for the similar
views of Drs. Hiebe, et al., and Dr. Vaccaro. Dr. Bumpus (Exhibit
B-4) makes the further salient point that "Lack of data prevents
adequate control." We simply have far less data regarding deep-sea
phenomena than we do concerning events taking place closer to shore.
(c) Limited relevance of the ocean dumping criteria to
deep-sea dumping— Dr. Bumpus (Exhibit B-4) has pointed out that
"There is tremendous difficulty in completing bioassays with deep
sea material." Although the ocean dumping criteria have rejected
the suggestion of Vaccaro, et al. (Exhibit C-3),and others,that
"insofar as possible, the bioassay organisms should be chosen from
organisms typical of the proposed dump sites," they do rely heavily
-23-
for waste screening on the use of bioassay tests, and they do mandate
the use of "appropriate sensitive" marine organisms for testing
purposes (see, e.g., S 227.27). Thus, given the differing sensitivities
and physiologies (see. Exhibit C-6) of deep-sea than of near shore
organisms, given the dependence of the criteria on bioassays,
and given the inability to perform such bioassays on deep-sea organisms,
the current ocean dumping criteria must be regarded as far less
useful for characterizing wastes proposed for off-Shelf than for on-
Shelf ocean-dumping. This only heightens the concern that we lack
the ability to adequately predict and evaluate the consequences of
off-Shelf ocean dumping of sewage sludge.
(d) Interferences from other wastes already at the 106-
Site—Vaccaro, et al. (Exhibit C-3) have endorsed the notion that
classes of wastes should be assigned to the most logical ocean
disposal sites, and that different waste types should be kept
separate "to minimize interference effects associated with complex
waste mixtures." Combination of sewage sludge with the many diverse
toxic chemicals already being dumped at the 106-Site can only
serve to complicate monitoring problems.
Comments; (a) If we were sure that dumping off-the-shelf would
not delay complete phase-out and we were sure that off-Shelf dumping
caused less harm than present dumping practices, it probably
wouldn't matter much if a move off the Shelf impeded monitoring—
provided, however, that sufficient surveillance were conducted to
minimize the occurrence of short-dumping. In fact, such a move
might actually increase surveillance by Coast Guard shipridera,
since the Coast Guard assigns greater priority to surveillance of
dumping at the 106-Site than to dumping at either of the current
sludge dumpsltes.
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(b) It is a lot more difficult to take corrective
measures for wastes in the ocean—even when contained in nearshore
waters—than for wastes on land. The incremental difficulty of
taking such measures at the 106-Site than at the 11-mile site, or
particularly at the 40-mile site, may have little practical significance.
(c) True, but relevant only if we're not sure that
a move to the 106-Site won't delay phase-out and won't cause any
more harm than present practices.
(d) The potential for interaction and interference
is no greater at the 106-Site than at the present 11-mile site, given
the density and diversity of dumping and other polluting activities
in the New York Bight. The concern may be more valid at the
Philadelphia dumpsite, particularly now that DuPont is no longer
dumping acid wastes nearby.
4. Relocation of sludge dumping to the 106-Site would
substantially increase the likelihood of short-dumping and attendant
undesirable consequences.
The practice of waste dumping short of assigned ocean disposal
sites is well-known if not widespread. One or two such incidents
are detected each year in connection with the Philadelphia dumpsite,
and short-dumping probably occurs in connection with the 11-mile
dumpsite as well. Some short-dumping is willful and represents an
effort by waste haulers to save time and money. In other instances
it is regarded as necessary to preserve ship and crew, where un-
expected adverse weather conditions arise at sea.
-25-
If sludge dumping is relocated to the 106-mile site, the
frequency of short dumping will inevitably increase substantially.
Even with adequate surveillance by ship-riders and absent willful
misconduct, it is clear that unexpected bad weather and the need
for 'emergency" short dumping will be a bigger problem the more
the haul distance increases. The consequences of this, in addition
to the probable need for closure of additional shellfish grounds,
will be the periodic introduction of a variety of contaminants into
a number of hitherto relatively uncontarainated areas.
Commenti The incremental haul distance for Philadelphia is
not nearly as great as for New York, and intervening shellfish
resources are far less substantial. Also, the frequency of
"emergency" short-dumps and the impacts of such dumping are uncertain,
where areas other than shellfish grounds are impacted. EPA should
develop estimates of the number and frequency of new barge trips
to the 106-site which would result from relocated sludge dumping.
These estimates should be compared with similar estimates for exist-
ing barging activities in the 106-site, to provide a better feel
for the expected degree of increase in existing barge traffic
levels. Assuming that reliable estimates can be made for the frequency
of short dumping by existing barge traffic (given its recent
origins, barge traffic associated with dumping by DuPont-Edgemoor
should probably be factored out of these considerations), it should
be possible (at least for sludge dumping originating in Hew York
Harbor) to project the likely frequency of new short dumping due to
sludge dump relocation.
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W
Ul
Considerations Relevant to the 60-Mile Site
The major consideration relevant to possible relocation to the
60-mile site relates to the fact that no ocean dumping has ever
taken place at this site, so that new dumping there would cause
the degradation of a previously undegraded area. In the absence of
a compelling reason to abandon use of current sludge dumpaites, the
factors which led NOAA and EPA (based on the DEIS on sludge dumping)
to decide last year against moving sludge dumping from its present
location in the New York Bight to the 60-mile site, would appear to
remain valid. Indeed, even if compelling reasons were to arise to
justify relocation of present sludge dumping practices, it is
far from clear that the 60-mile alternate should be given preference,
even for New York and New Jersey sludge dumping, over useof the 106-
site (it would be a matter of whether it was worse to risk unknown
consequences at the 106-site than to degrade a previously undegraded
60-mile site). Obviously, useof the 60-mile site would make little
sense for Philadelphia sewage sludge under any circumstances since
that site is probably not much closer to Philadelphia than is the
60-mile site, and the route a barge would have to take to get there
would probably mean crossing (and potentially impacting through short
dumping) more square miles of important shellfish grounds than
any other alternative. Use of the 60-mile site for both New York
and Philadelphia might also result in more intentional short dumping
than any other alternative, since it is unlikely that the Coast
Guard would increase its use of ship-riders for barge transport of
sludge to sites other than the 106-site.
Conclusions and Recommendations
On the basis of the factors analyzed In the foregoing discussion,
we conclude that neither of the existing sludge dumps should be
relocated at the present tine. This conclusion is based principally
on the lack of demonstrable need for and desirability of such a
move, the uncertain but potentially serious adverse consequences of
relocation to either the 106-site or the 60-mile site, and the
potential negative impact of relocation on the enforceability of
existing phase-out deadlines. Should the need for a move arise,
relocation of Philadelphia sludge to the 106-site, and of New York
and New Jersey sludge to either the 60-mile or the 106-mile site,
may then become appropriate. The likelihood of such a need arising
in the foreseeable future seems greater in the Philadelphia
situation than in the New York Bight area.
Accordingly, the National Wildlife Federation respectfully
makes the following recommendations:
1. EPA should relocate neither sludge dump at the present
time.
2. EPA should strictly enforce existing phase-out schedules
and deadlines.
3. EPA should immediately initiate the preparation of an
Environmental Impact Statement which fully addresses the circumstances
under which relocation to both the 60-mile site and the 106-mile site
would be justified and the environmental pros and cons of such a
course of action. Some of this has been done with respect to possible
relocation of New York Bight sludge dumping to the 60-mile site in
the DEIS issued last February by EPA Region II. EPA could elect to
expand this EIS to cover Philadelphia and the 106-site, but this
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should not be done simply through the issuance of an expanded Final
EIS. Instead, a supplemental Draft EIS should first be issued with
additional opportunity for public review and comment.
4. Monitoring (particularly at the Philadelphia dumpsite)
and survey work (particularly at the 106~mile site) should continue,
preferably at an intensified rate.
5. Efforts to reduce the hazard potential of ocean-dumped
sludge should be given a high priority. These efforts should
include particularly further attempts to reduce the microbial content
of Philadelphia sewage sludge, and efforts for all sludges to reduce
their levels of chemical contaminants (e.g., by pretreatment).
6. Future ocean dumping permits for sewage sludge should
specify that EPA reserves the option of requiring relocation to the
60-mile or 106-mile site on 30 days' notice, and if possible should
also specify the circumstances (e.g., detection of high fecal
coliform or virus levels in shellfish in the vicinity of the dumpeite)
which would trigger a relocation order.
7. Future EPA permit renewal hearings should expressly
address the possible need for future relocation and should entertain
any and all evidence or arguments on this subject the parties wish
to call to EPA's attention. The record of the present hearings
should also be made part of such permit proceedings. This would
obviate the need to hold further hearings when and if it became
necessary to proceed quickly with relocation.
-29-
8. EPA, the Corps of Engineers, and the concerned states
and localities should act expeditiously to reduce or eliminate other
sources of contaminant inputs to the New York Bight, including upgrad-
ing of sewage treatment works, and control of dredge spoil ocean
dumping.
The opportunity to present these views is appreciated.
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Footnotes
LIST OF EXHIBITS
M
I/ Capt. James L. Verber, Chief, Northeast Technical Services
Unit, Shellfish Sanitation Branch, Bureau of Foods, Food and Drug
Administration, Davisville, Rhode Island— Testimony at EPA adjudicatory
hearing on Philadelphia Sewage Sludge, Transcript, Vol. IV, pp. 60,
68, 71 (May 22, 197S).
2/ Capt. James L. Verber— Personal communication to Kenneth
S. Karolet, May 18, 1977; Prepared Statement Before EPA adjudicatory
hearing (Hay 22, 1975); Statement Before Subcomm. on Air and Hater
Pollution, Senate Comm. on Public Works, 92d Cong., 2d Sess., Ser.
H10, pp. 2101-10 (March 26, 1971).
V Capt. James L. Verber— Personal communication to Kenneth
S. Kamlet, May 18, 1977.
4_/ Id.
5/ National Science Foundation/International Decade of Ocean
Exploration, Anoxia on the Middle Atlantic Shelf during the summer
of 1976 (Nov. 1976) (Report of a workshop held in Washington, D.C.
on October IS and 16, 1976).
6/ New Jersey Department of Environmental Protection, Report
to Commissioner Bardin for Submission to the New Jersey Senate
Committee on Energy, Agriculture and the Environment on Ocean
Pollution Causes and Remedies in the Atlantic Coastal Area (prepared
by the Division of Water Resources Oct. 7, 1976,- revised Oct. 18,
1976; transmitted to interested parties, Jan. 26, 1977).
I/ NOAA, Long Island Beach Pollution: June 1976 (Feb. 1977)
(MESA Special Report).
§/ Harris, W.H., Spatial and temporal variation in sedimentary
grain-size fades and sediment heavy metal ratios in the New York
Bight apex. Am. Soc. Limnol. Oceanogr., Spec. Symp. 2: 102-23
(1976) (Proceedings of the Symposium on Middle Atlantic Continental
Shelf and the New York Bight, American Museum of Natural History,
November 3-5, 1975).
Exhibit
A-l Jannasch, H.H., et al., Microblal degradation of
organic matter in the deep sea. Science 171 (3972)i
672-75 (Feb. 19, 1971).
A-2 New York Times, Deep-sea dumping raises questions.
April 8, 1973, p. 69.
A-3 Jannasch, H.W. and C.O. Wlraen, Deep-sea micro-
organisms: in situ response to nutrient enrichment,
Science 180: 641-43 (May 11, 1973).
A-4 Wirsen, C.O. and H.W. Jannasch, Decomposition of
solid organic materials in the deep sea. Environ. Sci.
I Tech. 10(9): 880-86 (Sept. 1976).
B-l Excerpt from: Proceedings of Ocean Disposal Conference,
held at the Hoods Hole Oceanographic Institution, February
23, 1971, under the co-sponsorship of the New England
Division, Corps of Engineers and the Woods Hole Oceanographic
Institution.
B-2 Letter from Ralph F. Vaccaro (WHOI Associate
Scientist) to Dennis Hanson (National Wildlife Federation),
Sept. 28, 1972.
B-3 Letter from Dean F. Dumpus (WHOI Senior Scientist)
to Barbara Reid (NRDC), April 26, 1973.
B-4 Letter from Dean F. Bumpus (WROI Senior Scientist)
to T.A. Hastier (Chief, EPA Ocean Disposal Program),
August 7, 1973.
B-5 Conclusions of an EPA-sponsored Workshop at Airlie
Bouse on Evaluation of Ocean Dumping Criteria, Aug. 31-
Sept. 1, 1973 (workshop committee chaired by Dr. Edward
D. Goldberg, Scripps Institution of Oceanography).
C-l Draft position of National wildlife Federation on
deep-sea ocean dumping, January 2, 1974 (circulated to
WHOI scientists for comment).
C-2 Letter from Bolger W. Jannasch (WHOI) to Kenneth S.
Kamlet (NWP), Jan. 7, 1974 (commenting on the draft NWF
position).
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List of Exhibits, Cont'd.
Exhibit Subject
C-3 Letter from Ralph F. Vaccaro (HBOI) to Kenneth S.
Kamlet (NWF), Jan. 16, 1974 (communicating comments of
Drs. Vaccaro, Grice, Rove, and Hiebe on draft NWF position).
C-4 Letter from Dean F. Bumpus (HBOI) to Kenneth S.
Kamlet (HWP) , Jan. 15, 1974 (commenting on draft NWF
position) .
C-S Letter from D«an F. Bumpus (WHOI) to Kenneth S.
Kamlet (NWF), Jan. 22, 1974 (commenting further on draft
NW» position) .
C-6 Yayanos, A. A., Book Review: A.G. MacDonald,
Physiological Aspects of Deep Sea Biology, Science 192:
363-64 (Apr. 23, 1976) .
D Heirtzler, J.R. and J.F. Grassle, Deep-sea research
by manned submersibles , Science 194: 294-99 (Oct. IS, 1976).
•-J
oo
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RESPONSES TO LETTERS
The following comments are keyed to the preceding letters which have been
numbered and coded for easy reference. The first digit refers to the letter
number and the second digit refers to the. specific paragraph/comment within
the letter:
1.1 EPA is fully committed to ensure environmentally sound methods of
waste management. As a result of the Agency's efforts to end ocean
dumping, most dumpers have been phased out of ocean disposal since
1973. All of the remaining" dumpers are required to investigate and
develop land-based disposal methods.
5.1 There is presently no plan to use the 106-Mile Site for ocean
incineration. A potential incineration site adjacent to the
106-Mile Site is now under consideration and an EIS is being
prepared specifically for that site.
6.1 Most of these comments request a level of detail not pertinent to
this EIS. This appendix supplies information auxiliary to the main
body of the EIS. It is not meant to represent a complete literature
review of all subjects mentioned within it.
6.2 The text in Appendix A was changed to include this information.
6.3 This subject received additional attention in the Final EIS.
7.1 The EIS text has been modified to clarify the uncertainties of
the biological effects of waste dumping at the site.
7.2 The proposed action treated in this EIS was to designate an
already existing ocean disposal site (of prescribed site boundaries)
for continued use. Changing the size of the site was not considered
E-79
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in this document, since a site of such large dimensions is deemed
necessary to ensure that wastes are quickly dispersed after dumping.
Usage of different quadrants of the site precludes mixing of wastes.
7.3 The section discussing the 106-Mile Site in Chapter 3 begins with
a reference to Appendix A and, in fact, states that the material
presented in Chapter 3 is excerpted from Appendix A. Continental
Slope waters are never described in the EIS as biologically
"depauperate". The EIS does say that Continental Slope waters may
exhibit reduced productivity in comparison to Continental Shelf
waters.
7.4 It is true that larvae of economically important species have
been observed at the site; however, the site is not unique as to the
occurrence of the said larval forms. The larvae are found all along
the mid-Atlantic Continental Shelf and Slope. Dumping operations at
the site may kill or otherwise affect larvae in the waste plume, but
a noticeable effect on the overall population of any particular
species is not expected. It is important to note that larval
attrition is naturally high, due to such predation, normal die-off,
or changing physical environment.
7.5 Rare and endangered species are treated in additional detail
within Appendix A.
7.6 Additional information on the red crab fishery has been provided
in the final EIS.
7.7 The primary data base for the EIS is the culmination of more than
three years investigation, primarily by NOAA. There are certainly
some deficiencies in the data base, primarily because of the
difficulties in sampling sufficiently to detect adverse effects at
the site. EPA encourages NOAA to continue investigations at the
site, but does not feel that action should be delayed until NOAA can
complete additional studies.
E-80
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8.1 Unless otherwise noted, all comments were treated as text
changes. The EIS does not debate the relative merits of ocean
disposal in comparison with other methods of waste management.
EPA's ocean dumping permit program determines the need for ocean
disposal on an individual basis for each permittee. There are
presently no viable alternatives to ocean disposal for the four
permittees dumping wastes at the 106-Mile Site. Thus the main issue
in the EIS is to choose the best ocean location at which to dump the
wastes, and not whether to designate an ocean disposal site for
these wastes.
8.2 No relationship between past munitions and radioactive waste
disposal is anticipated in future industrial waste disposal.
Industrial wastes are not expected to reach the bottom at the site
where munitions and barrels containing radioactive waste were
dumped.
8.3 EPA requires permittees to monitor impacts occurring within the
period of initial mixing. The agency relies upon NOAA's monitoring
and research programs to provide information on effects occurring
both during and after the period of initial mixing. NOAA's
comments, which although valid, suggest studies that are primarily
research studies, and are therefore beyond the limit of reasonable
requirements of the permittees. It is hoped that NOAA will be able
to do the suggested work.
8.4 The procedure for obtaining "...2 percent additional nitrogen to
the site..." involved a worst-case analysis based on several
factors:
A mixing zone comprising one-fourth of the area of the site
to a depth of 15 m.
Background concentrations obtained from NOAA field studies
reported by (NOAA, 1977).
An input based on projected 1981 total volumes of sludge and
weighted average concentrations of nutrients reported for
ocean dumped sludge by Mueller et al. (1976).
E-81
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A 22-day residence time for dumped materials based on the
length of time a parcel of water crosses the site diagonal
at the lowest speed where a warm core eddy has been observed
to transverse the site.
The worst-case analysis was recalculated in the final EIS using
an average residence time of 14 days. The residence time was
adjusted after a determination that presence of an anticyclonic eddy
does not represent a worst-case condition because of the potential
for vertical mixing throughout the eddy. Instead an average current
speed of 10 cm/sec was used. Recalculations based on this factor
yield a 1% increase of nitrate and a 14% increase of phosphate due
to sludge dumping.
8.5 See Response 7-7. See comment 8.2 for munitions and radioactive
waste discussion. .
8.6 Whether or not ocean disposal is less expensive than land
disposal, it still means expense to the dumper. This cost
represents an irretrievable commitment of economic resource. It is
immaterial that the amount of money spent to dump waste in the ocean
is less than the amount that would be required to use it for
landfill; in either condition an economic resource has been
committed.
8.7 The range of pH values reported in Table 5-2 comes from analyses
of barge loads. It is not meant to represent solely the pH of the
acidic portion of the waste, but rather the acidity of the bulk
mixture. It is true that Edge Moor waste often contains extremely
concentrated hydrochloric acid; however, this acid is combined with
other materials and the resultant mixture is dilute by comparison.
8.8 The added sludge will increase the nutrient levels in seawater at
the site by a negligible amount. However, the overall effect of
this small nutrient enrichment on the biological productivity of the
area is unclear, because of the great diversity of water conditions
E-82
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at the site - high-nutrient coastal waters mixing with low-nutrient
oceanic waters. There are two reasons to discourage nutrient
enrichment in any area: (1) conditions may favor a particular
planktonic organism and lead to a drastic increase in its abundance,
to the detriment of other normally competitive organisms, and (2) a
severe bloom can change the water chemistry of an area to such a
degree that large organisms are adversely affected. Because of the
high dilution of waste materials discharged at the 106-Mile Site,
the threat of severe plankton blooms is not a reality for that area.
9.1 A regular monitoring program is one of the requirements of site
designation and usage. NOAA plans to continue its research studies
of dumping effects.
10.1 There are no existing or proposed units of the National Park
System located at or near the proposed waste disposal site.
14.1 The State of Maryland has not informed EPA of any conflicts
between designating the 106-Mile Site for continued waste disposal
and the state's present plans for economic development.
15.1 The proposed use of the 106-Mile Site for sewage sludge disposal
is not intended to be limited to sludge from the New York/New Jersey
metropolitan area. The EIS emphasizes sludge because of the
potential need to relocate dumping from the 12-Mile Site to another
site. If relocation of Philadelphia's sludge dumping from the
present site is deemed necessary, the 106-Mile Site will be one
alternative considered.
16.1 A complete dicussion of land-based alternatives is included in
Appendix D of this EIS. Further discussion is not necessary because
the subject of this EIS is to discuss the relative merits of ocean
dumping at one location versus another, rather than comparing land
and ocean disposal. EPA thanks the State of New Jersey for
expressing its views on land disposal alternatives.
E-83
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16.2 Pretreatment standards are presently being promulgated.
16.3 Organic materials, e.g., organohalogens, are permitted to be
dumped only as trace contaminants, in accordance with Part 227,
Subpart B of the Ocean Dumping Regulations. The Regulations further
state:
These constituents will be considered to be
present as trace contaminants only when they are
present in materials otherwise acceptable for
ocean dumping in such forms and amounts in
liquid, suspended particulate, and solid phases
that the dumping of the materials will not cause
significant undesirable effects, including the
possibility of danger associated with their
bioaccumulation in marine organisms [Section
227.6(c)].
^" Materials which exhibit a tendency to bioaccumulate in bioassays
.with approporiate sensitive marine, organisms are prohibited. In the
absence of appropriate bioassay procedures, the Regulations state
that organohalogens may be permitted for dumping (except under
emergency conditions) only when "the total concentration of
organohalogen constituents in the waste as transported for dumping
is less than the concentration of such constituents known to be
toxic to marine organisms", calculating that these constituents are
all biologically available, i.e., are not rendered inert in any
manner [Section 227.6(e)]. If an applicant can demonstrate that,
upon dumping, the wastes are rapidly rendered non-toxic to marine
life, or rendered non-bioaccumulative in the marine environment by
chemical or biological degradation in the sea, a permit may be
granted for their disposal [Section 227.6(f)].
16.4 During the ocean dumping permit application process, prospective
permittees must provide EPA with a complete analysis of all the
chemical constituents in the waste.
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17.1 Discussion of land-based sewage sludge disposal alternatives is
not relevant to this EIS. The chapter on land-based alternatives
from the EIS on sewage sludge disposal in the New York Bight appears
as Appendix D in this EIS. It has been included to provide
supplemental information. Sewage sludge is presently permitted to
be dumped in the ocean because there are no land-based alternatives
available at this time.
17.2 Industrial pretreatment standards are presently being
promulgated.
17.3 EPA must comply with PL 95-153 which states that ocean dumping of
harmful sewage sludge will cease by December 31, 1981. The sewage
sludge presently dumped in the ocean off the U.S. East Coast cannot
comply with EPA's environmental impact criteria; thus ocean dumping
of this waste must cease according to law.
22.1 These studies are already part of the research and routine
monitoring programs conducted at the site.
22.2 No accumulations of waste constituents are likely to result from
dumping; the EIS clearly establishes this point and provides
supporting information. Therefore, the great expense associated
with collecting benthic organisms and analyzing their tissues is not
warranted. EPA feels that it is better to put effort into
monitoring the elements of the environment where potential effects
are more likely to occur.
22.3 As a result of the practice of assigning dumpers to different
quadrants of the 106-Mile Site, a rotation system to another
off-Shelf site is not necessary to allow recovery of the dumpsite.
NOAA has established that the observable short-term effects are
transient; long-term effects are unlikely, considering the volume of
the mixing zone and the flushing rates of water at the site.
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22.4 The Coast Guard has been assigned the responsibility for
conducting routine surveillance of ocean dumping under MPRSA. The
present Coast Guard program goal is to observe 75% of all industrial
waste dumps and 10% of all municipal waste dumps. Any extra
surveillance required by EPA will be conducted at the permittee's
expense.
23.1 EPA is strongly committed to enforce existing compliance
schedules for the development of land-based alternatives by December
31, 1981.
24.1 The Ocean Dumping Regulations state provisions for determining
which materials will be permitted to be ocean dumped, based on the
nature of the materials and upon demonstration of adequate need to
ocean dump. Only in the absence of land-based waste disposal
alternatives can materials be considered for ocean disposal. After
ocean disposal permits have been granted, permittees must continue
to seek land-based alternatives.
25.1 The period for public review of a draft EIS - 45 days - is
prescribed by the Council on Environmental Quality. In the case of
this EIS, EPA accepted all comments received until the production of
the final EIS, a period of almost 5 months.
28.1 This item was corrected in the final EIS.
29.1 ^ The plan proposed on behalf of the Bergen County Utilities
Authority presents an alternative means for disposing of sewage
'j\\ -^
' < V'j sludge at the 106-Mile Site. Such a proposal is not evaluated as
.v part of the site designation process - the subject of the EIS - but
'1 would be properly evaluated in the permit procedure.
29.2 The EIS provides information to the public on the present
projected costs of using the 106-Mile Site for waste disposal.
Studies on cost-effectiveness of the different methods of using the
site are the responsibility of each individual permittee.
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29.3 Pretreatment regulations apply nationwide according to law. The
regulations apply to all cases unless a waiver is granted (highly
unlikely for the New York/New Jersey metropolitan area).
*
31.1 Concentrations of waste contaminants at the 106-Mile Site do not
appear to remain high after initial mixing. Among other data,
bioaccumulation in fish is partially dependent on sufficiently long
exposure to high concentrations of materials which fish can
accumulate. Fish at the site tend to be transient, thus it is
unlikely that they will be exposed long enough to permit detectable
uptake.
31.2 This subject is addressed in the EIS in Chapters 2, 3, and 4.
31.3 Procedures are not presently available for the fish named in this
list. For the present, appropriate sensitive (though not
indigenous) species are used for bioassays. As additional bioassay
techniques are developed in the future, other organisms will become
candidates for study.
2
32.1 The area of the site, approximately 1,700 km , is stated in
Chapter 2, within the section entitled "Continued Use of the
106-Mile Site."^
32.2 The legal framework of the proposed action is thoroughly
discussed in Chapter 1. The reader is referred to the EPA Ocean
Dumping Regulations and Criteria for the complete legal details of
the site designation. :\ • • .• ;
32.3 The EIS conforms with the CEQ requirements for preparation of
EIS's (40 CFR V) and the guidelines on site designation set forth in
the Ocean Dumping Regulations (40 CFR 228). Appendices have been
added to the format prescribed by CEQ in order to provide more
information than normally required, but which EPA deems a pertinent
enhancement.
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32.4 Sections of the EIS have been modified to aid understanding by
the general public. EPA feels that the document provides all the
information necessary for decision-making or for gaining a full
knowledge of the issues involved in designating the 106-Mile Site.
32.5 The debate is long standing on whether containment or dispersal
,,is the preferred method of managing wastes at an ocean disposal
site. At several locations in the ocean surrounding the U.S., toxic
wastes have been deposited in barrels which are now on the sea
floor. However, in the case of industrial wastes of relatively low
toxicity, dispersing mechanisms have been employed to disperse and
dilute the material widely and quickly. This is the procedure that
has been followed in the past at the 106-Mile Site.
Observations from field studies of wastes dumped at the site have
justified the concept of waste dispersal being preferred to
containment for aqueous wastes dumped at this location. The rate of
dumping for each waste can be gauged to the chemical and physical
character of material, to ensure that sufficient dilution occurs to
keep waste concentrations below the limiting permissible
concentration after the period of initial mixing. Thus there is no
reason to change the waste management practices in future use of the
106-Mile Site, given the same kinds of wastes as those presently
dumped.
32.6 The information contained in Appendix B is supplemental to the
main body of the EIS, but considered to be an integral part of the
document. The Appendix is referenced at many places in the body of
the EIS: The summary, Chapter 2 (within the sections entitled
"Basis for Selection of the Proposed Site: and "Recommended Use of
the 106-Mile Site"). Chapter 3 (under "Waste Disposal at the Site:)
and throughout Chapter 4. Much of the information contained in
Appendix B appears in the main body, e.g., the Summary, Chapter 2
(within the Section entitled "Continued Use of the 106-Mile Site"),
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Chapter 4, and Chapter 5. Besides containing relevant data on
dumpers presently using the site, the Appendix presents a
compilation of data on historical dumping at the site. This
information, although not entirely germane to future use of the
site, is, however, important as the historical record of the site
use.
32.7 Total quantities dumped are listed in Appendix B. Certain
subjects, e.g., the assimilative capacity of the site, are still
unknown. However, with respect to waste interactions, EPA has
developed site management policies which lessen chances of
significant impacts as a result of dumping. Examples of these
policies include confining simultaneous use to different quadrants
of the site, regulating barge speeds and discharge rates to ensure
adequate waste dilution, imposing a requirement for monitoring on
all dumpers, and including in dumping permits special conditions for
controlling dumping which are adequate for each waste. At the same
time, NOAA is continuing its research on effects of ocean dumping by
studying several aspects of the environment of the site. Due to
this level of effort, and concern for using the 106-Mile Site in the
safest way, the likelihood of long-term impacts occurring unnoticed
is slight.
32.8 The EIS strives to present information in a logical fashion, to
make it understandable to government decision-makers and to the
general public. Ocean dumping is a complex technical subject, thus
all aspects can not be understood by every reader of the EIS. All
statements have been carefully documented throughout the text.
Areas of incomplete or inconclusive information have been discussed;
EPA based its judgment to support site designation on the available
information, mindful of subjects where information is yet lacking.
32.9 See response to 32.11.
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32.10 Potential waste-concentrating mechanisms operating at the
106-Mile Site have been studied in NOAA's dumping research program.
THe EIS discusses these studies primarily within Chapter 4 and
Appendix A. The items addressed by NWF are answered individually or
collectively as appropriate.
NWF offered many examples of potential waste-concentrating
mechanisms believed to receive inadequate attention in the draft
EIS. Most of the points raised are research topics best addressed
as part of NOAA's ocean dumping research program. The mechanisms of
concentrating trace contaminants are complex, and depend upon
concentrations of the contaminants in seawater, the length of time
elevated concentrations are maintained, chemical state of the
contaminants, (i.e., whether bound in complexes or in ionic form),
and the ability of organisms to concentrate particular trace
contaminants in tissues. The wastes dumped at the 106-Mile Site are
quickly dispersed, and not present after mixing in concentrations
exceeding limiting permissible concentrations determined by
bioassays with appropriate sensitive marine organisms. Floe from
mixing of Du Font-Edge Moor and Grasselli wastes with seawater may
persist beyond a day; however the significance of this observation
is unknown. The existence of several unknowns related to use of the
site is acknowledged, but EPA feels that restricting the use of the
site until research studies are conducted is not justified, based
upon the information generated by the studies which have already
been conducted on effects of waste disposal at the site.
Specific responses follow.
a) The total organic component of the industrial wastes
discharged at the 106-Mile Site is minimal: 0.5% to 1%
from Du Pont-Grasselli and 1% to 2% from American
Cyanamid. Of the 34 million gallons of organic materials
estimated to be disposed of in 1978, less than 50% of the
waste was water insoluble and a much smaller amount could
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be considered lipophilic. Some of the latter may be
converted to solubility by surfactants contained in the
waste. Generally, however, the lipophilic organics - oil
and greases - can be considered negligible since NOAA
studies have failed report visible sheens.
b) Laboratory studies have been conducted on the floes which
form when Du Font-Edge Moor and Grasselli wastes mix with
seawater, to determine if waste constituents adsorb to
the particle surfaces. This subject is discussed within
Chapter 4 in the section entitled "Water and Sediment
Quality."
c) For discussion of concentrations of toxic waste
constituents with particulates, see Chapter 4, "Effects
on Water and Sediment Quality."
Association of pathogenic micro-organisms with
particulate material has been discussed in Chapter 5
(Survival of Pathogens). Particulate associated
pathogens suspended in the water column are vulnerable to
predators, toxins, effects of solar radiation and other
factors which contribute to inactivation and reduction of
these organisms.
d) It is true that bluefish and yellowfin tuna have been
reported to be attracted to acid wastes disposal at the
New York Bight Acid Site (Westman, 1958). However,
Westman acknowledged it is possible that increased
turbidity in the water after a dump disguises fishing
gear, thus making certain fish more easily caught.
Therefore ocean dumping may not, in fact, attract fish.
No fish attraction has been reported from studies at the
106-Mile Site, or at any other ocean disposal site.
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e,j) The significance of waste participates being associated
with pycnoclines is unknown, a point that is acknowledged
in Chapter 4 of the EIS. Many organisms are found in
association with thermal and density gradients, and there
is potential for ingestion of particles where organisms
and particles are found together.
No assumption is made in the EIS, as NWF asserts, that
"trapping of constituents at the thermocline will avoid
concentration of toxic wastes by preventing significant
deposition on the ocean bottom." What the EIS does say
in Chapter 4, is that density gradients in the water
column prohibit the downward movement of waste particles,
so that accumulation on the seafloor is unlikely.
f,i) Concentration of elements from water into tissues of
organisms is dependent on a number of factors: the
amounts of input elements in comparison to values
normally present in the water, the length of time that
elevated concentrations are retained, the chemical state
of the elements (whether present as free ions or in
complexes) and the proclivity of organisms in a waste
plume to concentrate elements. Transfer of trace
contaminants by vertically or horizontally migrating
organisms is feasible, but difficult to test.
Investigations of similar questions are part of NOAA's
continuing research on dumping effects at the site.
g) The EIS discusses in Chapters 2 and 4 the potential for
106-Mile Site wastes impacting fisheries. Fishing near
the 106-Mile Site is variable and dependent on the
occurrence of water masses or eddies which affect fish
abundance and distribution. Shelf fisheries are
sufficiently far from the site, so that wastes will be
adequately diluted before reaching the location of any
significant fishing.
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h) The potential for concentration and enhancement of
persistence and toxicity of organic constituents as a
result of diminished biodegradation in the deep ocean is
discussed in Chapter 5, specifically as regards sewage
sludge. The organic component of most of the industrial
waste dumped at the site is minimal. The only dumper
with significant organic waste is American Cyanamid;
however, the organics in that waste are principally
nonpersistent organophosphate pesticides.
k) Gulf stream eddies occupy the site about 20% of the time.
Their roles as potential waste-concentrating mechanisms
have never been studied. Eddies move through the site at
approximately 3 cm/sec, whereas the normal mean
current-speed is approximately 10 cm/sec. Therefore
horizontal flushing rates at the site may be less than
normal where an eddy is present. However, eddies can
change the vertical characteristics of the water column,
disrupting physical features which normally inhibit
downward movement of wastes (e.g., thermoclines and
pycnoclines), providing more water than normal in the
vertical dimension for mixing. This subject is addressed
in Chapter 4 of the final EIS.
1) Short dumping is possible at any ocean disposal site, no
matter how close to shore the site may be. However, it
is true that the possibility of short dumping increases
with distance from shore. Most important mid-Atlantic
fisheries are in the coastal waters over the Continental
Shelf. The alternative sites for the 106-Mile Site are
located in the Shelf area where commercial and sport
fisheries are prevalent; thus, the potential adverse
effect of short dumping at the alternative sites is
great, and may be greater than the effect of short
dumping in transit to the 106-Mile Site.
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32.11 The EIS bases its evaluation of the proposed 106-Mile Site
designation on five of the six major factors cited by Asst.
Administrator Jorling: environmental acceptability (Chapters 2 and
4), ability to monitor impact (Chapters 2 and 4), surveillance of
dumping activities (Chapter 2), economic burden (Chapter 2), and
logistics (Chapter 2). The sixth factor - the effect of using such
a site on the ability of dumpers to meet the December 31, 1981
deadline for the termination of harmful sewage sludge dumping - was
not addressed for two reasons: (1) the deadline does not apply to
industrial waste disposal, and (2) relative to sewage sludge
disposal this factor was already addressed in the EIS on sewage
sludge disposal in the New York Bight, EPA, 1978. Sewage sludge
dumping would only be permitted at the 106-Mile Site to relieve
adverse environmental conditions at the 12-Mile Site. Therefore
economics would not be an issue.
EPA's decision to propose the designation of the 106-Mile Site
for continued use, documented by this EIS, does not conflict with
Asst. Administrator Jorling1s decision, wherein he stated (in
reference to the Toms River Hearing):
I am impressed by the concern expressed by
many reputable scientists about the potential
for adverse environmental impacts from sludge
dumping at the 106-Mile Site. Nevertheless, I
would not regard these concerns as preventing
use of the 106-Mile Site if a sound predictive
judgement could be made concerning the impact of
dumping at the site and an effective monitoring
program could be established (Jorling, 1978).
The basis of the ultimate decision to discourage relocation of
New York/New Jersey sludge disposal was the conclusion of the Toms
River Hearing Officer (Breidenbach, 1977), who indicated that there
was a "potential for irreversible, long-range, and therefore
unreasonable degradation of the marine environment" which was
coupled with the unfeasibility "of designing an effective monitoring
program to evaluate the impacts of sludge dumping at the site."
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The decision to discourage relocation of sludge dumping from the
Philadelphia Sewage Sludge Site to the 106-Mile Site was based on
the speculative nature of the state of knowledge available at that
time, and on the prohibitive cost of mounting an effective
monitoring program (estimated by NOAA to be about $2.5 million per
year) compared to the resources available between 1978 and January
1, 1981, when Philadelphia will cease ocean dumping.
During the evaluation of the 106-Mile Site designation, the Toms
River Hearing testimony, Report of the Toms River Hearing officer,
and Asst. Administrator Jorling's decision were considered. At the
time the EIS was prepared (two years after the Tom's River Hearing,
and one year after Jorling's decision was published), additional
information was available with which to evaluate the impacts of
waste disposal at the 106-Mile Site. After careful consideration of
this additional information and the previously available
information, EPA decided that continued use of the 106-Mile Site was
feasible and clearly preferable to all available alternatives.
32.12 At the time of the Toms River Hearing little information existed
on which to base sound predictions of the fate and effects of sewage
sludge dumped at the 106-Mile Site. Thus, much of the testimony
presented at the hearing was speculative. Since the hearing,
additional information has become available on the fate of materials
dumped at the site, as new procedures for tracking these materials
have been tested. The most promising technique appears to be the
acoustic monitoring method, which can track some sizes of
particulates in waste. This technique has been used successfully
for sewage sludge (Orr, 1977b) and industrial waste (Orr, 1977a).
The most significant observation in these studies was retention of
waste material in all cases in waters above the permanent
thermocline/pycnocline (100-150 m) and, in come cases, in waters
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above the seasonal thermocline/pycnocline (10 to 50 m). Thus,
horizontal dispersion may be a greater factor than vertical
dispersion, and wastes are not expected to sink to the bottom of the
site in detectable amounts.
Residence of wastes in surface and near-surface waters is
relevant to some of the major concerns expressed at the Toms River
Hearing, especially the effects of the material on benthic
organisms, and the potential for inadequate biodegratdation of the
waste organic fraction. However, if wastes do not reach the bottom
in significant amounts, adverse effects on the benthos should be
negligible. Retention of wastes in the upper water column increases
the potential for dispersion through mixing and biodegradation.
It is important to note that EPA is not proposing to relocate
sludge disposal from any existing disposal site to the 106-Mile
Site. The Agency has already determined that the advantages to be
gained by this action do not sufficiently outweigh the risks.
However, in considering the 106-Mile Site for limited sewage sludge
disposal under the conditions described in the draft EIS, the Agency
retains an important alternative location for dumping this material
off the Continental Shelf. The only other alternative is to
relocate sludge disposal to another shallow water site on the
Continental Shelf.
The documents appended as Exhibits 1 and 2 were carefully
examined during preparation of the draft EIS. Since Exhibit 1
(Report of the Hearing Officer) consists of a summary of the
comments raised in Exhibit 2 (NWF testimony), the latter reference
is addressed in this response. Many points presented in these
references were found to relate solely to relocation of sewage
sludge disposal. The EIS did not evaluate the 106-Mile Site in
relation to other sewage sludge sites, but instead evaluated the
site on the basis of its individual merits as an ocean disposal
site; therefore these points were not applicable.
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The remaining points raised in the NWF statement were treated in
the EIS:
• The directive of MPRSA to designate ocean disposal sites off
the Continental Shelf whenever feasible (NWF, p 3; EIS,
Chapter 1).
• The lower biological productivity in Continental Slope
waters in comparison with Shelf Waters. (NWF, p. 4; EIS,
Chapter 4 and Appendix A.)
• The potential for interactions between different wastes
dumped at the site (NWF, p. 18; EIS, Chapter 4, Chapter 5,
Response 32-16).
• The potential for entrainment of wastes in the Gulf Stream
(NWF, p. 18; EIS, Chapter 4).
• The feasibility of monitoring the site (NWF, p. 20; EIS,
Chapter 2, and Chapter 4).
• The likelihood of short-dumping upon use of the site (NWF,
p. 24; EIS, Chapter 2, Chapter 4, Response 32-10 [e]).
32.13 Appendix B provides information on all wastes presently dumped at
the 106-Mile Site, and limited information on historical dumping at
the site. The information was generated primarily from EPA permit
files. Individual barge analyses were tabulated to provide
quarterly estimates of waste constituents loading. The chemical
characteristics of the wastes, physical, toxicological, and
dispersive characteristics are all discussed. This material is
referenced at several places in the EIS (e.g., Chapters 2, 3, and 4)
and additional information is included in the text of the DEIS.
Information is excerpted from the Appendix and used in sections
within Chapter 4 (Environmental Consequences).
The fate and effects of dumping the present wastes are treated
extensively in Chapter 4.
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Management of dumping operations at an ocean disposal site is the
responsibility of the EPA management authority. As such,
determination of separation distances for dumpers is not a subject
addressed in an EIS on site designation, but is properly addressed
as part of the ocean disposal permit and site management processes.
32.14 The properties of all wastes presently expected to be dumped at
the site are thoroughly discussed in Chapter 4 and Appendix B,
particularly with respect to toxic effects.
Persistence under worst-case conditions is addressed in Chapter
4, wherein the total waste loading at the site is evaluated in
relation to a minimally-dispersive environment.
Susceptibility of wastes to bioaccumulation is assessed for
individual wastes as part of the ocean dumping permit process. The
Ocean Dumping Regulations state that wastes containing constituents
which may be bioaccumulated are prohibited except as trace
contaminants.
"These constituents will be considered to be
present as trace contaminants only when they are
present in materials otherwise acceptable for
ocean dumping in such forms and amounts in
liquid, suspended particulate, and solid phases
that the dumping of the material will not cause
significant undesirable effects, including the
possibility of danger associated with their
bioaccumulation in marine organisms" [Section
227.6 (b)].
32.15 The meeting at which NOAA scientists estimated the minimum
assimilative capacity of the 106-Mile Site, was held at the same
time the draft EIS was issued. Thus, this estimate was not
available to the EIS preparers. The estimate put forth at the
meeting has yet to be verified.
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32.16 Waste disposal operations at the 106-Mile Site are managed in a
manner to avoid the possibility of waste interactions. Based on
present knowledge, the large surface area provides ample space for
simultaneous large dumps, with slight potential for mixing of
different waste plumes.
The potential for 106-Mile Site wastes interacting with an
incineration area to the south, is presently being evaluated in the
EIS under preparation for the incineration site; thus it is not
discussed in the present EIS. However, interactions between wastes
at the two sites would be expected to be minimal, because of the
extreme dilution of the wastes, especially the residues produced by
incineration.
32.17 The comment on Du Pont-Grasselli bioassay data resulted from a
mistake in the text which has been corrected in the final EIS.
It is true that oceanic organisms may be more sensitive to ocean
dumped toxicants than estuarine or nearshore organisms. The final
EIS discusses this subject in Chapter 4. However, bioassay methods
for oceanic organisms are not available at this time. When methods
are developed, the bioassay requirement will be modified
accordingly. Meanwhile, NOAA is supplying information on the
sensitivity of the organisms indigenous to the site as part of the
ocean disposal research program.
32.18 The text in the final EIS was modified in response to this
comment.
32.19 The depth of the permanent thermocline is variable in the
literature, hence the seeming inconsistency in the EIS. For
discussion purposes, the final EIS adopts a depth ranging from 100
to 150 m for the permanent thermocline.
The final EIS was changed in response to the comment on
inconsistency in distances.
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32.20 The draft EIS deals primarily with the use of the site for
industrial waste disposal. The EIS treats potential sewage sludge
disposal as a special case because there are presently no plans to
dump sludge at the site; instead, the site would be considered as an
alternative location for sludge disposal should adequate need arise.
For industrial waste and sewage sludge disposal the evaluation is
based on environmental acceptability, feasibility of monitoring,
surveillance, economics, and logistics.
32.21 If the site were not designated for continued use, disposal would
terminate with the end of the interim designation on December 31,
*7 1981. This alternative is rejected because of the need to
'» ocean-dump some waste materials, and the suitability of the 106-Mile
Site for such purposes.
During the permit application process, Du Pont-Grasselli
adequately demonstrated a need to ocean-dump, based on the lack of
available land-based alternatives. The waste complies with EPA's
environmental impact criteria, thus the Agency will permit it to be
dumped in the ocean until land-based alternatives are developed. As
a condition of the Du Pont permit, the company must continue to seek
land-based alternatives.
'32.22 The EIS demonstrates that surveillance and monitoring are
feasible at the 106-Mile Site. The associated costs are
acknowledged to be high, primarily due to the distance of the site
from shore. However, the environmental effects of continued use of
the site are estimated to be slight in comparison to alternative
nearshore sites (see Chapter 4).
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32.23
a) The size of the 106-Mile Site is an advantage in
comparison to the alternative sites. The ample area
2
(approximately 500 nmi , roughly 3% of the total area of
the New York Bight), permits rapid waste dilution without
impinging on fisheries or other uses of the ocean and
accommodates long barge tracks, thus further enabling
dilution of the dumped wastes within the site along track
lengths. A similar site would not be possible in coastal
waters because its use would conflict with other uses of
the waters. The excerpt from the Ocean Dumping
Regulations applies to sites where materials which
contain large amounts of solids are dumped. At such
sites, the objective is to localize the wastes, thus the
area of the site is limited. However, such size limits
do not apply at sites receiving aqueous wastes of low
toxicity which are intended to be diluted quickly.
b) The "emergency conditions" quoted from the EIS text and
the cover letter refer to the adverse environmental
conditions in the New York Bight, which would require
emergency relocation of the sludge dumping operations to
another site.
c) This typographical error was corrected.
d) The text has been changed in response to this comment.
e) Only wastes expected to be dumped at the site have been
evaluated in the EIS. The environmental effects of new
wastes would be assessed on a case-by-case basis during
the permit application process.
f) See Response 32.11.
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g) The "undocumented assertions" referenced to on these
pages cannot be identified.
h) The heavy metal content of NL Industries' waste is not
pertinent to this EIS.
i) The text has been changed in response to this comment.
j) The text has been changed in response to this comment.
k) The information described in this comment was unavailable
while the EIS was under preparation. However, the EIS
has already made a strong case for not relocating
106-Mile Site wastes to the New York Bight.
"^ 1) (Awaiting information from EPA Region II.)
''^ m) No response.
n) The information was provided to inform the public. Based
upon further evaluation, information on aliphatic
hydrocarbons was deleted in the final EIS because oil
pollution is not relevant to discussions of waste dumping
at the 106-Mile Site.
32.24 Every EIS on an ocean disposal site discusses unique issues,
because each disposal site is different. While one EIS may act as a
model for another in format or approach, EPA's ultimate decision on
whether to designate a site for ocean dumping is made on a
case-by-case basis.
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HEARING RESPONSES
The following comments were excerpted from the statements presented at the
hearing held on August 31, 1979, at Mercer County Community College, New
Jersey.
COMMENT: The EIS conclusion that sludge dumping is feasible at the 106-Mile
Site should not be interpreted as sanctioning continued indefinite ocean
disposal of sewage sludge (NJ Public Advocate).
Response: Congress has mandated that ocean dumping of harmful sewage sludge
will cease by December 31, 1981 (PL 95-153). Use of the 106-Mile Site
for sludge disposal would be limited by this date, as would use of any
other ocean site for disposal of sewage sludge. EPA is exercising a firm
commitment to enforce compliance with this law.
COMMENT: A major flaw in the EIS is that it fails to examine the
environmental and legal necessity of using the 106-Mile Site for sewage
sludge disposal as opposed to the existing site (NJ Public Advocate).
Response: Comparison of use of the 106-Mile Site for sludge disposal with use
of the existing site is not warranted in this EIS. The 106-Mile Site
would only be used if use of the 12-Mile Site were terminated. EPA has
already established that relocating disposal operations from the 12-Mile
Site to any other site would not cause significant improvement in
conditions at the existing site because of the existence of more
significant sources of contamination, e.g., contaminants entering the
Bight via the Hudson River outflow -and land runoff. (Breidenbach, 1977;
Jorling, 1978)
COMMENT: EPA should not evaluate use of the site for sludge dumping on a
case-by-case basis (NJ Public Advocate).
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Response: Use of any site for waste disposal is evaluated on a case-by-case
basis in accordance with the Ocean Dumping Regulations. Thus,
applications to dump sludge at the site would be treated the same as
applications to dump any other waste and would be evaluated individually.
COMMENT: The EIS states that sludge disposal at the 106-Mile Site is
feasible. Thus, EPA has no discretion under the MFRSA to allow continued
use of the 12-Mile Site (NJ Public Advocate).
Response: It was established at the Toms River Hearing that there is
presently no advantage to be gained by moving sludge dumping from the
existing 12-Mile Site to any other location. By evaluating and
designating the 106-Mile Site for potential sewage sludge disposal, EPA
is providing one more alternative location for disposing of sludge.
Designation of the site for sludge disposal does not imply that EPA must
use the site; rather, it is available for use if adequate need arises.
COMMENT: The EIS should discuss the economic impact of sludge dumping on
renewable living resources at the 12-Mile Site. (American Littoral
Society)
Response: Discussion of the economic impact of dumping sludge at the 12-Mile
Site is not relevant to an EIS addressing designation of another site.
Irrespective of the economic impact of sludge dumping at the existing
site, the 106-Mile Site will only be used for sludge dumping if a public
health hazard, or a significant decrease in water quality at the 12-Mile
Site or any other ocean disposal site, requires relocation.
COMMENT: The EIS should discuss less expensive alternative methods of
transporting wastes to the 106-Mile Site. (American Littoral Society)
Response: The subject of this EIS is designating the 106-Mile Site for
continued use. Alternative methods of waste transport to the site are
not evaluated in an EIS on site designation, but are best evaluated by
the prospective dumpers who must bear the costs of the dumping operation.
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COMMENT: The EIS should discuss less expensive alternative methods o*.
surveillance at the 106-Mile Site. (American Littoral Society)
Response: The U.S. Coast Guard is responsible under MPRSA for surveillance of
ocean disposal sites. In exercising this mandate, the Coast Guard
evaluates alternative methods of surveillance and uses the most
appropriate method - whether patrol boat, helicopter, or shiprider - for
each disposal site.
COMMENT: The EIS should provide more financial information. (American
Littoral Society)
Response: This comment is too general to permit a specific response. The EIS
provides all available economic information which is relevant to the
proposed action.
COMMENT: The EIS implies that sewage sludge dumping was the~cause of the 1976
fish kill in the New York Bight. (American Littoral Society)
ReJ^onse: The EIS states that there was no relationship between barged sludge
disposal and the occurrence of hypoxic conditions leading to the fish
kill.
COMMENT: The EIS seems to state that the effects of sludge dumping on the
environment of the 106-Mile Site are well known. (American Littoral
Society)
Response: The EIS acknowledges that several aspects of waste disposal at the
106-Mile Site are unknown (see Chapter 4).
COMMENT; The EIS implies that sludge dumping at the 12-Mile Site would
significantly increase productivity and that one advantage of moving
sludge dumping to the 106-Mile Site is that it would decrease the
likelihood of plankton blooms occurring in nearshore waters. (American
Littoral Society)
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Response: The EIS does not address effects of sewage sludge dumping -at the
12-Mile Site. The nutrients added to the Bight from sewage sludge
dumping are a small fraction of the total nutrient loading. Moving
sludge dumping from the Bight to the 106-Mile Site would have no
noticeable effect on occurrence of plankton blooms in coastal waters.
COMMENT; The criteria for an EPA case-by-case determination are ambiguous.
It is not clear what severity of need must be shown to direct one dumper,
and not another, to the 106-Mile Site. (NJ Public Advocate)
Response: The Ocean Dumping Regulations (Part 227) outline the criteria for
evaluating applications for ocean dumping permits. The MPRSA requires
•i that EPA consider the environmental impact of proposed dumping, the need
for ocean dumping, non-ocean dumping alternatives, and the effect of the
proposed dumping on esthetic, recreational, and economic values, as well
as on other uses of the ocean. Since individual circumstances vary, EPA
cannot grant permits on other than a case-by-case basis.
COMMENT: It is unclear whether the EPA-designated 60-Mile Site on the
Continental Shelf remains a viable alternative to use of the 106-Mile
Site. Use of such an alternative would not be in compliance with the
MPRSA (NJ Public Advocate).
Response: The designated Alternative Sewage Sludge Disposal Site (60-Mile
Site) is still considered by EPA to be a viable alternative to the
12-Mile Site. Designation of the 106-Mile Site for sewage sludge
disposal does not preclude the possibility of using the 60-Mile Site.
The MPRSA does not require that ocean disposal sites be located beyond
the Continental Shelf; instead the Act merely encourages use of such
sites "whenever feasible."
COMMENT: EPA's conditions for stopping disposal at the 12-Mile Site ignore
the fact that the marine environment at, and surrounding the 12-Mile Site
is being severely degraded. In addition, EPA's plan to take action only
when a public health emergency exists presents an unacceptable risk to
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the health and welfare of New Jersey residents, and to the State's
tourist and fishery industries which support our economy. The MPRSA
imposes a duty upon the EPA to protect against such happenings, not
merely to act once damage has occurred. Pursuant to that, EPA must move
the present disposal site before such catastrophic events occur. (NJ
Public Advocate)
Response: EPA based the decision to reject relocation of sludge dumping from
the present site to another location on several factors, which are
summarized in the published decision (Jorling, 1978). Central to the
decision, was EPA's belief that the 12-Mile Site is sufficiently impacted
by other sources of pollution that only slight improvement in water
quality would occur if sludge dumping were terminated at the site
(Breidenbach, 1977). Thus, there would be no environmental benefit to be
achieved by relocating sludge dumping from this site.
EPA acknowledges the potential for a public health hazard developing as
volumes of sludge dumped at the 12-Mile Site increase between now and
1981. Accordingly, the Agency has taken steps to monitor the situation
closely, and thereby safeguard public health. The Agency has implemented
a two-part program for assessing ambient water quality conditions during
peak summer months, the period of least dispersion. The assessment
includes sampling and evaluation of microbiological parameters and
dissolved oxygen depletion rates, both of which can be related to
existing and legally enforceable Federal and State water quality
standards. Designation of the 60-Mile Site for sludge disposal, and
proposed designation of the 106-Mile Site, are additional precautions
against any possible public health effects that might result from
overloading the existing disposal site. If monitoring indicates that
significant health hazards exist, with use of the 12-Mile Site, EPA will
move the dumping operation to another location.
COMMENT: EPA is not rigorously enforcing permit schedules for development of
environmentally sound, land-based disposal methods (NJ Public Advocate).
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Response: EPA is rigorously enforcing permit schedules for implementation of
land-based alternatives. The Agency has initiated legal action in
several cases to enforce compliance. For example, the City of New York
has been referred to the Justice Department, and the City of Philadelphia
is under a court order to cease ocean dumping by December 1980.
COMMENT: Pretreatment programs must be implemented by EPA on an expedited
basis, in order to ensure that sewage sludges from the highly
industrialized New York/New Jersey Metropolitan area do not pose a threat
to the environment and public health when_jiisposed of on land. (NJ
Public Advocate) £- / r ,^f./? (/,. / /
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Response: Pretreatment standards are presently being promulgated.
COMMENT: EPA must designate the 106-Mile Site for interim ocean disposal, and
further direct its use by all permittees as soon as possible, and in no
event later than 1981 (NJ Public Advocate).
Response: When the 106-Mile Site is designated for continued use, permits
will be granted after a case-by-case evaluation of individual applicants,
based on need and potential impact. In accordance with PL 95-153,
disposal of harmful sewage sludge at any ocean disposal site will not be
permitted beyond 1981.
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