206 
revision will upset the present system, which 
requires a balancing of disposal options to 
determine which constitute an "unreasonable" 
risk to human health and the environment. 
These points and our other specific concerns are 
discussed in more detail in Technical Attachment A. 
Impact of Draft Amendments on New York City 
The City, along with other municipalities, will be 
Significantly impacted by these amendments. 
We provide secondary treatment to 1.3 billion gallons 
of sewage and, as a result, generate approximately 260 
dry tons of sewage sludge each day. 
This sludge is contaminated with heavy metals such 
as lead, copper and mercury, PCB's and other toxic organic 
materials, and therefore, must be disposed of with the 
greatest care. A comprehensive pretreatment program can 
improve the quality of this material to some degree, but 
will by no means eliminate the pollutants which are the cause 
for our concern. These contaminants stem largely from non- 
industrial sources, such as domestic sewage and storm water 
run-off, which flows into our treatment plants through a 
combined sewer system, and therefore will not be removed 
by pretreatment. 
