Zl 
volved, only 15 percent is subject to the contaminants; 85 percent is 
not. That is the figure you gave me. 
Mr. D’Amours. You are very quick to accept figures that favor 
your position, which I understand. 
Mayor Kocu. Well, I am a lawyer. 
Mr. D’Amours. And may I suggest a very good one. 
But let me say this. Am I not correct in understanding that the 
sludge is produced at 12 different plants in New York and that the 
quality of the sludge produced at those 12 different plants varies? 
Mayor Kocu. It is uniform. That is to say that each of the sites 
during the course of the year will have contaminated sludge ex- 
ceeding the levels that you referenced. 
Do you want to add to that? 
Mr. McGouau. Yes. There are 3 plants of the 12 which do have 
sludges that, when they are dewatered and concentrated for com- 
posting and land application, consistently exceed U.S. Department 
of Agriculture limits for heavy metals, such as cadmium. However, 
when these sludges are left in a liquid state, and with proper dilu- 
tion, they will not have an adverse biological effect on marine or- 
ganisms if the sludge is disposed of at sea. Regarding land applica- 
tion, the sludges produced at the other plants, and it depends what 
the Department of Agriculture standards are, again—the standard 
deviation for the constituent metals, such as mercury, cadmium, 
and so forth, are so great that, as the mayor said, on any given day 
you may produce a sludge that exceeds those standards. Yes, it is 
true that 3 out of the 12 consistently exceed the U.S. Department 
of Agriculture heavy metals standards for composted sludge. The 
others are not consistent in exceeding those levels, but on any 
given day they may produce a sludge, because of what happens to 
enter the sewer system, that does exceed those standards for com- 
post. 
Mr. D’Amours. Maybe there is some way that we can distinguish 
between sources and sludges that exceed EPA standards and those 
that do not, and treat their disposal differently; is that not correct? 
Mr. McGouau. You could do that. 
Mr. D’Amours. You are saying that it is correct? 
Mr. McGoucH. You could perhaps separate the sludges with 
greater toxicity or metal content, particularly heavy metal content 
if it was based on some sort of an average, as opposed to particular 
days and times. However, what you would then propose is to take, I 
would suspect, the sludge with the heavier-metal content to an- 
other site. What you have done is collect bad material and put it in 
one place. As an environmentalist, I am concerned that although 
we have now narrowed the gap of what we have to deal with, it 
makes it more difficult to deal with. This is particularly true of 
land application of that material which is more concentrated. 
Mayor Kocu. May I just add three sentences to this? 
The Federal EPA examined the 106-mile site that you have made 
reference to, Mr. Chairman, and this is what they said: 
Environmental information is lacking for determining the fate of dredged materi- 
al dumped in the deep ocean and determining biological effects of dumping dredged 
materials. 
