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during the question period, there are at least three identifiable 
treatment plants that are significantly more heavily industrialized 
and generate distinctly more heavily contaminated sewage sludges 
than the rest. 
Back in 1978, consultants to New York City proposed a series of 
short- and long-term alternatives to ocean dumping that would 
have permitted the city to comply with the 1981 phaseout require- 
ment. The plan, developed by Camp, Dresser, and McKee—CDM— 
contemplated onetime application of composted sewage sludge at 16 
landfill and parkland sites. The plan was never implemented, in 
large part because of public opposition to placing sludge on park- 
land. 
It is important to recognize, however, that several of the city’s 
treatment plants and treatment systems are much more heavily in- 
dustrialized than the rest and generate far more heavily contami- 
nated sludges, so that it seems entirely conceivable that under the 
draft amendments we are talking about the city’s dirtier sludges 
could be deemed to have a prudent and feasible alternative in the 
form of composting and application to the four landfill sites identi- 
fied in the CDM report without having to resort to any of the more 
controversial parkland sites. These four landfills by themselves 
would supply at least 1,084 available acres or more than 42 percent 
of the total acreage earmarked in the original 16 sites identified by 
Camp, Dresser, and McKee. 
I might note at this point, in response to the concerns expressed 
by Mr. Biaggi this morning about possible use of the Pelham Bay 
landfill for this purpose, what we are talking about here is the one- 
shot application of composted sewage sludge mixed with soil to the 
landfill as a means of stabilizing it and to assist in the prevention 
of leachate escape from a landfill. This landfill, the Freshkills land- 
fill, and a variety of other landfills are significant pollution sources 
themselves which generate a great deal of leachate. The applica- 
tion of sludge in a controlled manner of the sort that is being dis- 
cussed would actually improve the environmental stability and 
quality of these areas. In fact, I am informed that representatives 
of the New York City Department of Sanitation within the past 
few days have been exploring the possibility of utilizing sewage 
sludge as a capping material on the Freshkills landfill in New 
York City. 
The second major issue I would like to address is the designation 
of ocean dumpsites. The ocean dumping law authorizes the EPA 
Administrator to designate recommended sites for dumping, but 
only after consideration of environmental evaluation criteria under 
the act. The London Dumping Convention allows dumping permits 
to be issued “only after prior studies of the characteristics of the 
dumping site.’ Determining a site’s suitability for dumping and its 
compatibility with particular waste proposed to be deposited there 
is no more than a matter of simple prudence and common sense. 
Yet, it has been honored, thus far, far more in the breach than in 
the observance. 
In 1977, EPA blanketly designated as interim-approved some 140 
unstudied ocean dumpsites around the country, giving itself 3 years 
to complete the site study process. Three years later, with only a 
small handful of sites studied, EPA blanketly extended the interim 
