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Mr. D’Amours. Thank you, Mr. Kamlet. 
I noticed that you also were here this morning throughout the 
Koch testimony. I would like to give you the same opportunity I 
gave to Dr. Knauss to respond to Mayor Koch’s contention that it 
makes better sense to continue incrementally polluting an already 
polluted area than it does to move to a pristine area, the area of 
course in question being the Bight Apex. What are your comments 
on that? 
Mr. KAM LET. I would like to say first that the 106-mile site can 
certainly not be regarded as a pristine area. It receives industrial 
waste, toxic industrial waste, which is being dumped right now and 
has been for a number of years. It is true there has not been long- 
sustained dumping of sewage sludge at the 106 site. There was a 
brief period during which the city of Camden dumped sludge at 
that site. Certainly one could not regard it as a pristine area. The 
65-mile site could better meet that description inasmuch as there is 
not any dumping currently going on at that site. 
It is a significant concern. I have mixed feelings about the desir- 
ability of shifting sludge dumping from the 12-mile site to the 65- 
mile area because I think that the ocean is the wrong place to put 
most of that sewage sludge or a large part of it, whether it is at the 
12-mile site or any other site. 
With respect to the New York City situation, a middle-ground 
approach that makes more sense than simply moving it all to 65 
miles or 106 miles would entail isolating those sludges that come 
from the most industrialized sewage treatment systems in the city, 
and there are at least three of them by the Commissioner’s ac- 
knowledgement this morning, and requiring those to be placed on 
land at landfill sites that I have identified in my testimony which 
would be available as an interim measure for 5 to 7 years, and 
then ultimately handling these sludges through an incineration 
technique or some other longer-term means of dealing with them. 
The balance of that New York City sludge, the less industrial- 
ized, less contaminated material, I perhaps would just as soon 
prefer to see continue to be dumped at the 12-mile site in that al- 
ready degraded area than have the entire sludge moved further 
out. The economics of that may not be all that unfavorable. 
Mr. D’Amours. That is very interesting. I made such a sugges- 
tion to Mayor Koch earlier today. His response was, although as I 
recall it was not shared by the gentleman who accompanied him, 
that he thought the material generated by all 12 sites was uniform. 
Would you disagree with that, then? 
Mr. KAMLET. I would agree with the New York City Environmen- 
tal Protection Commissioner who indicated that there are at least 
three treatment systems that do generate distinctly more heavily 
contaminated sludges. The point the mayor was making was that, 
even for the less contaminated systems, there are occasions in 
which the sludges become heavily contaminated. 
Mr. D’Amours. What would you do with the more highly con- 
taminated sludge? 
Mr. KAMLET. There are four landfill sites that would provide 
about 1,200 acres of available capacity to accommodate the sludge 
which could receive sludge on a one-shot only basis and accommo- 
date it for a 5-to-7-year period. These were sites identified by a con- 
