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the issue at hand—sewage sludge is an additional, significant, and, 
perhaps most important, growing source of contaminants and of 
oxygen depression. 
Testimony attesting to these facts was submitted by the Sierra 
Club to the subcommittees on June 4 of last year. I understand 
that the printed record of the 1981 hearing that contains our testi- 
mony will soon be in print, so we will not repeat it or submit it 
here. 
A particularly poignant example of the great impact of sludge is 
that of PCB’s. Nearly one-fourth of the PCB’s entering the bight 
come from sewage sludge dumping. No better example exists to 
refute those who argue that sludge does not contribute significant- 
ly to the bight. I believe the fact that sludge contributes 50 percent 
of the mercury to the bight has been mentioned. The most recent 
source I noticed on this was NOAA’s testimony to this committee 
last year stating these figures of 25 and 50 percent. 
Elimination of the toxin’s in sewage sludge will not, of itself, 
make ocean disposal of sludge acceptable since sludge will continue 
to pose the potential for depressing bight oxygen and adding micro- 
bial pollution to the bight. Thus, a comparison with land-based al- 
ternatives after industrial pretreatment does not lead us to con- 
clude that ocean disposal will become a safe, reliable disposal 
method once pretreatment is in effect. 
It is critical to understand that sewage sludge will be a growing 
problem and an increasingly important contributor to bight pollu- 
tion in the years ahead if ocean disposal is not curtailed. In 1978, 
5.386 million wet tons of sewage sludge were dumped into New 
York’s Bight. The figure rose to approximately 7 million tons in 
1980 and is rising still further. 
As more sewage treatment plants that employ full secondary 
treatment are completed, the volume of sewage sludge generated 
will continue to increase. According to NOAA, by the year 2000 
sewage treatment plants in the region will generate 52,000 tons of 
sewage sludge per day. If past trends continue, over 13 million wet 
tons of sewage sludge will be dumped in the bight by the year 2000. 
Unfortunately, the bill draft does not unequivocably ban all 
dumping of sewage sludge into all ocean waters. It is unconscion- 
able that we are putting any sludge into an environment where it 
is harmful in many cases and when we do not know its effects in 
others. There are no appropriate ocean sites for sludge, not the 
Apex, not the 106-mile site, not a 60-mile location. As reported in 
the EPA’s Environmental Impact Statement on the Ocean Dump- 
ing of Sewage Sludge in the New York Bight, the hearing officer of 
the Toms River hearing in 1977 recounted the following reasons 
why sludge dumping at the chemical wastes site would be environ- 
mentally unacceptable: 
The preponderance of informed scientific opinion urges extreme caution in dump- 
ing wastes in the deep ocean, particularly wastes containing solid materials, because 
of the many unknowns about this part of the environment. There is a strong feeling 
among marine scientists that it would be possible to start long-range trends which 
would be undetectable until it was too late to take corrective measures. 
Specific concerns with the dumping of sewage sludge in the deep ocean are the 
possible persistence of pathogens for long periods of time, the accumulation of biode- 
gradable materials which could ultimately float up undecayed to contaminate seas 
