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in which environmental degradation and risks to human health 
will be minimized. 
The suggestion has been made by some participants in the 
debate over the use of the ocean for sludge that sewerage 
agencies will always take the "easy" and "cheapest" alternative. 
That really does not do us justice. We must live with the 
people we serve and we are as dedicated to achieving the best 
possible mix of alternative strategies for handling waste as 
any other responsibility. Just. as the ocean should not be 
used for disposing of sludge simply because it may be the most 
economical method, so it should not be barred just because it 
may be the most economical method. 
SEWAGE SLUDGE -- THE OPTIONS 
Our members are in the unenviable position of having to 
find a place for something that, in general, nobody wants. As 
a result of Congress' 1972 mandate to achieve secondary treat-— 
ment of waste water, the volume of sludge produced annually in 
this country continues to grow at a rate far outstripping pop- 
ulation growth. In 1977, the National Academy of Sciences/ 
National Research Council, in its report entitled, "“Multi- 
medium Management of Municipal Sludge", criticized the Congress' 
medium-by-medium approach to waste management, and singled out 
the then-existing policy of the U.S. Environmental Protection 
Agency (EPA) against any ocean disposal of sludge after 1981, 
as a particularly irrational waste management decision. In 
1981, the National Advisory Committee on Oceans and Atmosphere 
(NACOA), criticized our nation's pattern of environmental 
regulation as one which simply "chases" man's wastes to the 
medium of least regulation, rather than the medium which would 
pose the least human health risk and environmental degradation. 
The NACOA report, "The Role of the Ocean in a Waste Management 
Strategy," also criticized EPA's absolute ban on ocean disposal 
of sewage sludge after 1981, and in fact specifically recommended 
that ocean disposal of sewage sludge, both by barge (dumping) 
and by pipeline, be allowed to continue so long as no unreason- 
able degradation, or human health risk, occurred. 
There is no single method for disposing of or utilizing 
sewage sludge. Just as every region of the country has its 
unique hydrological, meteorological, and oceanographic character- 
istics, every sewage sludge has a unique composition of natural 
organic material, nutrients, metals, synthetic organics, and 
petroleum hydrocarbons. Sewage sludges tend to concentrate 
certain constituents that can be detrimental to man and the 
environment, when present in large enough quantities. This is 
because these constituents, primarily heavy metals and synthe- 
tic organic compounds, are associated with the particulate 
fraction of wastewater. Approximately one-half of theSe materials, 
present in a sewage plant's influent, finds its way into the 
sludge. i: is the presence of these contaminants, when they are 
found in high concentrations, that gives rise to one of the most 
