170 



dustrial pretreatment can significantly reduce the cadmium con- 

 tent of the sludges in the New York metropolitan area. 



So, yes, there is I think great potential regardless of the ultimate 

 disposal option utilized for greatly reducing environmental risk, 

 and enhancing benefits through aggressive and maximum pretreat- 

 ment efforts. 



Mr. Carper. Is that industrial pretreatment onerously expen- 

 sive? 



Mr. Kamlet. I wouldn't think so. You have to recognize that in- 

 dustries that do not currently discharge into municipal systems are 

 required to directly treat their materials before they discharge 

 them into navigable waterways. So in large part the ability to dis- 

 charge into municipal treatment plants has represented a subsidy 

 for many years over the costs of treatment of the direct discharg- 

 ers. 



So particularly if you take that subsidy into account and even if 

 you don't, it seems to me the technology is there and the costs are 

 not prohibitive by any means. 



Mr. Carper. How is it that Philadelphia and a number of other 

 cities are actually selling their compost? Is their sludge cleaner? 

 Isn't Philadelphia's sewer system tj^iical of the type of system used 

 perhaps in New York City? What specifically is the relevant differ- 

 ence which enables Philadelphia to find reasonable uses for its 

 sludge whereas New York City cannot? 



Mr. Kamlet. The most relevant difference is that EPA Region 3 

 in whose jurisdiction Philadelphia falls, started out and continued 

 to be much more aggressive than Region 2 in holding Philadel- 

 phia's feet to the fire. There seems to have been a greater Federal 

 will there. I think that was the most significant contributing 

 factor. 



But in terms of cadmium contamination and quality of the 

 sludge, I think you are right, Philadelphia sewage sludge was 

 pretty badly contaminated with cadmium and other contaminants, 

 perhaps not as badly contaminated as a few of the dozen separate 

 sewage treatment plants that New York City has but certainly 

 more badly contaminated than the majority of New York's plants. 



Yet through aggressive pretreatment they were able to signifi- 

 cantly reduce the cadmium levels so that Philadelphia sludge is 

 currently applied beneficially to reclaim stripmined areas in Penn- 

 sylvania, a soil conditioner fertilizer agent known as Phil-Organic 

 is marketed very successfully currently; farmers in the surround- 

 ing area come from miles around to cart away truckloads of dewa- 

 tered Philadelphia sludge and there is a very promising pilot 

 project underway that shows a lot of potential for converting 

 sewage sludge from Philadelphia into a paving material that can 

 be used by the streets department of Philadelphia in connection 

 with some city paving projects. 



So, yes, I think it is clear that there are other options available. 

 The vast majority of the municipalities have resorted to them. 

 Ninety-six percent of the sludge generated is dealt with by means 

 other than ocean disposal. That surely suggests that there are 

 better things to do with the sludge than put it in the ocean. 



Mr. Carper. Thank you very much for the answers to those ques- 

 tions. 



