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fecal coliform to the Bight. 



There has been a great deal of interest in the pretreatment 

 program as a possible solution to the contamination of sewage 

 sludge. We appreciate the frustration of those who wish that 

 our sludge could be a resource rather than a problem. The City 

 is fully committed to implementing the legal requirements of the 

 Federal pretreatment program. We are on schedule to have an 

 approvable local program in place by July 1, 1983, deadline contained 

 in the Environmental Protection Agency's regulations. However, the 

 pretreatment program can not totally eliminate the pollutants which 

 are concentrated in treatment plant sludges. Much of the contaminants 

 come from non-industrial sources, such as storm water run-off which 

 flows into the treatment plant by way of combined storm and sanitary 

 sewer systems. And obviously the pretreatment program can not 

 address the many pathways other than treatment plants by which 

 pollutants find their way into the Bight area. However, we are 

 looking forward to some reduction in the heavy metals content of 

 our sludges in the near future. 



When Congress enacted the 1977 Amendments to the Ocean 

 Dumping Act, EPA directed its efforts to land-based alternatives. 

 So did New York City. Like other municipalities, we proceeded to 

 develop an interim land-based system to convert sludge to compost. 

 Design of the system was completed in 1980 and bids for construction 

 were solicited. The system was designed for a seven-year useful 

 life, costing $335 million. However, money aside, among our 

 scientific and m.anagement community the fear grew that while 



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