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composting would stabilize and partially sterilize the sludge 

 materials it would not remove the heavy metals and persistent 

 organics. Thus, we would have been trading off potential environ- 

 mental problems with ocean disposal for potentially more severe 

 environmental impacts and management problems by spreading the 

 material on land. The long-term solution -- incineration -- 

 appeared to the scientists to be worse: the danger of generating 

 contaminated ash, release of toxic compounds, and increasing air 

 pollutant emissions in a densely populated area. 



Faced with this dilemma, the City brought suit in the U.S. 

 District Court, arguing that the 1981 deadline applies to sewaae 

 sludge dumping that unreasonably degrades the marine environment, 

 and that in applying this deadline, the EPA must evaluate all the 

 statutory criteria. Judge Sofaer ruled, in April, 1981, that EPA 

 must revise its regulations. In particular, EPA was directed to 

 evaluate the characteristics of the proposed dumpsite, to evaluate 

 the availability of the alternatives, and to evaluate the environ- 

 mental effects of the alternatives. The decision in the case 

 allows New York City to continue ocean disposal until EPA completes 

 site designation and evaluates our special permit application. 



We are now well into this process. In accordance with the 

 judgment, we petitioned EPA to proceed with site designation 

 procedures. On December 20, 1982, EPA began rulemaking on the 

 106-mile site and solicited comments on the 12-mile and 60-mile 

 sites. The City completed its three volumes of technical information 

 in support of the designations and submitted them to EPA prior to 

 the May deadline. At the same time we are proceeding with 



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