241 



and the money was returned to the Federal Government when the 

 Sofaer decision came down. I do not know precisely, but $30 million 

 we spent in developing the short- and long-term alternatives, I be- 

 lieve. 



Mr. Carper. Is there any sludge produced now — I understand 

 you have a number of plants in the city — at one or several of those 

 plants which is acceptably clean for land application or compost- 

 ing. 



Mr. McGouGH. Well, I will turn to Jim, but I believe the Oak- 

 land Beach plant, which is an entirely residential area, we have 

 been talking to Gateway National Park that now owns our sludge 

 beds, for land application of that because it meets land-based appli- 

 cation. It is a very small plant, however. 



Mr. Gift. I cannot answer, I do not know whether I can add a 

 lot. There is a moratorium on land application of sludges in the 

 State of New York. I am not sure what the status of that is now. 

 There is obviously a variability in the pollutant loading in the 

 sludge of some of the plants. Some are cleaner than others. Cer- 

 tainly there could be a way to differentially manage them based on 

 the constituents. 



Mr. Carper. In Delaware, they used to criticize the city of Phila- 

 delphia because they dumped their sludge off the coast of Bethany. 

 They do not do that now. Among other things, Philadelphia is sell- 

 ing their compost. I wonder, is their sludge cleaner? Do you think 

 Philadelphia sewage treatment is not the same as sewage treat- 

 ment in New York City? What specifically do you think the rele- 

 vant differences might be that enables the city just down the free- 

 way from you folks to find reasonable uses for its sludge, whereas 

 New York City has not yet done so? 



Mr. McGouGH. Well, I am not familiar with the individual com- 

 ponents of their sludge. What I believe, though — and I would be 

 happy to complete the record with respect to an analysis of their 

 sludges and ours for you — but certainly in the quantity and in the 

 heavy metals our sludges have not been and will not in our opinion 

 prove to be a responsive to the pretreatment program. Therefore, 

 even after our pretreatment program is in place we will have a 

 larger percentage of heavy metals and higher concentrations. That 

 will be one difference. And of course the quantity. 



The other thing is, too, that I think from my familiarity with the 

 case in Philadelphia is that the strip mines have considerably wid- 

 ened their options. 



However, I understand the State has not finalized permits in 

 Pennsylvania to do that, and there is a lot of opposition to that ap- 

 plication of those sludges, which fall into the same categories of 

 quality as ours. 



Again I come back to the fact, is it environmentally sound to do 

 what Pennsylvania proposes to do? Is that the most environmental- 

 ly sound option? It is the one that gets it out of the ocean, but is it 

 the most environmentally sound option, maybe more environmen- 

 tally sound then 65 miles but not 106? So again I would say the 

 decision by Philadelphia to get out of the ocean was based on a de- 

 termination because of EPA aggressiveness, but whether or not 

 they chose that option has not been answered. 



