252 



by sludge disposal in the New York Bight, the actual percentage 

 of PCB's contributed by sewage sludge in this area may be in the 

 same range as other contaminants in these sludges, that is 

 between 3-12 percent. 



Sludge production for the year 2,000 can now be more accurately 

 estimated at 354 dry tons per day. As the treatment processes 

 are upgraded and we approach these projected dates, we are able 

 to provide more accurate estimates of sludge production. 



We believe that the gradation of one City's sludge compared to 

 another, as to which is "cleaner" or "dirtier", is not an 

 exercise in which we wish to participate. The Environmental 

 Protection Agency, in reviewing each municipality's special 

 permit application, will have to decide if that municipality's 

 sludge unreasonably degrades the ocean environment or not. 



New York City's current cost to dispose sludge at the 12 mile 

 site, based on 1982 sludge production figures and costs, is 

 $68.16 per dry ton. The estimated cost to transport the sludge 

 to the 106 mile site is $254.27 per dry ton. When one considers 

 that the costs of all municipal services are higher here than in 

 other cities, to seek out more expensive methods for any of 

 these services without a sound basis would be indefensible. 

 When these alternate methods are environmentally less 

 acceptable, as we believe land based alternatives are compared 

 to ocean disposal, such a switch would also be irresponsible. 



