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The city of Philadelphia, like New York City, has an old combined storm /sanitary 

 sewerage system. Philadelphia disposes of its sludge in a number of ways, including 

 the experimental uses of composted sludge to reclaim strip-mined areas in western 

 Pennsylvania. The lease to utilize these strip-mined areas is expiring, and the State, 

 has not yet reauthorized use of these areas. Philadelphia, like New York City, will 

 now need to reevaluate alternative disposal methods. 



Question. Can industrial pretreatment make NYC's and NJ municipalities' sludge 

 clean enough for at least some useful land application or composting purposes? 



Answer. Industrial pretreatment can result in the reduction of concentrations of 

 constituents of concern thus improving the quality of sewage. However, the institu- 

 tion/regulatory and land use/availability problems mentioned previously remain to 

 be resolved regardless of whether an industrial pretreatment program is implement- 

 ed. 



Question. Could you provide for the record evidence that the EPA and the Coast 

 Guard are making an effort to ensure adequate surveillance of ocean dumping activ- 

 ities, especially in the event the 106-mile site is designated? 



Answer. Under the Marine Protection, Research, and Sanctuaries Act, the U.S. 

 Coast Guard has the responsibility for conducting police-type surveillance of ocean 

 dumping activities. The current U.S. Coast Guard instruction regarding surveillance 

 and enforcement of dumping activities at ocean disposal sites establishes a goal of 

 observing 75% for industrial waste disposal operation and 25% for municipal 

 wastes. General surveillance activities include stationing a shiprider onboard the 

 vessel to observe the disposal operation, conducting random spot checks before the 

 barge leaves port, checking vessel logs for departure and arrival times, randomly 

 inspecting shore facilities, and using helicopter/plane and picketship surveilance. 

 Nearshore sites permit use of patrol vessels and helicopters; however, until other 

 techniques are developed, surveillance at the 106-Mile Site is limited to the use of 

 observers (ship-riders). As indicated by Mr. Steven Schatzow, Director of EPA's 

 Office of Water Regulations and Standards, before the Subcommittee on Oceanog- 

 raphy and the Subcommittee on Fisheries and Wildlife Conservation and the Envi- 

 ronment of the House Merchant Marine and Fisheries Committee on 25 May 1983, 

 some innovative surveillance techniques — permittee supported shipriders, "black 

 boxes", navigational overlays — are being considered by EPA to augment those meth- 

 ods of surveillance currently employed by the U.S. Coast Guard. 



Questions of Mr. Hughes and Answers by EPA 



(1) To what extent will the cross medium analysis program currently being under- 

 taken by EPA's sludge management task force be directly applicable to regional 

 problems in the New Jersey/New York area? 



The fundamental charge to the Task Team is the development by the end of 1983, 

 of draft comprehensive guidance for sewage sludge disposal; that is, disposal on or 

 in land, incineration, and discharge into the ocean. The guidance will embody ex- 

 plicit policy objectives formulated as part of this effort and will complement existing 

 Agency regulations and technical guidance pertinent to sludge management. The 

 guidance document, which is expected to be advisory rather than regulatory in 

 nature, will include: (1) general and technical background information; (2) recom- 

 mended practices and criteria for assuring environmental protection; (3) guidance 

 for maximizing beneficial uses and cost effectiveness; and (4) a general analytic 

 framework for assisting local officials in assessing their disposal and reuse options 

 in light of local environmental, economic, and socio-political conditions. Thus, once 

 available, the guidance may be utilized by Federal, State, and local regulatory agen- 

 cies and sewage sludge generators in assessing technically feasible, environmentally 

 acceptable, and economically affordable disposal and reuse options. 



(2) Does the ocean dumping of sewage sludge in the New York Bight Apex play a 

 role in lowering the bottom-dissolved oxygen concentrations in and adjacent to the 

 New York Bight Apex, stressing fish and shellfishing populations, altering benthic 

 productivity, and possibly resulting in the death of some bottom organisms? 



The oxygen demand from ocean dumped sewage sludge can contribute to the low- 

 ering or dissolved oxygen concentrations in bottom waters in and adjacent to the 

 dump site, particularly during late summer months. A similar statement for the 

 entire Apex would not necessarily be accurate. Reduced dissolved oxygen concentra- 

 tions, (i.e., below 3 ppm), can stress non-mobile fish and shellfish populations, can 

 alter benthic productivity, and can result in the death of some benthic organisms. 

 The role that sewage sludge dumping has played in reduced oxygen content and re- 

 duced species diversity at or near the 12-Mile Sewage Sludge Dump Site in the 



