246 



The act provides that the administrator of EPA shall determine which dumpinj? 

 will not unreasonably degrade tlie ocean environment. However, the regulations 

 are so specitic that the prerogatives of the administrators to accept and utilize 

 available scientific information in their determination of what is permissable 

 dumping, is negated, particularly if such scientific evidence would tend to justify 

 ocean disposal. 



If the intent of the regulations is to eliminate the dumping of wastes, and in 

 particular sludge generated by sewage treatment, in the ocean it may be well 

 to consider the potential impacts of the alternatives. For example, is the total 

 environment improved by eliminating the dumping of sludge at sea and placing 

 the same sludge on land? The large scale land application of digested sewage 

 sludge, particularly in the humid urban northeast corridor, must be examined 

 closely to determine its feasibility. Lack of information regarding such dispo.sal 

 activities on land would seem to preclude this alternate as an immediate sub- 

 stitution for ocean disposal. While land application of sludge is currently being 

 practiced by Chicago, there is indeed no assurance of the transferability of 

 the results or of the methodology employed. This is evidenced by the fact that 

 the city of Philadelphia and the U.S. EPA are currently negotiating a research 

 facility demonstration grant for this purpose. 



In order to properly manage and optimize the use of our total natural resources, 

 any legislation and implementing regulations must consider the entire environ- 

 ment, including a myriad of socio-economic needs such as : 



1. "What is the total environmental impact of the many alternates as compared 

 to ocean use, including activities?'' 



2. "Will other disposal methods intensify the energy cri-sis?" 



3. "Will public opinion prefer other disposal techniques to ocean dumping?" 

 Questions (^f this nature must be effectively answered before regulations and 



criteria are produced that might unnecessarily eliminate the use of the ocean as 

 a vehicle for recycling our natural resources. 



Along these lines, implementing national policy should not cause a burden or 

 hardship to certain segments of country by precluding an acceptable waste 

 disiwsal method. In the highly urbanized northeast, for example, the cost of 

 alternate means of disposal for certain wastes will be significantly higher than 

 ocean dumping. Federal subsidies may be required in such areas to offset these 

 costs which are incurred as a function of geography. Increased costs for waste 

 disposal in urban areas must also be considered in the context of higher priority 

 human needs such as schools, crime prevention, better housing, etc. 



Philadelphia now produces nearly 380.000 gallon of digested sludge a day. 

 We cannot shut down our three plants which treat over 450 million gallons of 

 sewage per day not only from Philadelphia, but from surrounding communities. 

 These plants are being rebuilt at a cost of $247 million in compliance with 

 EPA regulations. When complete, the new plants will generate twice the pres- 

 ent volume of digested sludge and intensify the problem. 



In the design of these new facilities, we had to necessarily reassess our 

 methods of sludge disposal. The environmental feasibility of any method was 

 an important factor as well as related capital and operating costs. In our 

 opinion, disposal of digested sludge at sea is an environmentally acceptable 

 method with the least effect on our total environment. Operating costs for 

 ocean disposal are approximately $10 per dry ton. If figures for Chicago's land 

 disposal method are applicable to the Philadelphia metropolitan area, then oper- 

 ating costs for this method are as high as .$70 a dry ton and it would appear 

 that the Philadelphia area would experience particular problems for trans- 

 portation which could add significantly to the estimated cost for land disi)osal. 



Incineration is expen.sive method with projected costs running as high as 

 $R0 a dry ton. With incineration, one must al.so consider air pollution aspects 

 and additional capital and operating costs. 



It has been estimated at start up of Philadelphia's new updated plans using 

 present day prices that additional costs for ocean disposal will be about $1 

 more per account or 2.7% of today's charge for sewerage services: land dis- 

 l)nsal will increafip the sewer bill l)y 40% ($!;"). 001. and incineration 47% ($17.40). 

 These numbers will have to be increased to reflect inflation which is currently 

 estimated to be 8% per year for contractual services. 



Prudently, we must consider costs and in so <l()ing we conclude that on the 

 basis of available scientific information, there is no cause to foreclose use of 

 the ocean for disposal of digested sewage sludge and consequently increased 

 costs which in Philadelphia's case would be .1-8 times their present level. 



