Question: I’m just reporting that it is not an unknown problem. 
G. Wallace: I'm glad to hear that. 
C. Breen: Gordon, if I understand your statement about the 301(h) waiver 
process, the reason, in your words, they were ignoring the impacts of the sludge discharge 
is that the sludge discharge into Boston Harbor is something that is not supposed to 
happen, and plans are underway to halt it. A separate EIS on sludge disposal options will 
be prepared following completion of the EIS on treatment plant siting. 
G. Wallace: No. In judging between primary and secondary, you always end up 
with the higher toxic levels in the secondary treated sludge. That poses a problem with 
disposal. And the consequences of that activity versus primary sludge disposal and the 
options we have, therefore, have to be balanced. And that's what was not done. 
C. Breen: Okay. Thank you for clarifying that because I thought you were 
talking about the discharge of sludge into Boston Harbor. 
G. Wallace: No. 
K. Castagna: I'd like to say that the waiver regulations are written very 
specifically as to what shall be evaluated when a municipal applicant applies to the EPA 
to allow for a lower level of treatment other than secondary. Those regulations don't 
allow for economic analyses, such as how much more secondary would cost than primary. 
Those regulations also don't allow for the evaluation of what we do then with the residual 
waste product, meaning sewage sludge. So under regulations in evaluating that waiver 
application, EPA does not have that variability or viability to go into, say, a cost-benefit 
analysis and weigh those other conditions. 
G. Wallace: I know. 
J. Thomas: Maybe I could just shift gears here just a little bit. We heard 
earlier—I think it was from Paul Boehm, and if not Paul, excuse me—that you're not sure 
that a trend toward whether or not the system was getting worse or better because the 
data base was too short in temporal time. We also heard people talk about problems with 
spatial variation, that they had only sampled in some of the pockets and thus weren't sure 
whether their samples were truly representative or not. 
The question I'm really asking is from this panel—and maybe we can hear from 
several of you—do you feel that the habitat of Boston Harbor and Massachusetts Bay, the 
trend, is getting worse, getting better, or don't you know? Do you feel the State of 
Massachusetts and the Federal Government are getting on top of the problem? Or do you 
feel that the question is pretty much up in the air? And maybe if you want to include the 
living marine resources in there as well, we'd be interested to hear some kind of wrap-up 
statements on that. 
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