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                          H: A report to the Administrator of the
                          Environmental Protection Agency by the
                          President's Water Pollution Control
                          Advisory Board.
  0/I "

     '
  U.S. ENVIRONMENTAL PROTECTION AGENCY
        Washington, D.C. 20460
  .-*•  ^>-
  ^ * .«'

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        OCEAN DISPOSAL
        PRACTICES
        and  EFFECTS
  *A report to the Administrator of the
   Environmental Protection Agency of a
   recent meeting held by the President's
   Water Pollution Control Advisory Board.
        SEPTEMBER 26-29, 1972
U.S.  ENVIRONMENTAL PROTECTION AGENCY
        Washington, D.C. 20460

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          THE PRESIDENT'S WATER POLLUTION CONTROL ADVISORY BOARD
    Chairman

Mr. William D. Ruckelshaus
Administrator
Environmental Protection Agency
Washington, D. C.  20460
    Executive Secretary

 Mr. Alan Levin
 Office of the Administrator
 Environmental Protection Agency
 Washington, D. C.  20460
                            Ex Officio Member
                            Honorable Elliot L. Richardson
                            Secretary, Department of Health,
                              Education, and Welfare
                            Washington, D. C.  20201
Members
Mr. Jack A. Beaver, General Manager
San Bernardino Valley Municipal
  Water District
1350 South E Street
P. 0. Box 5906
San Bernardino, California  92412

Mr. Frederick J. Conn, Jr.
President and Publisher
San Angelo Standard-Times
34 W. Terrace
San Angelo, Texas  76901

Mr. William D. Farr
President
Farr Farms Company
Box 878
Greeley, Colorado  80631

Mr. Ray W. Ferguson
California Water Commissioner
218 Deodar Street
Ontario, California  91762
Mr. Thomas W. Gleason
International President
International Longshoremen's
  Association, AFL-CIO
17 Battery Place, Suite 1530
New York, New York  10004

Mr. Byron P. Jordan
Executive Vice President
French Jordan, Inc.
1010 Common Street, Suite 1065
New Orleans, Louisiana  70112 .

Mr. Irvan F. Mendenhall
President
Daniel, Mann, Johnson § Mendenhall
3250 Wilshire Boulevard
Los Angeles, California  90010

Mrs. Samuel Rome
Environmental Quality Chairman
League of Women Voters of Illinois
1421 Forest Avenue
River Forest, Illinois  60305
                         Dr. Mitchell G. Zadrozny
                         Professor of Geography
                         Wright Junior College
                         34 N. Austin
                         Chicago, Illinois  60634
 STAFF:
 Mrs.  Shron Gascon,  Staff Assistant

 Miss  Elaine Galloway, Secretary

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      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C.  20460
                                                                OFFICE OF THE
                                                               ADMINISTRATOR
Dear Mr. Administrator:

I am pleased to submit this report of the meeting of the President's
Water Pollution Control Advisory Board on ocean disposal practices
and effects held in New York City on September 26-29, 1972.

The Board met to explore and advise on the problem of ocean dis-
posal not only as it relates to New York, but also as a national
and international issue.  The primary objectives of the meeting
were to focus public attention on the topic, to explore alter-
natives to ocean dumping pollution, and to provide some insight
for obtaining answers to unknown aspects of ocean disposal problems.

The Conclusions and Recommendations included as an Appendix to
this report were formulated following a comprehensive briefing to
the Board by representatives of Federal, State, and local govern-
ment, a flyover by helicopter to view dumping practices in the
New York Bight, and a full day of public testimony by experts in
the field of ocean disposal.

As you are aware, since the meeting some of the Board's major
recommendations have already been implemented through enactment of
the Marine Protection, Research and Sanctuaries Act of 1972 and the
Federal Water Pollution Control Act Amendments of 1972.  The Board
stands ready to help in any way possible to translate its remaining
recommendations into action.

                               Respectfully submitted,
                               Alan Levin, Executive Secretary
                               President's Air and Water Advisory
                                 Boards
                             -11-

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                         INTRODUCTION
The President's Water Pollution Control Advisory Board was autho-
rized by the Water Pollution Control Act Amendments of 1956 (P.L.
84-660).  The Board's authority was continued under the Federal
Water Pollution Control Amendments of 1972 (P.L. 92-500).

The Board's mission is to advise, consult with, and make recommen-
dations to the Administrator of the Environmental Protection Agency
on matters of policy relating to water pollution control.   Under
this authority the Board regularly examines all phases of the
national water pollution problem and from time to time holds public
meetings to hear the views of individual citizens, various levels
of government and private agencies and groups.

There are nine members, appointed by the President, who serve three
years each.  The Chairman is the Administrator of the Environmental
Protection Agency, and the Secretary of the Department of Health,
Education, and Welfare is an ex officio member.  Three of the appointive
terms expire each June 30 or at such time thereafter as successive
appointments become effective.  No member may succeed himself within
one year of the date his term ends.

The Advisory Board holds four to six.meetings a year.  Usually two
of these are held in Washington, D. C. for the purpose of reviewing
clean water plans, policy and progress with the EPA Administrator.
The other meetings are held in various regions of the country at the
call of the Chairman, or at request of individual Board members or a
State governor who feels that a particular water pollution problem
should have the Board's attention.  The regional meetings serve,
first to inform the Board members on the various types of water
pollution problems and control programs that exist throughout the
Nation.  Also, because they are open to the public, the regional
meetings focus public attention on particular city, State or regional
problems and stimulate action for pollution control in problem areas
under review.
                                -111-

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TUESDAY, SEPTEMBER 26, 1972:
The meeting was convened in the Environmental Protection Agency, Region
II, New York City by Mr. A. James Barnes, Assistant to the Administrator,
EPA in the absence of Administrator, William D. Ruckelshaus, permanent
Chairman of the President's Water Pollution Control Advisory Board.

Board members present:  Mr. Jack A. Beaver, San Bernardino, California;
Mr. Frederick J. Conn, Jr., San Angelo, Texas; Mr. William D. Farr,
Greeley, Colorado; Mr. Ray W. Ferguson, Ontario, California;
Mr. Byron P. Jordan, New Orleans, Louisiana; Mr. Irvan F. Mendenhall,
Los Angeles, California; Mrs. Samuel Rome, River Forest, Illinois;
Dr. Mitchell G. Zadrozny, Chicago, Illinois.  Mr. Richard S. Green
represented the Secretary of Health, Education, and Welfare who is the
ex officio member of the Board.  Former Board member, Dr. Wallace W.
Harvey, Jr., Manteo, North Carolina served as a consultant for the
meeting.  Not present was Mr. Thomas W. Gleason, New York, New York.

The following newly appointed members were sworn in by Chairman Barnes:
Mr. Jack A. Beaver, Mr. Frederick J. Conn, Jr., and Dr. Mitchell Zadrozny.

After the swearing in ceremony and introduction of the Board members,
Mr. Barnes emphasized the importance of the meeting as it related to the
pending legislation on ocean dumping (The Marine Protection Research,
and Sanctuaries Act of 1972).  He also pointed out the inter-relationship
between ocean disposal and other pollutents and that ocean dumping is
merely a small part of the overall ocean disposal problem.

Following Mr. Barnes' statement, the Board heard from Mr. Jerome Kretchmer,
Administrator, New York City's Environmental Protection Administration,
who spoke on behalf of Mayor John V. Lindsay.  Mr. Kretchmer referred
to New York City's staggering environmental problems and emphasized
that what the City needs from the Federal government 4s- financial, tech-
nical, and legal assistance.  He explained that although the Board is
meeting on ocean dumping, New York City's fundamental problem is that
of solid wastes.  Mr. Kretchmer then reviewed the City's sewage sludge
problems and some of the possible alternatives to ocean dumping, none of
which, in Mr. Kretchmer's opinion, would allow an immediate change in the
City's present practice of dumping.  In the area of toxic metals, he
stated that the City has acted to remove such metals discharged by com-
panies into the City's sewer system.  However, he strongly urged for
the adoption of Federal standards in this area to avoid companies from
"jumping" to other jurisdictions with less stringent standards.
Mr. Kretchmer summarized the needs of New York City as follows:
                                 -1-

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      (1)  A joint Federal-City project to explore the  environmental
           implications of expanding ocean disposal in  such  a way that
           there would be no harm to the ocean.   This project could
           include a testing program of the effects of  leaching or
           other escape of baled refuse, dumped  beyond  the continental
           shelf.

      (2)  Alternative methods  of disposing of solid wastes.  The City
           needs money for research and technology and  a change in
           some restrictive Federal legislation  in the  recycling area.
           Methods should be explored of making  solid waste  a useful
           material for landfill in strip mines,  quarries, and sand pits,
           etc.

      (3)  Federal legislation  to set uniform  standards to control dis-
           charge of heavy metals to avoid the threat of industries
           fleeing to less regulated sites.

      (4)   Federal legislation  to provide funding for the disposal of
           sewage sludge should the current  ocean dumping practices of
           New  York City be altered in any way as  a result of the Board's
           recommendations.

Finally, Mr. Kretchmer made  a  strong plea for Federal-City  cooperation
to work  out short and long range solutions.   "If a Federal-City partner-
ship can find  solutions  now  for New York, the problems of other urban
coastal  complexes  can follow suit",  Mr.  Kretchmer concluded.

Mr. Gerald M. Hansler,  EPA Regional Administrator, Region II,  presented
an overview of the  ocean  dumping problems in his region.   Mr.  Hansler
concentrated on  the sludge disposal problems and discussed some of the
possible alternatives.  He explained  that incineration was tried but
that this increased the particulate matter  in the  atmosphere thereby
causing  an air pollution  problem.  As a  result, he has concluded that
ocean dumping of sludge  in the  New York-New Jersey area should be regu-
lated but not totally banned.  Mr. Hansler also proposed the idea of
experimenting with  digested  sludge  and spreading it on land in low
nutrient areas.  He concluded that  additional regulatory authority and
technology are needed and especially  the  funds to develop such technology.

The Board then flew by helicopter to  view dumping of sewage sludge, acid
wastes, and dredge  spoils  in the New  York Bight.  Mr.  Richard Dewling,
Director of Surveillance,  EPA Region  II,  conducted a briefing aboard the
helicopter.  Mr. Dewling  pointed out  that 5 or 6 barges a day each from
New York City and New Jersey municipalities dump  (50% digested, 50% raw
sludge) into the New  York  Bight, but  that there is no assurance that
such barges go to the  full 12 mile  limit  designated for such dumping.
Mr. Dewling further stated that  70% of all the sludge dumping, by vessel
or barge, in the country  occurs  there.  He indicated that water quality
                                -2-

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is not too adversely affected on the surface, but that bottom organ-
isms such as lobsters, oysters and clams do not survive.   The acid
wastes dumping are industrial discharges with 90% originating from one
company - National Lead.  Mr. Dewling indicated 55% of all the acid
dumped in the U. S. takes place in the New York Bight area.  However,
he did emphasize that such wastes do not have high levels of suspended
solids and therefore the impact on the ocean bottom is minimized.
Finally, the Board witnessed the dumping of dredge spoils from a U.S.
Army Corps of Engineers barge.  Mr. Dewling pointed out that the effects
of such dumping are immediate oxygen depletion and that there have
been citizen complaints during the summer from New Jersey shore residents
as a result of dredge spoils washing up on beaches.  Finally, it was
explained that no sludge dumping by barge occurs on the West and Gulf
coasts and that those areas employ submarine dumping by outfall with
the sludge pumped out with the effluent.

The afternoon session of the briefing for the Board continued at
Governor's Island.  The first speaker was Mr. Richard Goodenough,
Director, New Jersey Division of Marine Services who represented
Mr. Richard J. Sullivan, Commissioner, New Jersey Department of Environ-
mental Protection.  Mr. Goodenough explained that as in many other
States, New Jersey has reorganized its State pollution control agency
to deal with the environment.  The State has also recently passed a
Clean Ocean Act to regulate pollutants that are dumped at sea.  One
of the problems facing New Jersey is trying to determine how far out
to dump.  As part of the new Act, rules and regulations have been pro-
posed providing for licenses and permits for dumping.  However, before
such regulations are officially issued the State is required to hold
public hearings.

Mr. Roger Strelow, Senior Staff Member of the Council on Environmental
Quality summarized that ocean dumping has been an important concern
to the Council ever since its formation early in 1970.  In April of
that year, in a special message to Congress, the President directed
the Chairman of CEQ to work with other Federal agencies on a compre-
hensive study of ocean dumping to recommend further research needs
and appropriate legislation and administrative actions.

Mr. Strelow then reviewed the magnitude of the problem as follows:
Our oceans, containing 140 million square miles of water surface,
cover more than 70% of the earth and are an important part of the over-
all world environment.  They produce about two thirds of the oxygen
we breathe and absorb a major part of the excess carbon dioxide in the
atmosphere.  The oceans also affect world climate and provide food,
minerals and other necessities.  Unfortunately, a very large portion
of the world's pollution eventually ends up in the oceans.  Much of
our air pollution is either carried directly into the oceans by wind
or washes into the ocean from the land with rain or snow.  It is
                                  -3-

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 estimated that more than 90% of the petroleum polluting oceans each
 year comes not from tanker breakups or  other disasters but from the
 vaporization of gasoline and other petroleum products ashore.  The
 amount of lead and DDT entering the marine environment from the
 atmosphere may equal or surpass the amount carried there from rivers.
 Pollution from rivers,  however, is still  the principal pathway by
 which most pollutants reach  the oceans.   Industrial waste effluents
 are the largest components of river-borne pollution entering the oceans
 in  coastal and estuarine regions.  Close  behind are municipal waste
 effluents.  Agricultural pollutants from  land runoff add to the total.
 Some municipal and other wastes enter the ocean directly through sub-
 merged outfalls.   Vessels contribute sewage and oil, and particularly
 appropriate for the Board meeting, substances purposefully trans-
 ported from land for the purpose of disposal in the ocean.  Altogether,
 these sources  of pollution have created a disturbing condition,
 alarming scientists throughout the world.

 Mr.  Strelow continued by pointing  out that ocean dumping is a small
 but potentially growing part  of the overall ocean pollution picture.
 He  stated that although domestic dumping  off the Pacific Coast has
 declined the reverse may be  true of the Atlantic Coast.  We know even
 less of the trends in and volume of ocean dumping by other nations.

 Mr.  Strelow emphasized  that in the U. S., we have controls over air and
 water pollution,  but to permit a truly  systematic and comprehensive
 control  of pollution, we must  have regulatory controls on ocean dumping
 as well.   He referred to the ocean dumping legislation passed by both
 Houses of Congress,  but temporarily held  up because of jurisdictional
 squabbling between Congressional Committees.

 Mr.  Strelow briefly discussed  current status - domestically and inter-
 nationally - on  ocean dumping  controls.   He mentioned the CEQ
 comprehensive  study:  Ocean Dumping: A  National Policy issued in
 October  1970.  The Council's study concluded that ocean dumping wastes
 are  heavily concentrated and contain materials that have a number of
 adverse  effects.    The  report  further concluded that existing regu-
 latory activities  and authorities were not adequate to handle either
 the  current or the potential expanded problem of ocean dumping.  The
 report recommended legislation that would require a permit from EPA
 for  all  ocean  dumping activities subject  to U. S. jurisdiction.  It
 also underscored  the need for  international action to protect the
world's  oceans.   Finally,  the  report identified various areas of
 research needing  attention in  order to permit the most effective exer-
 cise   of both national  and international  controls.  On the basis of
the Council's report, the  President proposed a Marine Protection Act -
the  legislation currently pending approval.  At the same time, he
instructed  the Secretary of State in coordination with CEQ to develop
and pursue  international  initiatives for  the world-wide control of
ocean dumping.  The U. S. has been working with other nations  on an

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international convention to control ocean dumping in accordance with
a permit system to he administered by national authorities.   The
June 1972 United Nations Conference on the Human Environment called
upon interested governments to convene a conference by November 1972
to negotiate a convention for signature before the end of the year.
In the meantime, in February 1972, 12 European nations signed the
Oslo Convention - a regional convention to curtail ocean dumping of
hazardous wastes by ships and planes in the northeast Atlantic and the
North Sea.

Mr. Strelow concluded that it may be that the oceans ultimately will
provide the most environmentally acceptable repository for limited
types of man-generated wastes, at certain sites and under certain
conditions.  However, the available evidence indicates that recycling
of the materials or land disposal appear to be preferrable.   The legis-
lation and international convention should provide the mechanisms for
requiring ocean disposal to be dealt with on this basis.

The next speaker, Mr. T. A. Wastler, Chief, Water Quality Protection
Branch, EPA first discussed the scope of the ocean disposal problem.
He indicated that the sum total of pollutants to marine waters is not
known, largely due to the size and complexity of the problem, but some
quantitative estimates of toxic constitutents developed by the National
Academy of Sciences is impressive.  In this regard, it is estimated
that from 1/4 to 1/2 of fishing production is directly or indirectly
dependent on estuaries.  These are the areas in which we are concen-
trating our wastes, thereby inflicting an as yet undetermined stress
on coastal marine ecosystems.  There is little information about the
fate of wastes materials after they reach the open ocean, but a few
illustrations show that man's methods of waste disposal are impacting
there as well.

Mr. Wastler pointed out that pollutants can enter the marine environ-
ment along many pathways, but there are three main ones.  The first
is as the residuum of pollutants from inland sources discharged to
rivers which ultimately flow into the sea.  The second pathway is as
direct discharges into the ocean through ocean outfalls, and the wastes
so discharged can contain the wide variety of polluting substances
present in municipal and industrial waste streams.  Direct  dumping of
wastes into the ocean is the third main pathway, and such wastes
generally contain pollutants which are extremely difficult or uneco-
nomical to treat by conventional means.  Mr. Wastler then proceeded to
discuss existing legislative authorities as follows:  Continuous
point source discharges of pollutants into "navigable" waters are
controlled under existing laws by water quality standards set by
State and Federal action.  The existing Federal Water Pollution Act
does not contain authority for EPA to regulate directly continuous
point source discharges into the contiguous zone or to regulate the
dumping of waste material into marine waters.  Under present law,
                                -5-

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 discharge to navigable waters  are controlled under  Section 13 of the
 Refusre Act of 1899,  however, the contiguous zone  and the open oceans
 are not included in  the law,   final  authority  for permitting the
 dumping and/or discharge of waste material into navigable waters is
 vested in the U.  S.  Army- Corps of Engineers.   Within the scope of
 existing laws, then, EPA has no effective means of  controlling the
 dumping of wastes into the  marine environment.

 On the subject of anticipated  legislation, Mr. Wastler reviewed the
 provisions of the proposed  Marine Protection,  Research, and Sanctuaries
 Act of 1972 (Ocean Dumping  Act)  under which the transportation and
 dumping of all materials in the open seas outside the limit of the
 territorial waters will  be  regulated by  issuance of permits.  This
 proposed legislation addresses itself specifically  to the problem of
 ocean  dumping, however,  there  is a close relationship between the
 responsibilities  explicitly assigned in  this legislation and the
 authorities involved in  the extension of EPA authorities to the con-
 tiguous zone of the  near-shore-oceanic waters, as is proposed in the
 current legislation  to amend the Federal Water Pollution Act.  In
 addition to these proposed  laws, there already exists recognition of
 concern for the problems  of the  "estuarine zone" in authority to study
 this part of the  environment and to  make recommendations on how to use,
 develop,  and preserve it  under Section 5(m) of the  existing Act and
 under  Section 140(n)  in  the proposed amendments.

 Mr. Wastler outlined some of EPA's past, present and proposed strategies
 in dealing with the  marine  environment.  The past approach to combating
 marine pollution  problems has  been one of responsive enforcement.  This
 approach  is not,  however, sufficient to  cope with the existing and
 potential pollution  problems of the  estuarine, coastal, and oceanic
 environments.   Mr. Wastler  stated that the strategy necessary to cope
 with such problems,  including  ocean  dumping must be one of correcting
 potential problems before they occur as  well as making a direct attack
 on the problems that already exist.  EPA's program  strategy in imple-
 menting the Ocean Dumping Act  of 1972 will be  an integrated approach
 toward control and cessation of  ocean dumping, using not only the new
 authorities of the Act, but also the other authorities EPA has, or
 expects  to have,  in  the marine environment.  Mr. Wastler stated the
 program consists  of  two phases.   The first is  a predominantly in-house
 effort  during the first six months directed toward,  developing  criteria
 guidelines  and regulatons for  the permit issuing system to become
 operational six months after enactment of the  law.  The second phase
 consists  of the routine operation of the permit system while working
with NOAA and the Coast Guard  in developing information from which
 revisions  to  criteria can make the permit system more effective and
which will  also lead to a more integrated approach  to the solution of
 all marine  pollution  programs.

Mr. Wastler then briefly  outlined some of the responsibilities of other
Federal agencies with regard to  ocean dumping and particularly in
reference  to  the proposed legislation:
                                -6-

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00  U. S. Coast Guard;  The Ocean Dumping Act specifically charges
     the Coast Guard with the surveillance of ocean dumping operations
     and enforcement of the conditions under which specific ocean
     dumping permits will be granted.

(2)  U. S. Army Corps of Engineers:   The Corps has had special  regula-
     tory authority over ocean dumping for the port areas of New York,
     Baltimore, and Hampton Roads, Virginia, under the Supervisory
     Harbors Act of 1888; the Ocean Dumping Act of 1972 rescinds this
     authority.  Section 4 of the Rivers and Harbors Act of 1905, and
     Section 13 of the 1899 Refuse Act which regulate ocean dumping  in
     the territorial sea, are also superseded by the Ocean Dumping Act.

(3)  Atomic Energy Commission:  The Ocean Dumping Act of 1972 requires
     that the AEC consult with the Administrator, EPA prior to  issuing
     permits for the ocean disposal of radioactive material and that
     the AEC, in issuing permits comply with standards set by the
     Administrator respecting limits on radiation exposures or  levels,
     or concentrations or quantities of radioactive materials.

(4)  National Oceanic and Atmospheric Administration:  The Act
     specifically charges NOM with responsibility for monitoring of
     dumping areas and for comprehensive research on ocean pollution.

C5)  Department of State:  The Act directs the Secretary of State, in
     consultation with the Administrator, to seek effective inter-
     national action and cooperation to ensure protection of the marine
     environment.

(6)  Other Federal Agencies:  The Act directs the Administrator, in
     developing criteria for ocean dumping, to consult with the
     Secretaries of Commerce, Interior, State, Defense, Agriculture,
     HEW, and DOT, AEC; and other appropriate Federal, State, and local
     officials.

Mr. Arnold Joseph, EPA Office of Research and Monitoring outlined EPA's
program of research related to ocean dumping.  The Office of Research
and Monitoring conducts two programs of scientific, marine pollution
related research.  These programs are known as "Ecological Effects" and
as "Fate of Pollutants in the Marine Environment."  Both have as a
principal objective the development of scientifically sound marine water
quality criteria to be used in establishing marine water quality stan-
dards.  The Ecological Effects program involves studies on the effects
of a wide range of pollutants on marine fishes and invertebrates.
Pollutants studied include heavy metals, oil and oil spill dispersants,
chlorine, and heat.  Fundamental work on dissolved oxygen, salinity and
pH requirements of organisms at several trophic levels is also conducted.
Although none of the Ecological Effects research program has been
directly concerned with dump site conditions and effects, the research
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 results  on  specific pollutants  are applicable to dumping in so far as
 the  s-ame pollutants would Be  introduced By- dumping.

 The  Fate of Pollutants program  Has been more directly concerned with
 ocean waste disposal problems.  Its studies deal with the processes
 and  mechanisms governing the  introduction, transport, distribution and
 chemical transformation of pollutants in marine waters.  Emphasis is
 given to development of predictive and descriptive math models for the
 fate of  pollutants, and to developing guidelines for environmentally non-
 degrading waste dischrge practices.  Also, under the Fate program there
 are  several  studies related to  the sludge  dumping problem.  One involves
 the  chemical characterization of municipal sewage sludges destined for
 sea  disposal.  Measurements are being made of heavy metals, persistent
 organics and other possible pollutants contained in the sludges.  The
 other is a project in cooperation with the Navy's Fleet Numerical
 Weather  Center to develop and test a computerized coastal circulation
 model that will predictably describe the mixing taking place over sludge
 dumping  areas.  More projects with a direct relationship to sludge
 dumping  problems are contemplated, budgets permitting.

 Mr.  Joseph reviewed some other  marine related programs of the Office
 of Research and Monitoring which include those of an engineering develop-
 ment nature to develop systems, mainly hardware, to control or abate
 oil  and  hazardous material spills and to treat shipboard sewage.  There
 is also  a substantial interest  in developing alternate means of sludge
 disposal on land.  These are addressed in the 'Task Force Report on
 Sludge Disposal" by the Office  of Research and Monitoring, April 1972.
Mr. Joseph also mentioned a report, "Ocean Disposal of Barge Delivered
 Liquid and Solid Wastes from U. S. Coastal Cities" (1971), by the
 Dillingham Corporation of LaJolla, California.  This work was supported
by the Office of Solid Waste Management, EPA and comprehensively covers
 the  logistics in 1968 of ocean-barge disposal of all classes of wastes.

Mr. Joseph emphasized that we are still some distance away from under-
standing the impact on or the capacity of the marine environment with
respect  to disposed wastes, and that there is no shortage of recommen-
dations  or ideas for research.  He explained that the Office of Research
and Monitoring has developed a work plan to implement the pending ocean
dumping  legislation.  The program outlined would work toward seven
objectives:

     (1)   Characterization of dump materials;

     (2)   Physical, chemical, ecological effects of past dumping;

     C3)   Toxic and/or beneficial effects of sludges, spoils;

     C4)   Testing protocols for potential waste disposers;
                                -8-

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     C5]  Optimum dumping technology;

     C6)  Criteria for site selection and use; and

          Bioassays of pollution in dumped materials.
Mr. Joseph concluded by stating that in order to establish scientifi-
cally objective, quantitatively valid criteria, it is necessary to
have accurate information and data on the materials to be dumped,
particularly the physical and chemical forms of the ecologically dis-
ruptive constituents.

Mr. Martin Lang, Commissioner, New York City Department of Water
Resources discussed the City's sludge disposal problems.  Mr.  Lang
pointed out that it is his mission to protect and enhance receiving
waters and that New York City is presently treating 75% of its waste-
water.  As a result some waterways, namely the East River, portions of
New York Harbor and Jamaica Bay have reportedly had rising levels of
dissolved oxygen.  Mr. Lang's position is that it is better to dump
sludge and preserve the more precious in-surface waters.  It is
Mr. Lang's view that the City's real problem is solid waste and if that
problem is solved it will in turn solve the sludge problem.  Mr. Lang
discussed some of the alternatives such as incineration, however, he
is not satisfied with the air pollution impact.  Another alternative
being considered is to use sludge as a landfill to build a park.
Mr. Lang concluded with a discussion of the metal content in sludge.
He emphasized that the metals input can be minimized, but it must be
done in a rational manner.  Further, he stated that what is needed are
good data in relation to the amounts of concentration and effects , not
emotion.  Mr. Lang also stated that the toxic metals problem in sludge
is not as severe in New York City as in some other large cities.

The day's final speaker was Dr. Roland Smith, Chief, Division of
Living Resources, Office of Marine Resources, NOAA.  Dr. Smith indicated
that although NOAA has no direct responsibilities for regulating ocean
dumping, the issue is of key importance to his agency.  A major goal
of NOAA is to develop programs to assure that the ocean environment and
its resources are wisely used.  NOAA's National Marine Fisheries Service
has fisheries development responsibilities on which ocean dumping and
other environmental quality issues bear directly.  A second major goal
of NOAA is to monitor and predict environmental conditions.  In this
regard the pending Federal ocean dumping legislation assigns important
responsibilities for research and monitoring on ocean dumping to NOAA.
Dr. Smith emphasized that in exercising these responsibilities, his agency
expects to be able to provide information which will be of use to EPA
and the Corps of Engineers in their regulatory programs.  NOAA has
already conducted studies on the effects of the dumping practices on
the biota of the New York Bight.
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 Dr.  Smith, then described  a major new program being developed by NOAA -
 the  Marine Ecosystems Analysis  Program  QfESA),  The program encom-
 passes issues  broader than ocean dumping, But it is the principal
 vehicle through, which NOM's ocean dumping responsibilities will be
 addressed.   The objectives of MESA are  to:

 (1)   Describe,  understand, and  monitor  the physical, chemical, and
      biological processes of marine environments,

 C2)   Provide information  and expertise  required for effective manage-
      ment  of marine areas and the rational use of their associated
      resources  and,

 (3)   Analyze impact on marine ecosystems of natural phenomena or man-
      made  alterations.

 Dr.  Smith  explained that  an  aspect of the MESA program will be a
 systematic,  comprehensive study of the  New York Bight which is to be
 initiated  this  year.  He  stressed that  the success of this project
 will  be heavily dependent upon  NOAA's success in developing effective
 relationships with the other agencies working in the Bight such as the
 U. S.  and  New York City Environmental Protection Agencies and the
 Corps  of Engineers.  As part of this effort, the Corps of Engineers
 and  NOAA jointly sponsored an interagency meeting on September 12, 1972
 to review  the programs of the various agencies.  As an outcome, NOAA
 is chairing  an  informal interagency task force which is to formulate
 recommendations for program  coordination which all agencies concerned
 can review.
WEDNESDAY, SEPTEMBER 27, 1972:

The Board held a public meeting to hear testimony from invited experts
in the field of ocean disposal.  Eleven speakers presented statements
before the Board.  In addition, Senator William V. Roth (R) Delaware,
entered a statement for the record.  A list of the speakers and the
organizations they represent is attached to this report as Appendix 1.
A summary of the statements follows.  Senator Roth's entire statement
is included in this report as Appendix 2.  A complete set of the other
statements may be obtained from Alan Levin, Executive Secretary,
President's Air and Water Advisory Boards, Office of the Administrator,
Environmental Protection Agency, Room 1127, Washington, D. C.  20460.

Chairman Barnes introduced the Board members and reviewed the prior
day's procedures for the public's information.
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Mr. Henry Diamond, Commissioner, New York State Department of Environ-
mental Conservation:

Commissioner Diamond welcomed the Board on behalf of Governor Rockefeller.
He emphasized that this is a very important time for the future  of water
pollution control in the country* in light of anticipation of amendments
to the Federal Water Pollution Control Act.  He pointed out that if  the
amendments are passed there will have to be a massive retooling  job.
Commissioner Diamond explained that New York State has come to the end
of the first phase of its Pure Waters Program, has committed about
$3 billion and has under way 348 sewage treatment plants across  the  State.
In moving to the second stage the State has on the ballot this fall  a
bond issue calling for a $650 million appropriation for continuance  of
the State's share of the water quality program.  Included are portions
of the bond issue for solid wastes, for land acquisition and for air
pollution control, thereby indicating the State's cognizance that air
and water pollution and land use are closely interrelated.

Commissioner Diamond turned to the issue of sludge dumping and stressed
that in order to cease this practice most of the sewage plants in the
New York City area would have to be closed down causing disastrous
consequences.

Another point emphasized by the Commissioner is the.need for additional
Federal funds for sewage treatment plant construction and the importance
that actual appropriations of funds be commensurate with authorizations.

During the questioning following Commissioner Diamond's presentation,
Mr. Barnes inquired as to the possibilities of land disposal of  sewage
sludge.  Commissioner Diamond replied that there are some possibilities
in certain parts of the State, but as for New York City land is  enor-
mously valuable and scarce.

Dr. John B. Pearce, Officer-in-Charge, National Marine Fisheries Service,
Middle Atlantic Coastal Fisheries Center, Sandy Hook Laboratory, Highlands,
New Jersey:

Dr. Pearce discussed the impact of ocean dumping in the New York Bight
area.  He explained that until recently the possible biological  effects
of ocean dumping had not been fully appreciated.  In August 1968, the
Sandy Hook Sport Fisheries Marine Laboratory initiated a biological
census and hydrographic survey of the New York Bight to determine what
effects these dumping activities have had on the marine resources of the
New York Bight.  These studies revealed that in the New York Bight dump-
ing of contaminated dredging spoils and sewage sludge has had a demon-
strated effect on the physical environment and bottom dwelling marine
life.  The levels of certain heavy metals are greatly elevated in the
areas where sewage sludge and dredging spoils have accummulated.  The
sediments impinged upon by these wastes have a much greater amount of
organic material associated with them.  Bottom waters overlying the
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 disposal  areas have  lower levels of dissolved oxygen, particularly in
 the summer.   Exceedingly,  high counts of coliform bacteria were found
 in  sediments  collected  from the areas impinged upon by sludges and
 spoils, Dr. Pearce continued.  He also pointed out that the distribution
 of  both heavy metals and  coliform bacteria extend down the_Hudson Shelf
 Valley, indicating that the effects of ocean dumping may extend sea-
 ward from the point  of waste disposal.  In summary, it is Dr. Pearce's
 contention that the  40 year practice of dumping sewage sludge and dredge
 spoils from five to  10 miles off the New Jersey coast had created a
 "dead sea" threatening New Jersey and New York beaches, marine life and
 the public health.   Dr. Pearce then showed a series of slides illus-
 trating some  of the  consequences of the present dumping activities in
 the New York  Bight.

 Mrs.  Carl H.  (Jean)  Auer,  Member, State Water Resources Control Board,
 Sacramento, California:

 Mrs.  Auer spoke about ocean disposal practices on the west coast
 concentrating her remarks  on the State of California.  She explained
 that although all three west coast States (California, Oregon, and
 Washington) have standards applicable to marine and/or estuarine waters,
 only California has  a specific plan for discharge into the ocean.  The
 plan was  adopted on  July 6, 1972.

 Of  the three  west coast States, Washington's discharge to the ocean is
 the smallest with only one open ocean discharge of approximately
 200,000 gallons per  day.   The discharge, which is municipal, is given
primary treatment and discharged from an outfall approximately 300 feet
 long.  There  are four major ocean waste dischargers in Oregon, two
municipal and two industrial.  The industrial discharges, which total
 approximately 23 MGD, receive primary treatment.  Of the municipal
 discharge one, totalling 0.75 MGD, receives primary treatment and the
 other, totalling 1.6 MGD,  receives secondary treatment.  Mrs. Auer
pointed out that California discharges more than one billion gallons
 of  effluent per day  into the ocean.  That is about 30 percent of the
nation's total discharge to the ocean and more than two-thirds of the
wastewater generated daily in the State.  The major portion of these
 discharges receive primary treatment.  Implementation of California's
new  ocean plan will bring  the treatment level up to the equivalent
 of  secondary.

The plan establishes certain beneficial uses of the ocean waters which
must be protected;  preservation of marine resources, esthetic enjoy-
ment, recreation, navigation and industrial water supply.  In addition,
specific water quality objectives have been set forth to be maintained
in the ocean itself.  The  plan also sets up a category for areas of
biological s-ignificance.   In these areas natural water quality con-
ditions must be maintained and discharges are prohibited.
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Several other features of California's plan were emphasized by
Mrs. Auer.  At present 30,000 pounds of toxic heavy metals are gen-
erated per day.  Implementation of the plan will accomplish more than
90% removal.  The plan also requires that wastes be discharged in
deep water far from shore, with a 100-to-l initial dilution of sea
water to wastewater which must occur within seconds after the discharge.

As for implementation, the plan requires every discharger to submit
for approval both a technical report on what he will do to comply and
a time schedule for compliance.  The State will review and revise
these schedules, first at the Regional Board and then at the State
Board level.  The State believes that total implementation will occur
by 1977, but Mrs. Auer emphasized strongly the need for additional
Federal construction grant funds if the ocean plan is to be imple-
mented fully by that date.

Mrs. Auer discussed some of the other difficulties in implementing
the plan and conceded that often there is a difference in philosophies
between the discharger and the State Water Resources Control Board.
Nevertheless, the Board feels that the plan can be implemented.  In
this context, she emphasized that the new State law specifies that no
discharge of waste into the waters of the State "shall create a vested
right to continue such discharges."  It is no longer necessary to prove
damage to the environment before corrective action can be taken; a
reasonable suspicion is enough.  Mrs. Auer then discussed the effects
of ocean discharge, and stated that although there are many unknowns,
there is evidence that continuous ocean discharge can have an adverse
effect on the environment.  She indicated that there have been strong
indications that waste discharges are causing the destruction of kelp
beds, malformations of cancerous conditions in fish, and similar
damage.  She emphasized further that a new definition must be learned
for assimilative capacity.  In the past this level has been considered
as the highest level beneath which things start to die.  It should
properly be defined as the level that will assure total protection
of the environment.  Mrs. Auer feels it is the responsibility of
regulatory agencies, such as EPA and the State Board, to define goals
and objectives to meet the new definition, and the responsibility of
the engineering community to design the systems to get at the need.

In conclusion, Mrs. Auer urged the Advisory Board to recommend that
the comprehensive concept underlying California's Ocean Plan be used
in the Federal program as well.
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 Mr.  Jon Lindbergh,  Chairman, Oceanographic Commission, State of Washington:

 Mr.  Lindbergh  noted that more  than half of the world's population lives
 in close proximity  to  the oceans which comprise about 70% of the earth's
 surface and have  traditionally used the oceans as an all purpose dump.

 Mr.  Lindbergh  pointed  out that although such occurrances as oil spills
 are spectacular and arouse public outery, they are not as serious as the
 more subtle long  range problems caused by ocean contaimination of pesti-
 cides and toxic and heavy metals which build up in the food chain of
 marine life.   He  emphasized that sheer numbers of men and their industries
 are  now causing alterations in sea water and its confining beds that will
 lead inevitably to  changes in  sea life and resultant biological processes.
 On the other hand,  he  also pointed out that some changes in the sea can be
 beneficial  and cited examples  of a ship wreck, old car bodies or even an
 oil  well that  can induce prolific fish life in previously barren areas.

 Mr.  Lindbergh  in  conclusion urged the Advisory Board in its deliberations
 to consider the total  picture, not only the obvious and spectacular pro-
 blems of ocean dumping, but the long-term, subtle, and insidious problems.

 Asked by members  of the Advisory Board if he had any solutions, Mr. Lindbergh
 stated that there are  no magic answers, and added that there is no way in
 which we can prevent all man-made contaminations from entering the sea,
 but  it is vital that we examine the total consequences of what we put
 into it.
Dr. Donald P. de Sylva, Associate Professor of Marine Science, University
of Miami, Miami, Florida:

In discussing the effects of ocean dumping in the southeastern United
States, Dr. de Sylva reinforced several of Mr, Lindbergh's remarks, namely
that the greatest threat to the oceans is not from sewage sludge, but from
thousands of man-made chemicals that flow to the sea via rivers around the
world.  Most endangered he stressed are the coastal estuaries where 80% of
the oceans' productivity occurs.

He also told the Board that swimmers and divers using some ocean waters on
the Atlantic coast have become mysteriously ill and, in some cases died,
as a result of diving and swimming around sewer outfalls in the ocean.
Dr. de Sylva also cited a number of examples of ocean dumping by the
Federal government.

Further, he stated that while all ocean dumping cannot be ceased immedi-
ately, there must be long-range programs wjtrch, vdbll favor Recycling
resource conservation, and more economic and environmently safe techniques
of waste management.  He indicated that until ocean dumping is ceased, we
must be prepared to find a wide variety of pollutants gradually or even
suddenly appearing in sea water, sediments, and in the marine organisms
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we eat.  It is especially important, Dr.  de Sylva said,  to note that
ocean dumping is usually considered to be a purposeful practice whose
source can be theoretically identified and controlled.  Yet it is  the
sum of all sources of oceanic pollution which accumulate and concentrate
in the marine environment.

In the area of research, Dr. de Sylva emphasized that there is a great
deal more knowledge and study needed before any realistic analysis of
the effects of ocean dumping can be proposed and evaluated.  He stated
that the nation's leading oceanographers are seeking funds for such
studies and urged the Environmental Protection Agency along with such
agencies as the Department of Health, Education, and Welfare, the
Department of Defense, the Department of Interior, and the Atomic
Energy Commission to support such research.

In summary, Dr. de Sylva stated that an analysis of ocean dumping  is
really a study of the dynamics of physical, chemical, biological,  and
geological processes.  Field and laboratory research for American
researchers is urgently needed now and nothing short of  well-funded, long-
term research will supply the answers we seek, Dr. de Sylva concluded.


Mr. Donald J. Benson, Seattle Metro, Seattle, Washington:

Mr, Benson's present responsibility is River Basin Study Coordinator for
the Municipality of Metropolitan Seattle (Metro).  However, since
Mr. Benson formerly served as Executive Secretary of Northwest Pulp
and Paper Industry, the Board requested that he concentrate his remarks
on industrial practices of ocean dumping.  In this context, he explained
that in the Pacific Northwest, there are a number of major ocean outfalls
that utilize salt water diffusion as an adjunct to land  based treatment
processes.  These a~re continuous discharges, mostly industrial wastes
from the pulp and paper industry.  Included as ocean discharges are out-
falls into Puget Sound.  The bays and inlets of the Sound operate  like
estuaries, but the main body of water is similar in many respects  to the
open ocean.  In the Sound, five major outfalls serve the pulp industry
and three more are being planned.  Several shallow outfalls to the Sound
serve the petroleum refinery industry.  Most of the communities and other
industries along the Sound discharge treated wastes into relatively shallow
discharges.  The State of Washington policy now requires maximum diffusion
and dispersement of such discharges.  The proposed outfalls for the pulp
industry require comprehensive field studies to determine current and wind
patterns utilizing both the drops and sophisticated metering instrumen-
tation.  A new petroleum refinery with a shallow outfall to Puget Sound
has received one of the few Federal permits under the 1899 Refuse Act on
the condition that an unprecedented detailed and intensive biological
and bioassay.monitoring system be established.  The monitoring program
also included computer models of the outfall and receiving water system to
estimate probable impact conditions of wind and tide.  The model includes
functions of nearby outfalls to predict any overlapping of discharges.
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 In  an example cited by Mr. Benson, two pulp mills at Everett, Washington
 solved a serious oxygen depletion and fish passage problem in the 1950s
 by  jointly constructing a 3000 foot outfall and diffuser section to a
 point 300 feet deep in the Sound.  A Federal study in 1967 indicated
 biological damage from this practice, but the mills continue to disagree
 that any substantive harm is resulting from the practice.  Nevertheless,
 Mr. Benson stated the mills were ordered to install recovery equipment
 for the spent liquor being discharged.  One mill has announced that it must
 close and the other is under construction with a $60 million facility.
 Mr. Benson said it is unfortunate that the system required utilizes the
 spent liquor as a fuel with the recovery of sulfur as sulfur dioxide in
 the stack gases.  The mill is located at the downtown Everett Waterfront,
 and through the years a very tight sulfur dioxide control system has been
 developed that meets Federal secondary ambient SC^ standards.  The
 recovery unit will increase the potential SC^ emission from the pulp mill
 complex about five to tenfold.  This will require the installation of
 emission controls well beyond the usual for such mills to meet ambient
 standards.  The net result will be a substantial increase in the emission
 of S02, but below levels that can be expected to exceed ambient standards.
Mr. Benson's point in discussing this example is that interrelated envir-
 onmental decisions were lacking.

 In conclusion, Mr. Benson stated that he had reviewed the CEQ recommen-
 dations for a national policy on ocean discharges and feels that it is a
good one.   However, he offered the following suggestions for modifying
 the policy:

 (1)  The policies relating to specific types of waste should allow for,
     an overall impact analysis to ensure that available alternate
     techniques do not cause even more severe environmental impact in
     all cases.  The policy provides for this with radioactive wastes
     and toxic industrial wastes.

 (2)  The jurisdiction for regulation of ocean discharges should remain
     with the prevailing water pollution control agencies, rather than
     establishing new jurisdictions.

 (3)  Research on ocean outfalls should be greatly expanded as articulated
     by the CEQ policy.   Particular emphasis might be placed on the develop-
     ment of operational biological monitoring techniques and the
     development of computer simulator models for the design and operation
     of outfalls.
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Dr. C. H. Ward, Professor of Environmental  Science  and Biology, Rice
University, Houston, Texas:

Dr. Ward's statement dealt with a review of current dumping practices
off the coasts of New Orleans, Louisiana, and Galveston,  Texas and  a
discussion of procedures used to evaluate impact  of ocean disposal.

Current Dumping Practices:

Dr. Ward stated that dumping in the Gulf has gone on in an essentially
unregulated fashion since World War II.   Records  of the Corps of
Engineers' district offices  in Galveston show that  since 1952, 20 com-
panies have been allowed to  dump off Galveston.   In 1970, five indus-
trial firms were dumping. Today, as far- as is known to the Corps,  no
companies, municipalities, or governmental  agencies are dumping in
Galveston Bay or off shore,  with the exception of dredge spoil resulting
from maintenance of the Houston Ship Channel and  the new construction at
Morgans Point.  All "letters of no objection" (to dumping) to the com-
panies were withdrawn last spring.  Prior to withdrawal of the  five
"letters" the Corps specified that all dumping would occur off  the
continental shelf at depths  not less than 107 fathoms (642 feet).

Dr. Ward reported there have been numerous  reports  since 1958 of shrimp
fishermen netting drums of chemical wastes  in shallow waters  close  to
shore.  In 1970, the New Orleans Corps Office had five "letters  of  no
objection" on record and these letters are still  in effect.  However,
two of the five companies have since voluntarily stopped their  ocean
disposal.  The disposal site designated by the New Orleans Corps  is in
excess of 400 fathoms of water in a 20 square  nautical mile  area about
50 miles south of South Pass off the Mississippi  Delta.  This area  is well
off the Continental Shelf.  Yet, Louisiana shrimpers have also  had  a long
history of snagging drums in shallow waters filled with chemical  wastes.
In citing these several examples, the point made by Dr. Ward is that the
Corps has no jurisdiction or authority outside territorial waters.   They
can not legally issue permits for ocean disposal, only "letters of no
objection".  Violators of the "letters" cannot be prosecuted nor can dumpers
without "letters".  As a consequence, there is every reason to believe
that we have no idea  what is being disposed of in the Gulf,  Dr.  Ward
stated.  He emphasized that the Corps records do not reflect current
practice.  If they did, off shore disposal companies would not be pros-
pering.

Dr. Ward urged congressional action to control off shore  disposal.   Until
Congress provides applicable legislation, he recommended  an immediate
moratorium on dumping on the Continental Shelf.  Nevertheless, Dr.  Ward
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 indicated that he hoped that Congress will  recognize  that  ocean dis-
 posal of some types of wastes,  regulated by proper authority, may for
 the forseeable future, represent the most desirable alternative with
 regard to protection and preservation of the environment.

 Turning to another point, Dr. Ward indicated that  he  does  not know of a
 single published report of an investigation on  the biological effects of
 off shore disposal of wastes in the Gulf.   However, he said there are two
 broad scope research programs in the Gulf that  could  reasonably be
 expected to yield data applicable to,judging biological effects of ocean
 disposal.   Studies in the Texas A§M Sea Grant Program have been limited
 to mechanical and engineering aspects  of handling  dredge and hazardous
 materials  in coastal zones.   The Gulf Universities  Research Corporation
 is conducting NSF sponsored physical oceanography  studies  in Gulf con-
 tinental waters.   In addition,  they are conducting research sponsored by
 a group of oil companies  designed to evaluate environmental effects of oil
 drilling operations on the shelf.   The American Petroleum  Institute is
 funding another group of  biologists to study the effects of oil and oil
 spills on  the physiology  and ecology of marine  organisms.

 In summarizing,  Dr.  Ward  stated that applicable technical  information
 does  not appear to be available nor is  it being collected  in a systematic
 approach.

 Procedure  for Evaluating  Environmental  Impact of Ocean Dumping:

 Dr. Ward indicated that the  procedure  established  for preparation of
 Environmental  Impact Statements under  the National Environmental Policy
 Act  (NEPA)  of 1969 is  too  narrow in scope since NEPA prohibits preparation
 of the EIS  whose  focus is  out of context with the  environmental problem
 and the affected  area.  He pointed  out  that  the Gulf is a  finite resource
 of inestimable value as a  whole functioning  eco-system.  He stressed
 that  the practice of judging the environmental  impact of national policy
 (in this case  dumping) on  finite resources by reviewing individual
 actions under  that policy  must  be stopped.   He  recommended that some
 segment of  the Federal structure should accept  the responsibility to act
 as the lead agency in preparation of an EIS-that addresses the entire pro-
blem  of ocean  dumping.  In conclusion,  Dr. Ward urged the Advisory Board
 to use its  influence to see  that both  the spirit  and the  letter of NEPA
 are adhered to in all questions  relating to water pollution control.


Mr. Donald  L.  Corey, Supervising Sanitary Engineer, Massachusetts Divi-
sion  of Water  Pollution Control, Boston, Massachusetts:

Mr. Corey opened  his presentation by stating that Massachusetts has long
recognized here dependence on the ocean for  food, production,  commerce,
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recreation and other benefits.   Representatives  of the Massachusetts
Division of Water Pollution Control have been engaged, in a continuing
effort to abate probTerns of ocean dumping off the Massachusetts  coast.
This has involved a cooperative effort with other State and Federal
agencies.  Mr. Corey categorized dumping off the Massachusetts coast
into three classes of wastes:  sewage sludge, hazardous wastes,  and
dredge spoils.  He described the policies and plans being implemented
in each of these categories in order to provide  some insight into the
problems which his regulatory agency has faced.   He then summarized what
Massachusetts believes are major considerations  in arriving at a
satisfactory solution.

Sewage Sludge:

At the present time digested sewage sludge is discharged through ocean
outfalls from two major treatment plants in Massachusetts.   The  total
quantity discharged is approximately 30,000 tons (dry basis) annually.
Through two contracts, the Massahcusetts Division of Water Pollution  Con-
trol has developed a mathematical model which, in conjunction with sample
analyses, has shown that the present practice of sludge discharge violates
certain water quality criteria for class SB waters.  Class SB waters
should be suitable for bathing and recreation, including water contact
sports, industrial cooling, excellent fish habitat, good aesthetic value,
and suitable for certain shellfisheries.  The practice of sludge disposal
through ocean outfalls directly interferes with these assigned uses.
Recognizing the inadequacy of these sludge disposal practices, the
Metropolitan District Commission (MDC) engaged a. consultant to study
alternate sludge disposal methods by incineration or other means.
Through a recently executed Memorandum of Agreement between the  Divi-
sion of Water Pollution Control, MDC, the U. S.  EPA and others,  a schedule
has been established for construction of facilities for sludge disposal.
Construction is to be completed by May 1976.  Upon construction  of these
facilities, the State anticipates termination of ocean disposal  of sewage
sludge in Massachusetts waters.

Hazardous Wastes:
A limited program of off-shore hazardous waste disposal is presently
being conducted in Massachusetts Bay.  Wastes include those materials which
because of chemical, flammable, explosive or other characterisitcs, con*-
stutute a danger or potential danger to public health, safety or welfare
to the environment.  Materials presently disposed of include explosives,
reactive metal wastes (i.e., sodium, magnesium, potassium] and chemical
wastes.  Only one contractor is authorized to dispose of hazardous wastes
in this manner since it presently represents the least potential hazard
compared to other alternatives.  However, Mr. Corey explained comprehen-
sive legislation has been passed which would regulate the disposal of such
wastes.  Hearings on the proposed regulations have been announced and the
State intends to have them implemented by the end of 1972.  The regulations
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 will apply to disposal of hazardous  wastes  at  land  sites  as well as in
 off shore areas.   When the regulations are  effective over a 75%
 reduction in the  volume of hazardous wastes dumped  will be achieved.
 The following materials will  continue  to be disposed of at sea under
 State regulation  until suitable alternative methods are developed:

      (1)   Sodium  and other highly reactive  metals and their compounds
           (these  are naturally  present in sea  water, and  land disposal
           may result in conditions dangerous to humans due to the intense
           reaction with water}.

      (2)   Laboratory quantities  (1 liter or less) of chemicals, or
           equipment contaminated with  chemicals, which are not highly
           toxic (disposal  in  sanitary  landfill sewage treatment plant
           or by mixing may produce unpredictable results).

      (3)   Explosives.

Mr.  Corey pointed out that no readioactive  wastes are presently disposed
of  in Massachusetts  waters.

Dredge Spoils:

The most  significant current  ocean dumping  problem  in Massachusetts waters
concerns  disposal  of dredge spoils.  The largest volume of dredge spoils
originates from Federal  harbor  and channel  projects initiated by the
Corps of  Engineers.   The spoils  from many of these  Federal projects are
typically polluted,  Mr.  Corey explained.

Some progress has been made in the last several years to bring this pro-
blem under greater control.  Copies  of applications for dredging permits
are  forwarded by the Corps  to a  number of State and Federal agencies for
review and comment;  environmental  impact statements for Federal projects
are  similarly forwarded  by  the Corps.  The  Criteria for Determining
Acceptability of Dredged Spoil Disposal, which were developed as guide-
lines for the EPA have provided  useful limits on certain chemical parameters
to be checked on each project.

It has been the State's  experience that land disposal of polluted dredge
spoils is impractical in most cases; however, in several small projects
where acceptable land disposal sites have been available this has been
the preferred location.  Mr. Corey detailed some of the needs faced by
regulatory agencies  as follows:

      (1)  The number of  dumping  grounds for polluted dredge spoils and
          the size of such  grounds should be minimized, preferably with-
          in presently designated dumping grounds.
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     C2)  The criteria established by- EPA for dredged spoil disposal
          should be reviewed and revised as appropriate,

     (3)  Effective monitoring of the environmental effects of ocean
          disposal of dredge spoil materials is presently inadequate.
          The monitoring work should include seasonal biological,
          chemical, physical and geological observations  of ocean
          bottom, sea water, nutrients and biota, the character of all
          materials to be dumped and the character of the spoil grounds
          before, during and after spoil discharges should also be
          evaluated.

In summarizing, Mr. Corey outlined the following specific problems in
Massachusetts, but also typical of other coastal areas:

     (1)  Elimination of off shore disposal of certain wastes will
          require substantial financial assistance from Federal and
          State governments.

     (2)  A research and monitoring program for ocean dumping is
          essential in order to rationally determine key criteria
          which must be considered in regulating waste disposal at sea.

     (3)  An overview must be maintained by regulatory agencies to
          ensure that decisions are coordinated and are environmentally
          sound.

Finally, Mr. Corey concluded that State regulatory agencies have exper-
ienced the financial crisis in administration and enforcement of water
pollution abatement laws that all branches of State government currently
face.  Ultimate solution of the overall problems of ocean dumping will
require major applications of funds, new technology and continued dialogue
and cooperation between regulatory agencies at the State and Federal levels.


Dr. Thomas D. Hinesly, Soil Ecologist, Agronomy Department, University of
Illinois, Urbana, Illinois:

Dr. Hinesly spoke on the practices and effects of municipal sludge utili-
zation on land as an alternative to ocean dumping.  In lieu of summarizing
his prepared statement, Dr. Hinesly showed a series of slides illustrating
the effects of sewage sludge disposal on land.  Accordingly, Dr. Hinesly's
entire prepared statemrnt is included in this report as Appendix 3.

An important point emphasized by Dr. Hinesly, is that amounts of sludge
will increase as wastewater treatment facilities are upgraded.  Tertiary
treatment, for example, will retain between 95 and 98 percent of incoming
effluent as fresh sludge.  Instead of incineration, Dr. Hinesly said,
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thousands of acres of land scarred by coal strip mining would provide
more than enough area to receive nutrient rich, treated sludge as  ferti-
lizer
Mr. Kenneth L. Johnson, Director, Air and Water Programs  Division,
Environmental Protection Agency, Region II, New York City:

Mr. Johnson spoke on incineration as an alternative to ocean dumping of
sewage sludge.  As a result of the concern regarding adverse environ-
mental effects which might result from sewage sludge incineration,  EPA
established in June 1971 a Task Force to assess such concerns.   After a
program of testing and evaluation, the Task Force established the  follow-
ing conclusions and recommendations.

     Conclusion 1:  When properly operated, today's sludge  incinerator
     systems, which have been designed to meet exisitng air quality
     standards, have been shown to produce acceptable stack emissions
     of particulate matter, nitrogen oxides, sulfur oxides  and odors.
     Most sludge incinerators which are in existence today, however, do
     not incorporate high efficiency particulate matter control devices.

     Conclusion 2:  Small, but measurable, quantities of specific metals
     which are known to accumulate in the human system, and which  are
     known to be toxic at certain levels, were found in the input  sludge,
     stack emissions, scrubber water, and residue of those  incinerators
     which were subjected to comprehensive testing.  These  same metals
     were also found in each instance  where only the sludge alone  was
     analyzed.

     Conclusion 5:  Small, but measurable quantities of specific organic
     chemical compounds including various pesticides and polychlorinated
     biphenyls, which are known to accumulate in the human  system were
     found in all of the sludge samples analyzed.  It should be expected
     that, under conditions of poor combustion, such compounds could be
     emitted from the stacks of sewage sludge incinerators.

     Conclusion 4:  It was impossible for the Task Force to accurately
     establish the potential for health effects which might be associated
     with sewage sludge incineration because:  Ca) there are insufficient
     health effects data relating to low atmospheric concentrations of
     suspected pollutant materials, and (b) there are insufficient  stack
     gas sampling and analysis methods sophisticated enough to produce
     accurate information regarding quantity, size distribution, and con-
     stituent quality related to size, of the particulate matter emitted
     by sewage sludge incinerators.

     Recommendation 1:  Incineration should be accepted as  an ultimate
     disposal method for sewage sludge, provided that the incinerator is
     properly designed and operated, and provided that controls are
     enforced to minimize the quantities of objectionable materials present
     in the input sludge to the incinerator.
                                   -22-

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     Recommendation 2;  EPA should, immediately,  require  that  juris-
     dictions, which, are to receive Federal construction  grants, possess
     enforceable industrial waste ordinances- designed to  minimize  the
     amounts of objectionable materials introduced into the treatment
     system.

     Recommendation 5:  Federal legislation should be enacted  which
     would control, through a national permit system, all industrial
     liquid discharges.

     Recommendation 4:  EPA should, immediately,  require  that  juris-
     dictions, which are to receive Federal construction  grants for
     facilities incorporating sludge incinerators, guarantee an inciner-
     ator design which will assure the optimum combustion of any organic
     compound present in the sludge.

     Recommendation 5:  EPA should, immediately,  require  that  juris-
     dictions, which are to receive construction  grants for facilities
     incorporating incinerators, guarantee an incinerator design which
     will assure compliance with State and local  air pollution control
     regulations and Federal new source performance standards.

     Recommendation 6:  EPA should engage in research and development
     projects to:

          a.  Accurately assess human health effects of incineration.

          b.  Produce more effective and accurate stack sampling and
              analysis techniques.

          c.  Improve existing sewage sludge incinerator  and pollution
              control designs, with regard to impact upon environmental
              quality.

In summary, Mr. Johnson pointed out that pollutant emissions to  the atmos-
phere from sludge burning should not be considered extraordinary when
compared against the emissions from other combustion processes,  such  as
solid wastes.  Further, he explained that air pollution problems,  especially
in urban areas, are caused by the sum total of many individual sources.
Accordingly, any new particulate matter, even relatively  small ones such
as sludge incinerators, and emissions of heavy metal and  pesticides added
to urban atmospheres should be a cause for concern.

Mr. Johnson concluded by stating that at a time when ocean dumping of
sewage sludge is being phased out, it would be extremely beneficial if
new environmentally sound methods of ultimate sludge disposal could be
developed.  He suggested examination of such potentially beneficial prac-
tices as controlled pyrolysis, perhaps combining a load of sludge  and solid
waste.
                                 -23-

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During the questioning, Chairman Barnes pointed out to the Advisory
Board that in thinking about some of the alternatives  to sludge  dump-
ing we should consider what kind of energy means will  be used and what
impact that may have back in the atmosphere.   Mr. Johnson agreed,
emphasizing that we might solve one environmental problem and create
more.
Dr. Austin N. Heller, Secretary, Department of Natural Resources and
Environmental Control, State of Delaware:

Although not originally scheduled to speak, Dr. Heller requested that
he make a statement before the Board on behalf of Governor Peterson of
Delaware and was granted the time by Chairman Barnes.

Dr. Heller opened his remarks by stating that the probable deleterious
effects of ocean dumping is but a phase of Delaware's broader interest
in protecting its coastal environment.  This led to the passage of
Delaware's Coastal Zone Act of 1971.

Delaware is deeply concerned with the problem of ocean dumping since
such dumping has not been accompanied by valid scientific study and eval-
uation of ecological effects.  The State is also concerned at the lack of
a single, responsible regulatory agency, and Dr. Heller stressed the need
for comprehensive Federal legislation which would provide for a single
national agency to regulate waste disposal in the territorial waters of
the U. S.

Dr. Heller outlined several immediate needs.  The first is for a more
precise knowledge of what man dumps into the sea.  Continuous monitoring
of water conditions would be a second step.  He stated that,  in the inter-
est of safety, one thing that could be accomplished now, would be to dump
sludge in water twice as deep as the present practice.  This, he suggested,
should increase the dilution and reduce the rate and amount of on shore
drift.

Dr. Heller explained the State is experimenting with a project, involving
solid waste reclamation and sewage sludge disposal, which shows considerable
promise.  He described the project as basically a solid waste reclamation
plant capable of separating and recovering the components of  solid waste
in a form which will allow their diversion back into the consumer market,
e.g., humus, glass, paper, carbon, ferrous and non-ferrous metals, and
energy.  The process uses sewage sludge as a diluent.  The mixture of
domestic waste and sewage sludge is shredded, milled, pulped  and digested
by aerobic bacteria in a controlled atmosphere.  One of the products is
a pathogen-free humus-type of material.  The State is hopeful that the
plant will be funded by an EPA grant and become a demonstration plant.
                                   -24-

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Dr. Heller concluded by pointing out that the project  would solve  two
major environmental problems in one plant in a single  process:   Com-
bining biodegradable refuse with sewage sludge to produce a marketable
pathogen-free humus.  He proposed that this would seem to offer a
reasonable alternative to those who are told to stop ocean dumping.
THURSDAY, SEPTEMBER 28, 1972

Before beginning its deliberations, the Advisory Board heard from two
additional speakers.

Mr. Albert Printz, Director, Refuse Act Programs, Office of General
Counsel, EPA:

Mr. Printz provided the Board with a brief status report of the Refuse
Act Permit Program.

From the standpoint of background information, in December 1970,
President Nixon signed Executive Order 11547 establishing an indus-
trial effluent control program based on permits issued under the 1899
Refuse Act.  The program is administered jointly by the Corps of
Engineers and EPA, with the latter being responsible for determining
the permit conditions necessary to maintain the desired receiving
water quality.

Mr. Printz explained the Permit Program received a major setback in the
form of an injunction against issuing permits imposed as the result of
a suit filed in the District of Columbia, commonly referred to as the
Kalur decision.  The lifting of the injunction is contingent upon
revising the Program regulations to provide that (1) permits could not
be issued for discharges into non-navigable waters, and (2) Environmental
Impact Statements be prepared in accordance with the National Environ-
mental Policy Act of 1969.  In considering the appeal, EPA and the Corps
of Engineers took into account the passage of new water legislation
(since enacted) that would bring relief.  In anticipation of the legis-
lation, EPA adopted as a policy the application of the best practicable
control technology currently available by 1976 as a pre-requisite for the
receipt of a permit under the Refuse Act.  EPA then moved into a program
to internally identify what constitutes the "best practicable control
technology currently available" (BPCTCA) for 20 different industries.
In defining BPCTCA, EPA utilized the ground rules set  out in the House
Committee Report, i.e., levels demonstrated on either  the basis of actual
performance, demonstration or pilot studies.  The technical aspects were
discussed with selected representatives of the concerned industry.
                                     -25-

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 The guidance was  then  distributed to the regions and allowed EPA to get
 a major jump on fulfilling  the requirements of the new legislation.  The
 new legislation will require defining not only BPCTCA for many of these
 industrial  sectors, but  also the best available treatment and new source
 performance requirements, Mr. Printz concluded.

 Major General  Richard  H. Groves, Division Engineer, North Atlantic
 Division, Corps of Engineers:

 General  Groves  discussed the responsibility of the Corps in the New York
 Bight area.  He explained that the Corps's primary responsibility is for
 maintaining navigation in U. S. territorial waters and that it operates
 a permit program  for ocean  dumping of dredge spoil under section 13 of the
 Refuse Act.  The  Corps also has had special regulatory authority over
 ocean dumping  for the  port  areas of New York, Baltimore, and Hampton Roads.

 The General emphasized that the Corps realizes its contribution to the
 ocean dumping problem, but  that there are no suitable alternatives
 available to dredge spoil dumping at this time.  For example, dredge
 spoil  could be  hauled  100 miles out to sea and dumped off the Continental
 Shelf, but the  equipment to do this does not exist, and it would increase
 costs;   digested  sludge  and dredge spoil could be spread on land, but this
 also would be very costly.

 General  Groves  concluded by emphasizing that since the Corps' basic
 mission  is to maintain navigation, it would just as soon get out of the
 responsibility  for issuing  permits.

 Following the presentations by Mr. Printz and General Groves, the Board
 devoted  the remainder  of the day to the formulation of conclusions and
 recommendations and also adopted one resolution (Appendix 4).
FRIDAY, SEPTEMBER 29, 1972:

The Advisory Board concluded its meeting with a press conference held at
EPA Region II.  Chairman Barnes opened the press conference by emphasizing
that based on the testimony presented there is marked need to obtain a
much better idea of what is going into the ocean.  He also stressed the
need for better control of toxics and heavy metals.  He placed further
emphasis on the pending legislation on ocean dumping and amendments to
the Federal Water Pollution Control Act.

The Board then presented it Conclusions and Recommendations which are
included in this report as Appendix 5.

The meeting was adjourned at 11:30 a. m.
                                  -26-

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PROGRESS;

Since tfte meeting of tile President's Water Pollution Control Advisory
Board on ocean disposal, Both the Marine Protection Research and Sanc-
tuaries Act of 1972 and the Federal Water Pollution Control Act Amend-
ments of 1972 have been enacted into law and thereby several of the
Board's major recommendations have been implemented.

In addition, the 91-nation Convention on Dumping of Wastes at Sea was
held in London in November.  Agreement was reached on the final text of
an ocean dumping treaty which generally prohibits the dumping of extremely
hazardous material such as radioactive waste, biological and chemical
warfare agents, oil, pesticides, and durable plastics.  Less harmful
materials, auch as lead, copper, scrap metal, and fluorides, could be
discharged only under special permits.  Enforcement and punishment would
be left to individual countries.  The agreement takes effect when
ratified by 15 countries.
                                    -27-

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                                                       APPENDIX  1
          PRESIDENT'S WATER POLLUTION CONTROL ADVISORY BOARD
                September 28, 1972 - New York, New York
SPEAKERS PRESENT FOR PUBLIC MEETING:

Mr. Henry Diamond, Commissioner
N. Y. State Department of
  Environmental Conservation
New York, New York

Dr. John Pearce
Sandy Hook Laboratory
NOAA
Highlands, New Jersey

Mrs. Jean Auer, Member
California State Resources
  Control Board
Sacramento, California

Mr. Jon Lindbergh, Chairman
Oceanographic Commission
State of Washington

Dr. Donald P. de Sylva
Associate Professor of Marine Science
University of Miami
Miami, Florida

Mr. Donald J. Benson
Seattle Metro
Seattle, Washington

Dr. C. H. Ward
Professor of Environmental
  Science and Biology
Rice University
Houston, Texas

Mr. Donald L. Corey, Supervising Sanitary Engineer
Massachusetts Division of Water Pollution
  Control
Boston, Massachusetts

Dr. Thomas Hinesly, Soil Ecologist
Agronomy Department
University of Illinois at Urbana
Urbana, Illinois

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Speakers  (continued):

Mr. Kenneth L. Johnson, Director
Air and Water Programs Division
Region II, EPA
New York, New York

Dr. Austin Heller
Department of Natural Resources
  and Environmental Control
Dover, De1aware
  (Represented Governor Peterson of Delaware)
ENTERED STATEMENT FOR THE RECORD

Senator William V. Roth
Delaware
                                   -2-

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                                                          APPENDIX  2
STATEMENT OP                                    September 2?, 1972
SENATOR WILLIAM V. ROTH
SUBMITTED TO PRESIDENT'S WATER POLLUTION CONTROL ADVISORY BOARD
Mr. Chairman,


       I appreciate your courtesy in allcr.-.-ing me to submit these


remarks for your consideration.  I know you are all busy, and I


thank you for taking the time to read what I have to say.


       My purpose in submitting these rer^arks is, quite frankly,


to ensure that the interests of my small State of Delaware are not


overlooked during your consideration of this problem.  While ocean


dumping concerns all Coastal States, Delavare's interest is, I


believe, more intense for two reasons:  first, because we have


exercised more restraint in the development of our coastal areas  than


some States, we believe Delaware has more to lose than many of our


neighbors; and, second, because Delaware is surrounded by great


metropolitan areas over which we have little or no control, we feel


more threatened.


       As you may know, the Cities of Philadelphia and Camden annually

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                                        William V.  Roth,  Jr., U.S.S.



                                                             -  2  -





 barge about 120 million gallons or treated sewage  to  an  ocean site






 lU miles off the coast of Rehoboth Beach,  Delaware's  principal





 recreation area.  Although the impact of such dumping is scientifically





 undetermined at present,  I personally believe that while doubts remain,





 Delaware should not be compelled to bear the  risk  so  that other States





 can save money by dumping sewage in the nearby coastal waters rather






 than disposing of it through other costlier,  but safer,  methods.  The





 citizens of Delaware have sacrificed  a great  deal  to  preserve our






 coastal  areas,  and we believe  that the off-shore disposal of sewage





 and other waste matter jeopardizes what we  have consciously fought to






 retain:   a  relatively clean and  pure  environment.






         I must  admit that a scientific study  commissioned by the City






 of  Philadelphia purports  to show that  there is no  environmental or






 ecological  damage  as..a result of the City's dumping practices.   But,





 as  far as I am  concerned,  Mr. Chairman,  this  study is  grossly inadequate.






As  a matter of  fact, one  scientist with whom I spoke  (who is associated

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                                       William V.  Roth, Jr., U.S.S.



                                                             - 3 -





with neither Delaware nor Philadelphia, but who is an acknowledged





expert on the effects of ocean dumping) told me' that the study was






"fast and dirty."  Yet, despite its inadequacies,  the study's





results are widely and highly touted as firm scientific proof of





the safety of ocean dumping.  Specifically, Mr. Chairman, I have





these criticisms of the study conducted "by the Franklin Institute:





        The focus of the report was on conditions  in and around the






dump site itself.  The most important conclusion was that the dump





site is almost completely free of sludge.  But for Delaware's






purposes this means only that the material has been swept away by





currents at the dump site; we must know where it goes.

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                                      William V.  Roth,  Jr.,  U.S.S.




                                                             - U -






        Because the sludge dumped, by Philadelphia is highly  resistant






 to further decomposition (it is the residue of attack  by extremely high






 concentrations of bacteria at temperatures  around 100  F.  for about 30






 days)  it is likely to persist in the natural marine environment.   To






 ensure that it presents  no "danger to Delaware, we must know where  it is






 transported by the dump  site currents and its ultimate fate.   These are






 questions  which the study has not considered, but there is  some evidence






 from the study itself, that the  ultimate  fate  of some  sludge  is to be






 washed up  on Delaware's  ocean beaches.






        Page  A-l of the study reports  the  results of sea bed drifter






 recovery.   Since sea-bed drifters move with the  currents within one or






 two feet of  the bottom,  when they are washed up  on shore  their distribution






 gives  a rough  idea  of how  sludge particles  might be  expected  to move.   Of






180 drifters releaced"at the  dump site, 33  (or 18  percent)  were recovered.






The others either drifted  out  to sea or were trapped in low places  or

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                                      William V. Roth, Jr., U.S.S.




                                                            - 5 -








deposition sites between the dump location and the coast.  Some






drifters may be dislodged during storms and washed up at a much later






date, but of the 33 that were recovered, 17 (or 52 per cent) were found






on Delaware's Atlantic Coast; and, 1^ of these 1? were found on the ik






mile stretch between Cape Henlopen and Indian River inlet.  Thus, k3






percent of the drifters recovered were found in an area that includes






some of Delaware's principal bathing beaches.  On page h-2 of the






report, the author states, "There is no specific section of the shoreline






that receives more than its share of drifter recoveries."  Clearly, this






is not so.






       The City of Philadelphia dumps approximately 500,000 tons of sludge






every year.  (Reference page h-1.6 of Report dated February 1972.)






       If we assume (and this correlation is by no means certain) that






the amount of sludge washed up between Cape Henlopen and the Indian River






Inlet is proportionate to the number of drifters washed ashore, then

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                                      William V.  Roth,  Jr.,  U.S.S.




                                                            - 6 -






 39jOOO tons of sludge are deposited along this stretch of beach each






 year,  (if I^/lQO's of the drifters wash ashore  at this point, then






 lU/180's of 500,000 tons of sludge should also come ashore.)  This






 would mean that over 1,000 pounds of liquid sludge per linear foot of






 beach is deposited.   And,  if the  liquid sludge is  10.8 per  cent solids,






 then 108 pounds of solid sludge a year are  deposited on every linear






 foot of beach between Cape Henlopen and the Indian River Inlet.  I






 should add that the  behavior of drifters in the  surf zone can be expected






 to differ from the behavior of sludge  particles.   Therefore,  it is likely






 that an unknown fraction of the 108 pounds  per linear  foot  is  carried






 north toward  Cape Henlopen by the  longshore drift.






        If dumping is  to  continue at the  present  site, we  determine where






 the  sludge  is  going,  since it seems quite likely that an  appreciable






portion moves  toward,shore.   To do  this, we must find some unique chemical






or physical characteristic  of the  sludge, so we  can differentiate it from

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                                      William V. Roth, Jr., U.S.S.




                                                            - 7 -






the natural sediments and trace its movements after being dumped.  Heavy






metal concentrations (i.e. lead, copper, silver) were found to be useful






for this purpose in a similar study in the New York Bight.






       Some work which bears directly on this problem has been carried






out in the College of Marine Studies of the University of Delaware, and






other work is presently in progress.  When we have found a unique






"fingerprint" for the Philadelphia sludge, we can begin to look for it






in a much wider area along the Delaware Coast where sludge particles might






be expected to settle.  In addition, long term current meter measurements






(onthe order of one year due to seasonal current variations) should be made






at and around the dump site to see where the sludge moves when currents






carry it from the site.  If a unique fingerprint for the sludge can be






found, the first part of a study could begin to yield results within






about three months. ,..The current meter study would require at least one
year.
       At present, there is not enough information- about the behavior

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                                     William V. Roth, Jr., U.S.S.




                                                           - 8 -






 of digested sludge in general, and about Philadelphia sludge in






 particular, to assess its danger.   We must know the levels of heavy






 metals, pesticides, and other harmful substances in the sludge, and their






 rate of release in the marine environment.  Further, we must know where






 the majority of the sludge is deposited, and what marine animals  metabolize






 it.   Finally,  the  effects on Delaware's beaches and human users must be






 ascertained if sludge dumping is not  to harm the tourist industry by real






 or  imagined sludge contamination.






        I should point out,  Mr.  Chairman, that I am a layman and the  preceding






 analysis of the Franklin  Institute's  findings v:;is   provided by a  group  of






 scientists  at  the  University of Delaware.   I  have  included this analysis,






not to generate a  scientific dispute, but  to  illustrate  the  pitfalls of






accepting the  conclusions of a  scientific  study merely because it is






"scientific."  I personally  have discussed the  scientific  aspects of ocean






dumping on numerous occasions with men whom I respect highly.   Based on






these discussions,  I am satisfied that until  we  are  able to  obtain conclusive

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                                         William V.  Roth,  Jr.,  U.S.S.




                                                               -  9 -








scientific evidence, ocean dumping practices should  be modified






substantially or halted completely.  Ocean dumping should  certainly






be banned off recreational areas while study is proceeding.






        J could say much more on this subject,  but I know  you all






have great demands on your time.  I appreciate  your  consideration






of my comments.

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                                                            APPENDIX 3







             Practices, Economics, and Effects of Municipal Sludge




                    Utilization on Land as an Alternative




                                to Ocean Dumping






                                 T. D. Hinesly






Factors Contributing to Sludge Handling Problems




     The disposal of wastewater treatment plant residues is the most difficult




and increasingly costly problem confronting major sanitary district staffs.   For




cities of over 50,000 populaton the average per capita suspended solids load at




wastewater treatment plants was found to be 0.25 pounds per day on a dry-weight




"basis (Loehr 1968).  Plants receiving large quantities of industrial waste may




have average per capita loadings approaching twice the average value.  For example,




the Metropolitan Sanitary District of Greater Chicago has an average per capita




loadings of about O.U pounds per day.  It is expected that the average per capita




loadings will increase because the installation of garbage grinders in homes will




augment suspended solids by an average of 60 percent, (American Society of Civil




Engineers Manual,  1959)-  However, at the time Loehr collected his data, only




about 12 percent of the homes were equipped with garbage grinders.




     At present the activated sludge treatment process is most frequently used




for secondary treatment of wastewater.  From the standpoint of suspended solids




removal, the process when preceded and followed by sedimentation, is about 85 to




95 percent efficient.  Eventually, as wastewater treatment facilities are upgraded




to include tertiary treatment processes, the efficiency for suspended solids




removal should be at least 98 percent.  Therefore, it is likely that in the  near




future, somewhere between 95 to 98 percent of the per capita loading reaching




the wastewater treatment plant will be retained as fresh sludges.

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                                       -2-






      Along with the increase in quantities of wastewater given tertiary treatment




 for improved removal of solids, higher priorities are also likely to Toe given to




 reducing phytoplankton nutrients to lower concentrations in effluent.  The removal




 of nutrients will require the addition of chemicals such as the dosing of effluents




 with lime or alum to precipitate soluble phosphates.   Added chemicals which cannot




 be economically regenerated for recycling will add materially to the solids handl-




 ing problems.   Assuming an average wastewater flow of 135 gallons per capita per




 day (Loehr 1968), a chemical dosage of only 50 ppm will  increase the per capita per




 day suspended solids in fresh sludge by 0.05 pounds.




      Considering the trend toward greater usage of garbage grinders, tertiary




 treatment processes, and chemicals for reducing nutrient concentrations in effluents




 an average value of 0.35 pounds per capita per day of solids as fresh sludge would




 appear to be a conservative estimate of production, at least for the larger advanced




 wastewater treatment plants.   For each million population served by sewers, about




 175 dry tons of fresh solids  will be removed from about  135 million gallons of




 wastewater requiring treatment each day.   Therefore,  municipal  sludge handling




 problems will  increase,  even  if our sewered population should remain static.




 Kinds  of Sludges  Generated




     The solids separated from wastewater  during  sewage  treatment  are a complex




 array  of organic  and inorganic residues.   Upon reaching  the wastewater treatment




 plant,  about 60 percent  of the suspended solids load  is  removed by sedimentation.




 The  solids portion  removed by this  sedimentation  is called  primary sludge.  The




 solids  not removed  by the  primary treatment  sedimentation process are transferred




to another tank as  a constituent  of the  effluent where they are mixed with large




 quantities of aerobic microorganisms and large volumes of air.  The microorganisms




use the oxygen  in the air to  convert part  of the organic waste  into carbon dioxide




and water to obtain energy, while converting another large portion into new cells.

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                                      -3-
The portion  of the waste converted into nev microbial cells and collected by




sedimentation after removal from the aeration tank is called activated sludge.




To maintain  a microbe population in the growth phase a portion of the activated




sludge is recycled to the aeration tank, but for the most part it is wasted and




thus often referred to as waste activated sludge.  The primary sludge and the




waste-activated  sludge generated during secondary treatment when taken together,




make up the  fresh sludge discussed above.




     In the  United States many attempts to spread primary or raw sewage sludge




on land have ended in failure.  Waste-activated sludge has been successfully




used as a fertilizer material only after heat drying and then at only light appli-




cations which could be thoroughly incorporated with soil.  Such biologically




unstable materials as primary and waste-activated sludge cannot be spread on land




or lagooned  because of odor and fly problems.  In some of the older literature,




waste activated  sludge is sometimes referred to as aerobically digested sludge.




Waste activated  sludge is highly unstable with regard to further biological




degradation  and  should not be referred to as a digested sludge.  To stabilize




waste activated  sludge sufficiently for land surface application by an aerobic




process would require a detention time of about 20 days (irgens and Halvorson




1965).  Studies  at the University of Wisconsin have demonstrated the adaptability




of an aerobic digestion process to the stabilization of mixtures of raw and




waste activated  sludge (Norman 196l).  Aerobic digestion of primary sludge has




been evaluated by Viraraghenen (1965) for average climatic conditions in the




vicinity of Madras;,  India.




     In the  older literature, discussions regarding sludges from Imhoff tanks are




often confused with those concerned with sludges from heated anaerobic digesters;




both simply  referred to as anaerobic digested sludge by some authors.  While some

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                                       -U-
 degree of anaerobic sludge stabilization is accomplished in Imhoff tanks,  it may
                                                  *
 or may not be comparable to that accomplished in a heated anaerobic digester

 where environmental conditions are maintained near optimum for rapid biological

 degradation of organic sludge constituents.  Lohmeyer (1959)  reviewed the  liter-

 ature pertaining to heated anaerobic digestion and presented recommendations for

 managing digesters to obtain the best overall results with the least difficulty.

 In a later literature review, Pohland (1962)  discussed anaerobic  decomposition in

 terms of two phases which he designated as first,  liquefaction and hydrolysis,

 the second being fermentation and gasification.  A rather heterogeneous group of

 bacteria convert the proteins, carbohydrates, and  lipids contained in the  waste

 largely to fatty acids,  carbon dioxide and ammonia  nitrogen during the first

 stage.   During the second stage strict obligate  anaerobic bacteria convert the

 fatty acids produced during the first stage to methane and carbon dioxide.  Toerien

 and Hatingh (1969) reviewed the literature toward presenting the  current state of

 knowledge about the microbiology and biochemistry of  the anaerobic digestion pro-

 cess and to identify areas  needing further research.   They state  that it seems

 probable that  fungi and protozoa do not play  significant  roles  in the degradation

 of  organic  matter  during  anaerobic digestion.  Andrews (1969) presented a dynamic

 model for the  anaerobic digestion process,  which has usefulness in predicting the

 results  of  changes made in  the operation of digesters.

     The  above  reports regarding aerobic and  anaerobic digestion  processes for

 raw  (primary) and  waste activated sludges are  sufficient to emphasize the attention

 that has been given to organic  waste  stabilization.  Some of the  reasons given for

 stabilization of sludges are that  it promotes  rapid dewatering, reduces the initial

bulk of solids for more economical handling, destroys pathogenic  organisms for

health protection, and noxious  odors are eliminated.  Another most important reason

for stabilization is the elimination of housefly infestations of  stored waste.

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                                     -5-





Apparently the housefly will readily breed in raw, waste activated or partially




digested sludge, "but not in a well digested sludge (Goudey 1932)  (Von Zuben,  et




al. 1951) (Wolf 1955).




     To overcome some of the objectionable characteristics of primary and waste




activated sludge, the use of heated anaerobic digesters have proven to be most




satisfactory and economical (Lynam, et al. 1972).  Heated anaerobic digestion




of sewage solids is used to accomplish two primary objectives. First, about  50




to 70 percent of the organic fraction of sludge solids are biologically converted




to methane and carbon dioxide, reducing the amount of total solids that must  be




handled by about ^0 percent.  After digestion, the organic fraction of the remain-




ing solids is sufficiently stabilized against further biological  degradation  so




the material can be lagooned, dewatered on open drying beds, or applied on the




surface of soils without causing noxious odors or fly breeding problems.  By  anaer-




obic digestion the projected sludge handling problem may be reduced from 175  to




105 dry tons per day per million population.




Cost of Sludge Disposal




     Cost for the incineration of sludges (includes wet-air oxidation, multiple-




hearth, and fluidized-bed) range from 30 to U2 dollars per dry ton as reported




by Burd (1968) and from 50 to 57 dollars as reported by Bacon and Dalton (1966).




Because these estimates were made from data collected several years ago they  are




probably on the low side.  If the greater cost for minimi zing air pollution and




increased .cost resulting from inflation are considered, the cost for incineration




of sludge solids today is probably greater than 60 dollars per dry ton.  Further-




more, incineration does not provide for a permanent solution to the solids




handling problem.  The ash accumulating from the oxidation of fresh sludges




amounts to 30 to 35 percent of the original dry weight and presents some of the same

-------
                                       -6-


 disposal problems as those encountered with the  original material.

      Waste activated sludge has sometimes been heat dried and sold as a low grade

 organic fertilizer.   Dry,  waste activated sludge contains about k to 6 percent

 nitrogen, 3 to 7 percent Pp°c equivalent  and 0.25 to 0.6 percent K?0 equivalent.

 Thus, from the standpoint  of a fertilizer, the inconvenience and cost of supplying

 sufficient quantities of dried sludge  to  satisfy the nutrient requirement of most

 crops is too great to expect an increase  in its  marketability.  Even before it was

 necessary to consider the  installation of equipment to reduce air pollution

 Bacon and Dalton (1966)  reported that  the net cost for disposing of 250 to 300

 dry tons of sludge as a  fertilizer material was  U5 dollars per dry ton.

      Burd (1968)  reported  a cost of 50 dollars per dry ton for drying and apply-

 ing sludge on land and 25  dollars per  dry ton for the application of dewatered

 sludge  on land.   He  also concluded that the cost  for disposal of dewatered sludge

 in landfills  was  about 25  dollars per  dry ton.   Cost estimates for permanent

 lagooning of  digested sludge  range from 12 (Burd  1968) to ^9 (Bacon and Dalton

 1966) dollars per dry ton.  A number of variables determine the actual cost of

 land  disposal schemes but the major variables are the initial cost of land and

 distances sludge  must be transported from the wastewater treatment facility to

 the disposal  site.  Whether sludges are applied on or near the soil surface,

 dumped  in landfills or held in lagoons all are aesthetically unacceptable be-

 cause,  if for no  other reason, the land is  condemned to a singular  low degree of
 usage.
     In the last  few years a  great deal of attention has been given to the old

 idea of utilizing digested sludges as a source of nutrients to grow crops and

 as a soil  amendment to .ameliorate physical  conditions in severely disturbed

lands that adversely affect the establishment and growth of plants.   It is not

 nvisioned that disposal by utilization can be carried out without cost to the

sanitary district.  On the otherhand,  contrary to strictly land disposal schemes,

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                                      —T—





it is envisioned that the solids will "be utilized in such a manner that land




usage is either not changed or in the case of land reclamation the number of




alternative land uses are increased.  In 1968, members of Harza Engineering




Company estimated the cost for pumping digested sludge containing 3 to 5 per-




cent solids a distance of about 50 miles and distributing it on land in amounts




just sufficient to supply the nitrogen needs of nonleguminous plants.   On the




bases of a 6 percent interest rate and amortization of all construction costs




over 50 years, and including maintenance and operation of the sludge distribution




equipment, they estimated the cost for sludge disposal by agricultural utilization




to be 22.30 dollars per dry ton.  Wirts (1956) estimated the cost for pumping




digested sludge to be 10 to 15 cents per ton mile.  He pointed out that cost




depends on the tonnage pumped and suggests that a connected population of 2




million people is an economical starting point for considering pumping distances




of 50 to 100 miles.  At the present time, sludge is being transported from the




Metropolitan Sanitary District of Chicago wastewater treatment plants to an




agricultural utilization site 160 miles downstate by a unit train.  The unit




train contains 30 tank cars, each having a 20,000 gallon capacity.  By another




contract,sludge is being barged 180 miles from Chicago to a land reclamation




site.  While transportation costs vary with the solids content of the digested




sludge they have generally ranged from 30 to 35 dollars per dry ton during these




short period  (3 years) rail and barge haul contracts.  With a continuous or sus-




tained operation, transportation cost by rail and barge could be considerably




reduced.  On a sustained operational basis it does not appear unreasonable to




consider transportation distances of 200 miles from large municipal waste treat-




ment facilities when contrasted to cost for alternative methods of sludge disposal.




Land Requirements




     If all municipal waste waters generated in the continental United States

-------
                                       -8-





 were given secondary treatment and the resulting solids  stabilized  for utiliza-



 tion as a fertilizer and soil amendment about  10 to 12 million dry  tons of  solids



 would be available each year.  The utilization of the  solids  in amounts just



 sufficient to meet the needs of nonleguminous  crops for  supplemental nitrogen



 would require an annual application of about 10 to 15  dry tons per  acre.  Thus,



 not more than one million  acres of land would be required  at  any one time  to




 utilize the total continental United States production of sludge solids.  Only



 enough sludge solids would be available to treat slightly more than 0.2 percent



 of the 1|65 million acres of cropland or slightly less  than  0.06 percent of  the



 total 1,90*1 million acres contained in the continental United  States.  However,



 because of its potential as a source of sorely needed  stable organic matter,



 municipal sludge exhibits its greatest value as a resource  when used as an  amend-



 ment  for the reclamation of surface-mined lands.   Since  over 0.5 million acres



 of land strip-mined for  coal prior to 1.96k already exists in various states of



 devastation,  while  another  0.5 million acres have been or will be stripped  during



 the 20-year period  from  196U to  1981*,  there is  no scarcity  of  land which needs



 the nutrients and organic matter supplied in sludge.   About 30 percent of the



 country's population are within  economical sludge pumping distances to land strip-




mined  for coal in Illinois,  Indiana,  Kentucky,  Ohio, West Virginia  and Pennsylvania.



     Those who express concern about  the  contamination of soils  with constituents



of municipal  sludges probably are  not  aware of  the relatively  small amount  of land




needed.   Confusion  often exists between land requirements for sewage effluent




disposal  of renovation and that  needed for solids  utilization.




Criteria  for  Selection of Sludge Utilization Sites




     For utilizing digested  sludge as  & soil amendment and fertilizer, the follow-



ing criteria for  site selection are recommended  (a)  The site should be located

-------
                                    -9-






where utilization of the sludge offers maximum benefits to the local agricul-




tural economy, consistent with reasonable costs to the particular sanitary




district.  The local populace must be able to veigh the benefits to be realized




from the sludge utilization program against the assumed or real stigma attached




to an area that becomes the receptor of waste from a large municipality.   People




living in areas devastated by surface mining activities readily recognize the




benefits to be realized by utilization of digested sludge to reclaim land.




(b)  To ensure that sludge applications are made under uniformly controlled




conditions the land must be susceptible to purchase or long term lease by the




sanitary district,  (c)  To minimize sludge distribution cost all lands in the




site should be contiguous, at least to the extent that the disturbance to exist-




ing residents is minimal.  Surface mined lands offer the best possibilities for




obtaining large contiguous acreage.  There is little or no disturbance of




existing residents, because this occurred during the stripping process.  It is




envisioned that much of the land will be repopulated with farm operators as the




land is reclaimed to a high state of productivity,  (d)  Soil depths should not




be less than six feet to permeable bedrock.  Water tables should be capable of




being maintained to average depths of at least 6 feet from the soil surface.




Such minimum soil depths, with good management practices, will provide protection




from ground water pollution,  (e)  Land slopes should not be so steep as to




prohibit the establishment of water management and erosion control structures at




a reasonable cost.  Slopes up to 18 percent may be acceptable where "push-up"




terraces with permanent vegetated or sodded back slopes can be established.  Un-




consolidated geological materials must be sufficiently deep to bedrock in the




borrow area so that after terrace construction a minimum 6 foot depth to bed-




rock is maintained.

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                                      -10-


 Envlronmental Benefits and Public Health Protection

 1.  Chemical and Physical

     In Table 1 some average concentration values are presented for several chemical

 elements found in digested sludge from the Calumet and Stickney wastewater treat-

 ment plants.  Sludges from both of these treatment plants have been used in the

 research conducted during the last five years by members of the Agronomy Department,

 University of Illinois.
       Table 1.   Composition of anaerobically digested sewage sludges  from
                 MSD of Chicago, Calumet and Stickney treatment  plants.  Samples
                 obtained during 1971 (Calumet late  in year).
   Element
                                               Means  (Wet Weight)
Calumet
Stickney
Cd ppm
Mn "
Ni "
Zn "
Cu "
Cr "
Fe "
Pb "
Hg "
Na "
P "
Ca "
Mg "
K "
N %
% Solid
% Volatile
3.0
8.0
3.0
83.0
16.0
26.0
726.0
16.0
0.063
98.0
757.0
963.0
180.0
195-0
0.09
2.05
58.0
lU.O
18.0
15.0
223.0
67.0
19^.0
2100.0
75.0
0.275
131.0
1141.0
1289.0
48U.O
390.0
0.156
4.36
48.0
    Anaerobically digested sludge, as it comes from digesters, contains 3 to 5 per-

cent solids as finely divided and dispersed particles.  It looks like crude oil

and has an odor which many people describe as earthy or tarry.  It can be easily

-------
                                      -11-





transferred by pipes using ordinary pumping techniques and equipment.  When applied



 to cropland at the rate of 2 inches per acre,  it will supply all of the major



 essential nutrients, including the folloving:   200 to 350 pounds of ammonium nitro-



 gen per acre; about the same amount of organic nitrogen  some of which will be



 slowly released in a form available to crops;  250  to ^50 pounds of phosphorus, of



 which about 80 percent is in the organic matter; and kQ  to 80 pounds of potassium.



 Sulfur will also be supplied in amounts adequate for crops.  The amounts of calcium



 and magnesium supplied will exceed the average annual losses of these elements by



 leaching in humid regions.



     High application rates of digested sludge  on cropland can cause obvious nitrate



 problems.  To determine maximum sludge loading rates on  soils, total and soluble



 nitrogen contents must be known.  The soluble  nitrogen in anaerobically digested



 sludge is in the ammonium nitrogen form, but under proper soil aerobic and temper-



 ature conditions it is rapidly converted to- mobile nitrate-nitrogen.  Thus, the



 loading rate of sludge on cropland is limited  by the amount of soluble nitrogen



 plus an annual mineralization of about ^ percent of the  organic nitrogen supplied



 by sludge applications.  If loading rates are  based on the amount of nitrogen



 furnished to meet crop needs and losses by volatilization, soluble phosphorus



 applications will also be at low enough levels that phosphorus will not present




 a eutrophication threat to water supplies. When sludge  loading rates are based



 on safe nitrogen application rates the capacity of most  soils other than sands to



 inactivate phosphorus by adsorption and conversion to sparingly soluble precipitates



 or compounds is great enough to maintain phosphorus levels in drainage water to




 less than 1 ppm.



     When the main objective is land reclamation, sludge  loading rates may be con-




 siderably greater because disturbed lands generally have small or nonexistent




 organic nitrogen reservoirs.  The amelioratory effect of organic matter on the

-------
                                        -12-





 physical properties of soil materials may make it desirable to increase  sludge




 loading rates on marginal or severely disturbed lands above those recommended for




 productive agricultural lands.  However, as the highly stabilized sludge organic




 matter accumulates in soils with succeeding applications, the  slow mineralization




 of organic nitrogen must be taken into account to prevent excessive losses of




 nitrate nitrogen to water supplies, within or adjacent to the  treated areas.




      Many toxic and nontoxic organic waste materials  occurring as constituents of




 sludge arise as discharges from industrial processes  such as the chemical production




 of textiles, plastics,  Pharmaceuticals, detergents, and pesticides.  After a period




 of acclimation, some organic toxic substances,  such as phenols and formaldehyde,




 can be almost completely removed from wastewater  by biological treatment, even




 though at sufficiently  high concentrations they are bactericidal (Jackson & Brown




 1970).   Others, which are nonbiodegradable under  aerobic conditions, may be removed




 from effluent with or by absorption on sludge sediments and later biologically




 degraded during anaerobic digestion of the solids.  Of all  the organic materials,




 polychlorinated biphenyls (PCB's)  have been of  greatest concern to those involved




 with municipal waste utilization.   Many sludges contain 1 to h ppm or more and like




 other chlorinated  hydrocarbons,  PCB's are  only  very slowly  degraded by micro-




 organisms.   Where  we have applied  115 dry  tons  of digested  sludge a small increased




 concentration of PCB's was  found  in the soil but they were not taken-up in




 detectable concentrations in soybean and corn plant tissues.   Since bacteria are




 the  first group of soil microorganisms to  be decreased by abnormally high concen-




 trations of  chlorinated hydrocarbons we have made total counts  from soil samples




 collected from plots  which have  been treated with up to 136  dry tons of  sludge




 over  a period of k years.  Total bacteria  populations  were  found to be higher in




 soils treated with sludge.  The  positive correlation between total bacteria and




amounts of applied sludge was highly significant.  It  appears that sludge applica-




tions have modified the soil environment in  a manner that favors the maintenance




of a highly active population of bacteria resulting in  a greater rate of pesticide




degradation than might be expected  in  soils  not treated with sludge.

-------
                                       -13-



     Heated anaerobically digested sludge is outstanding in its ability to in-


 crease the humus content of soils.  For example, in 19^1 a study was initiated at


 the Rothamsted Experiment Station in England to compare the effects of four types

                                                                   (Mann,  et al.  1962)
 of organic manures with inorganic nitrogen fertilizers on market-garden crops/(25).


 The organic manures were farmyard manure, digested sewage sludge, a compost of


 straw and farmyard manure, and a compost of straw and sewage sludge.  Each of the


 organic manures was applied at the rate of 15 and 30 tons per acre per year.  After


 nine years, nitrogen in the top 9 inches of soil was 0.088 percent where inorganic


 nitrogen, the familiar fertilizer source, had "been applied as compared to a value


 of 0.089 for control plots.  At application rates of 15 and 30 tons per acre per


 year of digested sludge, the nitrogen content in the soil surface was 0.176 percent


 and 0.2ifT percent respectively.  These data indicate that the amounts of nitrogen


 in the sewage-sludge plots increased about three times as much as in the correspond-


 ing plots treated with farmyard manure and compost made from straw and farmyard


 manure.  The surface soil in sewage-sludge treated plots contained about 50 percent


 more nitrogen than plots treated with equivalent amounts of compost made from straw


 and sewage sludge.  Following the first nine years, treatments between 1951 and


 I960 with digested sewage sludge produced only a slight increase in soil nitrogen


 percentages.  However, nitrogen contents remained at a considerably higher levels


 in sewage-sludge treated plots than were obtained with either farmyard manure or


 compost.


     In I960, Jansson (i960) investigated some specific properties of the humus


 fraction of fresh cow dung, well-rotted farmyard manure, and digested sewage sludge.


He found that the size of the lignin-like complex in farmyard manure and digested


 sludge was somewhere between fresh plant residues and developed soil humus, but


fresh cow dung was similar to fresh plant residues.  Jansson stated that "the


oxidation rate of the farmyard manure and the sludge is similar to that of the


humus of an acid podzol" (acid forest soil).

-------
                                       -Ill-





      More recently we have found that 136 dry tons per acre of anaerobically




 digested sludge incrementally applied during four years on Blount  silt loam soil




 increased its organic carbon content from 1.2 to 2.U percent in the  surface 6




 inches.  Furthermore, ve have found that the humic-acid extracts from heated




 anaerobically digested sludge gave an infrared spectrographic pattern that was




 similar to that of extracts of the natural organic matter  contained  in an Elliott




 silt loam soil (1971).




      Lunt (1959) reported that digested sludge had a very  favorable  effect on




 several soil properties.   He reported a moderate increase  of 3 to  23 percent in




 moisture holding capacity, non-capillary porosity, and cation exchange capacity




 following the incorporation of digested sludge into soils.   Furthermore, he found




 an increase in soil aggregation ranging from 25 to 600 percent which could be




 attributed to the digested sludge additions.




      The results of the  studies described above indicate that the  organic material




 produced in a 15-day heated anaerobic  digestion process has  properties very close




 to that  of natural soil organic matter or humus.   Digested  sludge  is one of the few




 materials that  can be used to  effect a rapid  increase in the humus content of soil.




 It is the only substance with  these properties  that  is  available in  quantity.




      To  reestablish soil organic matter contents  in severely disturbed or eroded




 lands to levels  equivalent  to  those characteristic of productive soils will take




many  years under normal cultural practices.   For  example, in nature the time




necessary to build up soil  organic matter profiles to a point  of equilibrium with




its environment has been estimated to be /Less than 200 nor more than 1,000 years




from  studies conducted on soil  profiles in Columbia  and California/U-950)•  Consider-




ing the  importance of soil  organic matter  as  a  storehouse of slowly available plant




nutrients, a source of cation exchange  capacity,  and a promoter of stable soil




structure, two centuries is too  long to wait  for  natural processes to build up

-------
                                      -15-


the soil organic matter levels in unproductive lands while we seek ways to dispose

of a material which can be used to effect a beneficial, immediate change.

     Some waste treatment plant sludges contain higher concentratons of chromium,

zinc, copper, lead, nickel, mercury, and cadmium than are found in typical agricul-

tural soils.  Berrow and Webber (1972) reported the results from analyses  of U2

sewage sludges collected from rural and industrialized city wastewater treatment

plants in England and Wales.  On a dry matter basis they found the sludges contained

consistently greater concentrations of silver, bismuth, copper, lead, tin  and zinc

than are present in typical agricultural soils.  In a small number of sludges, boron,

cobalt, molybdenum, chromium and nickel were present in sludges at greater  concentra-
                             i
tions than found in typical soils.  They correctly point out that the amount of

trace element present in soluble or available form is more important in relation

to uptake by plants than is the total content.  Thus, they assessed the solubility

of several trace elements by extracting with 2.5 percent acetic acid.  In  Table 2

their extractability data and some of ours are presented by decreasing solubilities

of several elements.  It would appear from these data that we must be mainly concerned

with first six elements presented in Table 2.

     Table 2.  Trace elements extracted by 2.5 percent acetic acid from ^2
               sludges in England and Wales (Berrow and Weber 1972).
Element

*Cd
Mn
Ni
Zn
Co
**B
Cu
V
Cr
Fe
Pb
Mo
Sn
Mean
Content extractable


lUU
300
190
15^0
8.8
10
96
3
22
650
20
0.12
0.58
Mean soluble %
of total content
matter

65
56
U6
UU
32
25
6.9
U.8
3.1
2.8
2.8
1.9
0.5
       * Unpublished 0.1 N HC1 data
      ** Hot water extractable

-------
                                       -16-





      On the "basis of total and extractable concentrations  of trace elements in



 sludges, Berrow and Webber speculate that where sludges  are  used  over a period



 of several years to fertilize crops some of the accumulating trace elements may



 give rise to toxicity problems in plants.  From the  results  of chemical analyses



 of samples collected from soils contaminated-with trace elements by air pollution



 and the use of municipal compost and sludges,  Purves (1972)  speculates that a



"general enhancement of the level of potentially toxic trace  elements in plants



 grown in urban areas could lead to deleterious effects both  on the plants and on



 the health of those eating them."  During five years of  research  using digested



 sludge we have not yet created trace element toxicities  in various feed grain



 and forage crops nor have levels of any element increased  in plant tissues to the



 extent that they would present a hazard to animals consuming the  produce.  Further-



 more,  LeRiche (1968) analyzed soils and crops  from a market  garden experiment at



 Woburn, England where 568 tons of sludge per acre had been applied between 19U2




 and 1961.  While there was an  increase in the uptake  of some  elements by vegetable



 crops  grown on the sludge-treated plots, as can be seen  in Table  3 from the aver-



 age values of his reported results, he reported that there was no evidence that




 crop yields were affected.



     The behavior of such trace elements in soils and their uptake by crop plants



 are influenced by several factors.   One of these is  soil pH.  Most heavy metal




 toxicities in terrestrial plants have been associated with pH of  less than 5.



 Liming  soils can,  to a large  extent,  control the uptake of many trace elements.



     Practices which promote  better soil aeration, such as drainage and structure



 development  may lead to decreased solubilities  of some trace  elements.  According




 to Jenne (1969)  oxides of iron  and manganese act as  "sinks" for heavy metals and



 the extractability or  leachability of the metals is  determined by the Eh (reduction-




 oxidation potential) and pH of  the  system.   Keeping the iron  and manganese hydrous

-------
                                 -163-
Table 3.  AVAILABILITY OF TRACE ELEMENTS AND THEIR UPTAKE BY VEGETABLE
          CROPS GROWING ON A SOIL TREATED WITH 568 TONS/ACRE OF SEWAGE
          SLUDGE  (LeRiche, 1968, Harpenden, England)
                                   	Parts per million (dry matter)	

SEWAGE [If
0.5N ACETTC
ACID EXTRACTABLE SOIL TREATED
1959 UNTREATED
Co
-
_
-
Cr
4.5
2.5
2.8
0.5
Cu
18
22
20
5.0
Mo
-
.
-
Ni
51
49
17.5
4.3
Pb
3.5
3.0
5.0
1.2
Zn
750
850
395
87.5
                                 -Parts per million (dry matter)-

TOTAL LEEKS TREATED
CONTENTS 1960 UNTREATED
p, TREATED
GLOBE 8 UNTREATED
CONTENTS 196Q H TREATED
§ UNTREATED
pn TREATED
g UNTREATED
CONTENTS 1961 H TREATED
§ UNTREATED
ctf
Co
0.16
0.18
<0.1
<0.1
<0.1
(0.1
0.35
0.38
0.02
0.03
Cr
0.54
0.71
1.0
0.9
0.8
0.3
3.00
1.70
0.03
0.09
Cu
16.0
5.75
10.0
9.0
18.0
11.0
8.3
4.3
9.5
9.5
Mo
1.10
0.50
0.7
0.5
0.3
0.1
0.98
0.38
0.28
0.40
Ni
6.95
2.0
16.5
3.2
13.0
1.7
5.25
1.70
0.58
0.25
Pb
1.60
1.15
2.6
2.4
1.6
0.9
2.60
2.80
0.19
0.25
Zn
135
46
510
219
250
103
270
90
28
30
                                     -Parts per million (dry matter)-

0.5N ACETIC SOIL TREATED
ACID EXTRACTABLE 1967 UNTREATED
TREATED
TO?8 UNTREATED
TOTAL CARROTS
CONTENTS 1967 TREATED
ROOTS UNTREATED
Co
„
-
<0.08
0.06

<0.05
<0.05
Cr
2.6
0.9
0.88
0.41

0.07
0.03
Cu
58
14.5
9.9
8.2

4.6
6.3
Mo
_
-
0.85
0.58

0.12
0.13
Ni
8.1
3.4
3.00
1.14

2.00
1.45
Pb
4.2
1.6
1.7
1.09

0.07
0.06
Zn
275
84
99
48

42
34

-------
                                      -17-


oxides in soils and sediments in the form of thin coatings on silicate minerals

instead of discrete crystalline minerals permits a chemical activity in  far

greater proportion than would be expected on the "basis of their concentrations

alone.  As the solubilities of iron and manganese compounds are increased by

reducing conditions the heavy metals originally adsorbed on the surfaces of  their

oxides are displaced by hydrogen and the metals become more mobile in soils.

     Some heavy metals may form inert and insoluble compounds with clays and
                 Thus
organic compounds./many trace elements are less available to growing plants  than

the total concentrations of these elements would indicate.

     When grown on the same soils, tissues from different crop species,  and  even

different varieties of the same species, differ markedly in concentrations of

nutrient and pollutant elements (Gabelman, 1970).  The selection of crops thus

affords a control over the entrance of undesirable amounts of trace elements into

food chains.  With regard to selection, Gabelman says, "The ease of discovery of

these genetic differences within species has been surprising.  We have been  too

conservative in assessing this potential."

     Perhaps we have not observed trace element toxicities in plants by  the  use

of stabilized sludge because it may contribute toward establishing a better  balance

of nutrient availability and uptake by crop plants.  We have learned from green-

house and other studies that there are many synergistic and antagonistic inter-

actions between various ionic metal species in sludge and soils affecting the

absorption of chemical elements by plant roots and their translocation within

plants.  As we learn more about interaction effects, we may be able to decrease

abnormal uptake of one trace element from soils by supplying another to  the soil

or crop.

     Clearly if or when a trace element problem does occur as a result of utilizing

municipal sludges as a fertilizer and/or soil amendment, there are management

-------
                                       -18-





 practices available which can be introduced to alleviate the situation.   Except




 perhaps in coarse sandy textured soils the heavy metals will move very little




 with percolating water.  Thus, most of the trace elements will remain at  the




 point of application unless they are transported away in an       adsorbed phase




 on eroded sediments.  By establishing erosion control structures and practices,




 complete control can be maintained over all elements applied on land as a con-




 stituent of sludge except some anion and anion forming species such as nitrate,




 sulfate, chloride, boron, etc.  At any rate those chemical elements which present




 the greatest potential hazard to animals will be retained in place and can be




 managed if the need develops.  To a large extent the opportunity to manage trace




 elements is lost once they are disposed of in water environments.




 2.   Biological




     Although no incidence of  disease  is  known to have been traced to the use of




 digested sludge as a fertilizer  or  soil  amendment,  it is  still one  of the greatest




 sources  of  concern for many.   From  a  rather  extensive literature it appears that




 most of  the  intestinal bacterial pathogenic  are  either destroyed or their popula-




 tions are reduced  to very low levels  by  heated anaerobic  digestion of sewage solids.




 Results  from several studies  indicate that the pathogenic organisms of tubercle




 bacillus, Taenia saginata, Ascaris  lumbricoides  and hookworm are not destoyed as




 rapidly  in a  heated  anaerobic  digester as are  the commonly used pathogenic indicator




 organism,  Escherichia coli or fecal  coliforms.




    One  of the most  crucial questions which  could not be answered from a search of




the literature was that of the fate of viruses during the anaerobic digestion of




 sewage solids.  Even if viruses were not recovered from digested sludge, one could




not be sure that they were not present in an adsorbed phase on the solids.  To




answer the question regarding the survival of viruses in the heated anaerobic




digester environment we initiated some laboratory studies using a swine enterovirus




 (ECPO-1) which has bio-physical properties similar to human enteric viruses.  After




gas production had stabilized in 6 laboratory  scale digesters, fed with a  mixture

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                                       -19-





of primary and waste activated sludge, they vere inoculated with 10  plaque form-



ing units of the swine virus.  After inoculation, 20 ml of fluid was periodically



withdrawn from the digesters and mixed with milk and fed to germ free piglets.



The feces from the piglets was then collected and assayed for the viable virus.



The viruses were not found in the feces of piglets fed sludge material which had



"been inoculated and digested for a period of time of 5 dajs or longer (Meyer, et  al.



1971).  It thus appears that a lU day heated anaerobic digestion period would



provide a considerable margin of safety with regard to the destruction of viruses.



    As Berg (1966) suggested, perhaps the simplest method for reducing viruses



and other pathogenic organism ;in sewage is by long storage of the material.  From



laboratory studies Berg (1966) determined the time in days required for a 99.9



percent reduction in the number of virus and bacteria by storage at different



temperatures.  The die-away data presented in his Table 5 is exhibited here as



Table 1*.  On the basis of these and other data it appears that an additional



margin of safety against pathogenic contamination of the environment could be



achieved by holding digested sludge in reservoirs for a minimum period of two



months before it is applied on land.




     After sludge is applied on the soil surface, die-away of many pathogenic




organism will occur fairly rapidly as seen from the data in Table 5.  The rapidity



with which fecal coliform die-away occurs after digested sludge is applied on



soil surfaces can be discerned in Table 5.  Furthermore, it has generally been



concluded that wastewaters percolating through unsaturated soil materials are



purged of pathogenic organisms within the first five foot depth (Butler, et al.



195U).  If this is true for wastewater applications it would surely be applicable




in the case of sludge utilization.  Since sludge solids are rapidly filtered and




clog the surface of soils, the rate of water infiltration during sludge applica-




tions is exceedingly low in comparison to that from wastewater applications.

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                           -19a-
Table 4.  Effect of Storage:  Laboratory Study Demonstrating
          Days Required for 99.9% Reduction of Viruses and
          Bacteria in Sewage (Berg, 1966)
                                          No. of Days
                                        Temperature ° C
Organism                            4°         20°        28C
Poliovirus 1
Echovirus 7
Echovirus 12
Coxsackievirus A 9
Aerobacter aerogenes
Escherichia coli
Streptococcus faecal is
110
130
60
12
56
48
48
23
41
32
• •
21
20
26
17
28
20
6
10
12
14

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                            -19b-
Table 5.  Disappearance of fecal coliforms in the sludge cake
          covering a soil surface.
Days after sludge                No. of fecal coliforms per gm
   application                    sludge cake (dry weight)
       1                                 3,680,000

       2                                   655,000

       3                                   590,000

       5                                    45,000

       7                                    30,000

      12                                       700

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                                  -20-





 Therefore,  frequent  applications  of  sludge  can be made only when the evapo-




 transpiration potential  is  relatively high.  That is to say, sludge is most




 likely to be  applied on  agricultural lands  during the late spring, summer, and




 early  fall  seasons when  evapotranspirational potentials generally exceed actual




 soil moisture losses.  For  the most  part  sludge will be applied when ambient




 temperatures  favor a rapid  die-away  of bacterial and viral pathogenic organisms.




     Like many of the potential chemical  water pollutants, lateral movement of




 pathogenic  organisms which might  survive  the digestion and storage period, can




 occur  only  if excessive  soil erosion processes are permitted to operate on the




 sludge utilization site.




 Conclusion




     Stabilized municipal sludges can be  beneficially utilized as a fertilizer




 and soil amendment.  With proper  selection and/or modification of the utilization




 site to ensure that  sludge constituents are not eroded from the point of applica-




tion, adjustment of  sludge application rates to crop requirement for the soluble




nitrogen supplied, and the establishment  of sound crop and soil management practices




 stabilized  sludges are a resource too valuable to be dumped in oceans, burned, or




permanently lagooned.

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                                  References


Andrews, J. F. (1969).  "Dynamic Model of the Anaerobic Digestion Process,"
     Proc. Amer. Soc. Civil Engi., Sanit. Engi. Div., SA1, p. 95.

ASCE (1959).  "Sewage Treatment Plant Design," ASCE Manual of Engineering Practice,
     No. 36, p. 6.

Bacon, V. W. and F. E. Dalton (1966).  "Chicago Metropolitan Sanitary District
     Makes No Little Plans," Public Works 97, p.  66.

Berg, G. (1966).  "Virus Transmission by the Water Vehicle.  II.  Virus Removal
     by Sewage Treatment Procedures," Health Library Science 2 (2), p. 90.

Berrow, M. L. and J. Webber (1972).  "Trace Elements in Sewage Sludge," Journ.
     Sci. Fd. Agric. 23, p. 93.

Burd, R. S. (1968).  "A Study of Sludge Handling  and Disposal," Fed. Water Pol.
     Control. Admin., Pub. WP-28-4.

Butler, R. G., G. T. Orlob and P. H. McGauhey  (1954).  "Underground Movement of
     Bacterial and Chemical Pollutants," Journ. Amer. Water Works Assoc., 46 (2),
     p. 97.

Gabelman, W. H. (1970).  "Alleviating the Effects of Pollution by Modifying the
     Plant," Hort. Science 5, p. 16.

Goudey, R. F. (1932).  "New Thoughts on Sludge Digestion  and Sludge Disposal,"
     Sewage Works Journal, 4 (4), p. 609.

Irgens, R. L. and H. 0. Halvorson (1965). "Removal of Plant Nutrients by Means,
     of Aerobic Stabilization of Sludge," Applied Microbiology, 13 (3), p. 373.

Jackson, S. and V. M. Brown (1970).  "Effect of Toxic Wastes on Treatment Pro-
     cesses and Watercourses," Water Pollution Control 69, p. 292.

Jansson, S. L. (1960).  "On the Humus Properties  of Organic Manures," Kungl.
     Lantbr. hogsk. Ann. 27, p. 51.

Jenne, E. A. (1968).  "Controls on Mn, Fe, Co, Ni, Cu, and Zn Concentration
     in Soils and Water:  the Significant Role of Hydrous Mn and Fe Oxide,"
     Advances in Chemistry Series, Amer. Chem. Soc., p. 337.

Jenny, H. (1950).  "Causes of the High Nitrogen and Organic Matter Content of
     Certain Tropical Soils," Soil Sci. 69, p. 63.

LeRiche, H. H. (1968).  "Metal Contamination of soil in the Woburn Market-Garden
     Experiment Resulting From the Application of Sewage  Sludge," Journ. of
     Agriculture Science 71 (2), p. 205.

Loehr, R. C. (1968).  "Variations of Wastewater Quality Parameters," Public
     Works, May.

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                                        -2-


 Lohmeyer, George T. (1959).  "A Review of Sludge  Digestion," Sewage and In-
      dustrial Waste, 31 (2), p. 221.

 Lowe, W. (1970).  "The Origin and Characteristics of Toxic Wastes, with Par-
      ticular Reference to the Metal Industries,"  Water Pollution Control,
      69, p. 270.

 Lunt. H. A. (1959).  "Digested Sewage Sludge  for  Soil Improvement," Conn. Agri.
      Exp. Sta. Bull. 622, p. 30.

 Lynam, B. T., Ben Sosewitz and T. D.  Hinesly  (1972).  "Liquid Fertilizer to
      Reclaim Land and Produce Crops," Water Research 6, p. 545.

 Mann, H. H. and H. D.  Patterson (1962).  "The Woburn Market-Garden Experiment:
      Summary 1944-60," Report of the  Rothamsted Experiment Station.

 Meyer, R. C., F. C. Hinds, H. R. Isaacson and T.  D. Hinesly (1971).  "Porcine
      Enterovirus Survival and Anaerobic  Sludge Digestion," Presented at the
      International Symposium of Livestock Wastes,  Columbus, Ohio, April 22.

 Norman, John (1961).  "Aerobic Digestion of Waste  Activated Sludge," Thesis,
      University of Wisconsin.

 Pohland, F. G.  (1967).   "General Review  of Literature on Anaerobic Sewage Sludge
      Digestion," Engineering Extension Bulletin, Series No. 110, Purdue University,
      Lafayette, Indiana.

 Purves, D.  (1972).   "Consequences of  Trace-Element Contamination of Soils,"
      Environ.  Pollut.  3,  p.  17.

 Toerien, D.  F.  and W. H.  J.  Hattingh  (1969).  "Anaerobic Digestion I.   The
      Microbiology of Anaerobic Digestion," Water Research 3 (6), p. 385.

 Viraraghavan, T.  (1965).   "Digesting  Sludge by Aeration," Water Works  and Wastes
      Engineering 2  (9), p. 86.

 Von Zuben,  F. J.,  L. J. Ogden and R.  E. Peel (1952).  "House Fly Breeding at
      Sewage  Treatment Plants  in  Texas," Sewage and Industrial Wastes,  24  (10),
      p.  1303.

Wirts,  J. J.  (1956).  "Pipeline  Transportation and Disposal of Digested Sludge,"
     Sewage  and  Industrial Wastes, 28  (2), p. 121.

Wolf, H. W.  (1955).  "Housefly Breeding in Sewage Sludge," Sewage and  Industrial
     Wastes, 27  (2), p. 172.

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                                                    APPENDIX 4
RESOLUTION:
Recognizing the substantial labors of Congress and the President to
bring to the people of the United States an adequately funded and
conscientiously written statute for a more vigorous national attack
on our environmental problems, the President's Water Pollution Control
Advisory Board urges the Congress to enact promptly and the President
to sign the proposed 1972 Amendments to the Federal Water Pollution
Control Act.

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                                          APPENDIX 5
          CONCLUSIONS AND RECOMMENDATIONS




                      of the




President's Water Pollution Control Advisory Board




             Meeting on Ocean Disposal




                September 29, 1972

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The President's Water Pollution Control Advisory Board met in New York
City from September 26-29, 1972 to explore and make recommendations to
the Administrator of the Environmental Protection Agency, and in turn,
the President on the subject of ocean disposal as a national issue.
Based on comprehensive briefings by representatives of Federal, State,
and local agencies, a flyover to view the sewage sludge dumping, dredge
spoil dumping, and acid waste dumping in the New York Bight and a full
day of public testimony from experts in the field of ocean disposal and
alternatives the Board has reached the following conclusions and recom-
mendations :

I.    CONCLUSION:

      The Board recognizes that unrestricted ocean dumping poses real and
      potential pollution problems to the marine environment and its
      resources.  At the same time, there is evidence which indicates
      possible beneficial uses of some wastes and dredge spoils under
      carefully selected and controlled conditions.

      RECOMMENDATION';

      The Board recommends immediate Congressional Action in its current
      session on enactment of the Marine Protection Research, and Sanc-
      tuaries Act of 1972 (Ocean Dumping Bill) which has been agreed to
      by the House and Senate Conferees.  It is important that the U.S.
      demonstrate its earnest intention to control ocean dumping prior
      to the forthcoming International Ocean Dumping Convention.  At
      the same time, the Board recognizes that the present version of
      this legislation will likely create a duplication of responsibilities
      in EPA and the Department of Commerce for research and monitoring
      and for seeking alternatives to ocean dumping, assuming passage of
      the 1972 Amendments to the Federal Water Pollution Control Act.
      Accordingly, it is recommended that this apparent redundancy be
      eliminated and all responsibilities for establishment, and enforce-
      ment of marine water quality criteria and associated research and
      monitoring activities be centered in EPA.

II.    CONCLUSION:

      The Board concludes that ocean dumping is only one of many pathways
      through which wastes reach the marine environment, and that
      effective control of marine pollution requires legal authorities
      beyond those provided by the Ocean Dumping Bill.

      RECOMMENDATION:

      The Board recommends enactment during the current session of
      Congress of the proposed 1972 amendments to the Federal Water
      Pollution Control Act as reported out this week by the joint
      Senate-House Conference Committee.

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III.    CONCLUSION:
       The Board concludes that under the  existing  Federal Water Pollu-
       tion Control Act no agency has the  authority to establish Water
       Quality Standards in the area between the  3  mile  and the 12 mile
       line in the so-called contiguous  zone.   Neither the new Water
       Bill nor the Ocean Dumping Bill remedies this, although each
       requires discharge permits to be  issued to protect the Water
       Quality in the contiguous zone.

       RECOMMENDATION:

       The Board therefore recommends that EPA seek remedial legislation
       to require the establishment of Federal Water Quality Standards
       for the waters of the contiguous  zone.
IV.    CONCLUSION:
       The Board has heard convincing evidience that  the  presence of
       toxic substances, primarily the heavy metals,  in municipal sewage
       creates special problems in the ultimate disposal  of the resulting
       sludge from treatment plants.   These substances  have an adverse
       effect through their possible  entry into the marine food chain
       when ultimate disposal of sludge is to the ocean.   Similarly,
       adverse effects follow from discharge to the atmosphere of these
       substances if incineration is  selected as the  method of sludge
       disposal.  Even when sludge disposal is to land, the presence of
       these toxic materials complicates the problem  and  introduces
       difficulties in the ultimate use of land.

       The Board has learned that the heavy metals in municipal sewage
       derive from a wide variety of sources within the cities, but  that
       the most concentrated source and the one that  lends itself princi-
       pally to control is through the components of  industrial waste in
       municipal sewage.

       RECOMMENDATION:

       The Board recommends that the EPA press for a  requirement that
       all industrial wastes containing significant amounts of toxic
       substances, including heavy metals, be pretreated  for the removal
       of such substances before being discharged to  municipal  sewage
       systems.
V.     CONCLUSION:
       After hearing a presentation upon the known and speculative effects
       of emissions from sewage sludge incinerators as an alternate to
       ocean dumping, the Board at this time has reservations about the
       recommended approval of such incinerators pending the development of
       more sophisticated type of equipment for the measurement of the
       emissions of toxic discharges.

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        RECOMMENDATION:

        The Board recommends  that  EPA  actively pursue the development of
        more accurate  emission measuring  equipment so as to provide adequate
        assurance that such incinerators  not pose unacceptable threats to
        human health or  to air quality.
VI.     CONCLUSION:
        The  Board  concludes  that considerably more and better scientific
        data and information are needed to establish ocean disposal criteria
        and  guidelines to safeguard the marine environment.

        RECOMMENDATION:

        The  Board  recommends all deliberate speed in the completion of
        an inventory of the  ocean bottom and the coastal waters (territorial
        and  contiguous seas)  of the United States and -ts territories in
        order to establish base-line data to which futuiv. comparisons can
        be referred.  The inventory, or base-line data, should include,
        but  not be limited to, the subsurface and bottom ocean currents,
        upwelling, temperatures and chemical composition of the waters,
        seasonal changes, distribution of existing aquatic life food chains
        and  aquatic migration patterns.

        The  Board further recommends that EPA take the lead and in cooper-
        ation with NOAA, the Corps of Engineers, Coast Guard and other
        interested agencies  plan and conduct a program of research and
       monitoring which will lead to improvement of marine water quality
        criteria, selection  and use of ocean dumping sites, provision of
        guidelines for proposed disposal operations, and assurance of non-
        degradation and enhancement of environmental quality of the oceans.
VII.   CONCLUSION:
       The Board's discussions frequently focused on the fact that the
       United States has become an urban society.  More than thirty per-
       cent of our population lives in the large metropolitan centers.
       Many cities are located on large rivers, lakes or oceans.   The
       problems of sewage sludge disposal are compounded because of lack
       of suitable disposal sites.

       Usually within a reasonable distance sometimes across State lines
       there are areas of low quality land, abandoned strip mines, or
       other low value areas with potential for enhancement that could be
       used for sludge disposal.

       Proper use of sludge disposal could reclaim these lands and make
       them available for future food production or recreation.

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       RECOMMENDATION:
       The Board recommends that where available Federal  or State  lands
       of relatively low value be utilized for experimental sludge
       spreading programs.
VIII.  CONCLUSION:
       The Board recognizes the necessity for dredging to  maintain
       navigational channels.

       At the same time, testimony has been presented indicating  that  a
       number of environmental problems are associated with  the practice
       of indiscriminate dredging and the ocean disposal of  polluted
       dredge spoils.

       RECOMMENDATION:

       In many areas there are continuing approved coastal land develop-
       ment projects.  Where possible or feasible, dredge  spoils  should
       be used as fill in such land recreation projects.   The Board
       suggests cost benefit studies to ascertain the value  of environ-
       mental enhancement resulting from containment versus  dumping of
       dredge spoil.  Studies should also be undertaken to determine the
       feasibility of treating dredge spoils to remove solids and other
       components, which might be deleterious to the ecosystem, prior to
       ocean disposal.
IX.    CONCLUSION:
       The Board recognizes that the oceans are a food source and may
       benefit from some by-products of our present civilization that may
       be thought of at present as pollution material.  It furthur
       recognizes that some of these substances may be utilized as
       nutrients for the ocean and may enhance or revitalize certain
       areas of the ocean.  The Board also recognizes the recreational
       value of the ocean and has observed the value of reef building by
       selected material being placed in known barren areas to enhance
       the marine environment.

       RECOMMENDATION:

       The Board recommends that the Federal government's research activi-
       ties include efforts to explore more fully those conditions under
       which nutrient-rich wastes can be effectively utilized to improve
       the marine environment.

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 X.     CONCLUSION:

       The  coastal waters  of various regions of the U.S.A. vary greatly
       as to physical  and  ecological characteristics  (such as currents,
       temperatures, bottom geology, etc.) as well as in their proximity
       to population concentrations.  The continental shelves represent
       the  most  fertile  locations for marine resource development and
       recreational purposes; yet here are located the waters most apt
       to be subject to  effluent discharges and ocean dumping.  Also the
       geography of our  nation finds at many locations State and various
       municipal jurisdictions closely grouped at or on concentrated
       harbor, river and other disposal locations.

       RECOMMENDATION:

       The  Board recommends that the Federal government continue to
       insist on regional  approaches and insure consistency in the appli-
       cation of standards of treatment, disposal and controlled dumping
       procedures applicable to all State and local agencies in the
       coastal region and/or on the river or estuarine systems.  Separate
       regional  standards must also be applied to such divergent coastal
       conditions as exist in the N.E., S.E., Gulf States, California,
       N.W., Alaska, and Hawaii.

XI.    CONCLUSION:

       Certain coastal States have presented to the Board substantial
       evidence  they have recently enacted stringent State environmental
       standards for shoreline protection.

       RECOMMENDATION:

      The  Board recommends that State governments should intensify their
       efforts to enhance the quality of their own shoreline and depend
      not  solely on Federal legislation.

       Federal encouragement of, and priority cooperation with all such
      States, should hasten the time otherwise required to correct the
      current abuse of the nation's coastal waters.

XII.  CONCLUSION:

      The Board heard testimony on the wastewater management problems of
      the City of New York, specifically noting that 480 million gallons/
      day of raw sewage and another 420 mgd of inadequately treated sewage
      are discharged to the Hudson River, East River, and harbor waters.
       In addition to public health hazards and general environmental
      degradation, the raw sewage discharges result in the annual deposi-

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tion of 2.3 million cubic yards of sludge which must be dredged and
removed from the harbor bottom.  From existing plants, the city
barges large quantities of digested and undigested sludge each day
for disposal in the New York Bight.  The City has developed engineer-
ing plans to build two new secondary treatment plants and upgrade
existing plants and may construct an additional plant in Staten
Island.  The City estimates that it can end sludge dumping at sea
in from 10 to 15 years, but in the interim as its treatment plants
go on stream, the quantity of digested sludge is expected to at
least triple.
RECOMMENDATION:

The Board recommends that the construction of facilities to end the
unacceptable practice of discharging raw sewage into any harbor is
mandatory.  While the Board cannot condone years of failure to com-
ply with acceptable health and welfare standards, we recognize the
funding limitations available to the City and urge as a priority
the construction of sewage treatment plants with sludge digestion.
Federal assistance for such plants must be contingent upon EPA
approval of the ultimate method of sludge disposal to assure non-
violation of environmental protecion regulations - whether disposal
is through incineration, marine disposal, land disposal, or other
means.

In the absence of an immediate solution to the present practice of
raw sewage discharge, a moratorium on new building construction
should be enforced to the extent that increased raw sewage discharges,
and over loading of sewers and treatment plants will not occur.
* U. S. GOVERNMENT PRINTING OFFICE : 1 972—5l
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