U nrTed States
Environmental Protection
Agency
Office of Water
(WH-556 F)
EPA 503/9-90/006
April 1990
Sludge  Recycling
Alternatives
Report to Congress

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REPORT TO CONGRESS
ON
SLUDGE RECYCLING ALTERNATIVES
April 1990
U. S. Environmental Protection Agency
Office of Marine and Estuarine Protection
Washington, DC 20460

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INTRODUCTION
In 1988, the United States Congress responded to the public’s
increasing concern over ocean dumping by passrng the Ocean
Dumping Ban Act (ODBA) The Act amended the Marine
Protection, Research, and Sanctuaries Act (MPRSA) of 1972
which regulates ocean dumping, and requires that ocean
dumping of industrial waste and municipal sewage sJudge be
terminated by December 31, 1991 The U S Envirorrriental
Protection Agency (EPA or the Agency) was assigned primary
responsibilrty for implementing ODBA, arid since enactment
several program actions have been initiated to ensure that the
Iegis1ation’s statutory requirements are met
Termination of ocean disposal of industrial waste has already
been achieved, and thus EPA is now focusing its efforts on the
nine sewerage authorities in New Jersey and New York which
use ocean disposal to manage their sewage sludge ODBA
required EPA. the states of New Jersey and New York, arid the
sewerage authorities to enter into compliance agreements that
would include a negotiated schedule to design, construct, arid
implement an alternative system to ocean dumping by
December 31, 1991 In case full implementation can not be
achieved by this date, enforcement agreements will be required
Given the stringent time frame, all nine sewerage authorities
entered into enforcement agreements, the agreements were
signed on or before August 4, 1989. The sewerage authorities
agreed to implement interim disposal plans until long-term plans
could be implemented Interim and final disposal plans, as well
as compliance dates, are shown for each sewerage authority in
Table 1.
Currenity, most of the New Jersey sewerage authorities plan
dewatering arid out-of-state disposal as the interim land-based
alternative and incineration is expected to be the4r final land-
based alternative. However, many of the New Jersey sewerage
authorities are continuing to investigate other alternatives For
example, the Passaic Valley Sewerage Commissioners are
considering a proposal for gasification, and the Rahway Valley
Sewerage Authority is considering a proposal for pe4letization
In New York, the sewerage authorities will dewater and then
utilize private vendors to manage ther sewage sludge in the
interim. The malonty of responses received as a result of the
request for proposal process indude chemical fixation,
composting, pefletization, land application and in a few cases ,
Iandfllling and inoneration. Alternatives for long-term land-
based disposal are still under study.

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TABLE 1 CURRENT SLUDGE MANAGEMENT COMPUANCE SCHEDULES AND
PLANS FOR INTERIM AND LONG-TERM IMPLEMENTATION
INTERIM LONG-TERM
SEWERAGE
AUTHORifY DATE DATE
Bergen County 3/17/91 Dewatering/ 1/1/96 Incineration
Utilities Authority Out-of-state
disposal
Joint Meeting of 3/17/91 Dewatenng/ 2/10/98 Incineration
Essex and Union Out-of-state
Counties disposal
Ljnden Roselle 3/17/91 Dewaterir ig/ 1/1/96 Incineration
Sewerage Authority Out-of-state
disposal
Middlesex County 3/1 7/91 Chemical fixation/ 3/17/91 Chemical f xation/
Utilities Authority Landfill cover Landfill cover
Passaic Valley 3/17/91 Dewatering/ 12/31/96 Incineration
Sewerage Out-of-state
Commissioners disposal
Rahway Valley 3/17/91 Dewatenng/ 2110/98 Incineration (at
Sewerage Authority Out-of-state Joint Meeting of
disposal Essex and Union
Counties)
Nassau County 6/30/91 (50%) Dewatering/ 12/31/94 Under study
Department of Public 12/31/91 (100%) Private venture
Works
New York City 12/31/91 ( 20 %)b Dawatenng/ 12/31/96 ( 50 %)C Under study
Department of 6/30/92 (100%) Private venture 6/30/96 (100%)
Environmental
Protection
Westchester County 12/31/91 Dewatering/ 9/15/96 Under study
Department of Private venture
Environmental
Facilities
$ Under its interim pLan, NCDPW plans to phase out 50% of its ocean dumping by 6/30/91 and 100%
by 12/31/91
b Under its interim plan, NYCOEP plans to phase out 20% of its ocean dumping by 12/31/91 and 100%
C LYndec rts long-term plan, NYCDEP plans to phase in 50% of its capacity by 12/31/96 and 100% by
6/30/98
2

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At a hearing on the FY90 Appropriations Bill, the Senate
Appropriations Subcommrtt on VA. HUD, and Independent
Agencies considered the Sewerage auttiormes’ Interim and final
plans. Concern was expre that the sewerage authorities
Selecting Incineration had done so wrthO t fully Considering
other disposal alternatives. The Subcomnit ee stated that under
ODBA and the Agency’s Pollution Prevention Policy, EPA has a
responSlbilrfy to Centrfy environmentally sound sludge recycling
alternatives and assist the sewerage authorities with their efforts
to implement these atternatr es In Senate Conference Report
ioi-i , the Subcommittee reques that EPA prepare a report
on actions it has taken to work with the sewerage authorities to
identify and implement sludge recycling alternatives
Specii9celty, the Subcommittee requested the following
• A description of the process that EPA is using to assist
the sewerage authorrties, and
• Economic and technologicel feasibility assessments of
alternatives that have been proposed to reuse or recycle
sewage sludge
EPA ASSISTANCE IN SELECTING
SLUDGE RECYCLING ALTERNATIVES
During ODBA Oversight Hearings in May 1989, the House
Merchant Marine Fisheries Committee, along with the Natural
Resources Defense Council, asked EPA to provide the sewerage
authorities with information and assistance on sludge
management technology via a rouridtable meeting on land-
based alternatives to ocean dumping. EPA Region II, with
assistance from the EPA Office of Marine and Estuarine
Protection (OMEP) and Office of Municipal Pollution Control
(OMPC), responded by hosting a two-day meeting in November
1989, in East Rutherford, New Jecsey EPA invited the nine
sewerage authorities, along with officials from other sewerage
authorities already familiar with the operation of land-based
sludge management systems. The meeting provided an open
forum to identify and discusa the political, economic and
technolOgK J difficulties associated with implementing land-
based technolog e . A report summarizing the discussions at
the rotindtable meeting was prepared and is induded as
Attachment 1
EPA has also developed offlciai policies to provide guidance on
sludge management issues. The Agenc s Pollution Prevention
Policy promotes source reduction and recycling and states that
AJtho .gh source reduction is preferred to other
mane garment practices, b )e Agency recognizes The
3

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value of env,ronmentaity sound recycling. and is
Committed to promoting recycling as a second prefer-
ence, above beaUnenf control and disposal
The Agency’s Beneficial Use of Sludge Policy is directed solely
towards management of sewage sludge and states that
• The U.S. Enwonmontal Protection Agency will
active promote Those municipal sludge management
practices That provide for The beneficial use of sludge
while maintaining or improving eiw:ronmenta! quality
and protecting public health ..
EPA and other agencies (e.g, Department 01 Agriculture,
Department of the Interior, National Science Foundation,
Tennessee Valley Authority) have conducted and/or funded
many research inrtiat;ves, workshops, conferences, and
demonstration projects to si.ipport the Beneficial Use of Sludge
Policy; results have been published in numerous EPA and
external publications. These publications, which are available to
the sewerage authorities, their consultants, and the general
public through private publishers, National Technical Information
System, General Pnnting Office, and other means, have focused
on a variety of public policy and technical issues related to
beneficial use of sewage sludge. Major topics addressed
inckjde
• Health effects associated with sludge and-application
practices
• Crop responses when grown on sludge amended soils
• Use of sludge compost in turf production and
maintenance
• Use of sludge in and reclamation and biomass
production
• Application of sludge to forest lands
• Technology assessment of n-vessel composting
• Technology assessment of static pile and wrndow
composting
• Technology assessment of dual digestion
• Technology assessment of chemical fixation and alkaline
stabilization processes
4

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While EPA recogrnzes that it has a role in providing assistance
to the sewerage authorities, it Should be noted that Section
405(e) of the Clean Water Act dearly states that
- the determination o( the manner o( disposal or use
of sewage sludge is a local determinabon -
EPA cannot prohibit a local government from implementing a
particular technology, and thus, the ultimate responsibility for
evaluating and selecting a land-based sludge disposal
technology lies with the local government.
EPA FEASIBILITY ASSESSMENTS OF
SLUDGE RECYCLING ALTERNATIVES
Economic and technological fe oility assessments of various
land-based sludge management technologies have been
conducted for years as a result of EPA’s Construction Grants
Program The program, which has provided over $52 billion in
federal funding since 1972 for construction of publidy owned
wastewater treatment facilities, requires a facility to conduct a
full evaluation of potential alternatives before selection of a
technology As a result, project- and area-specific economic
and technical assessments have been conducted of various
land-based sludge management alternatives. In addition, a
number of area-wide Sludge management studies, including
specific technology assessments and pilot tests, have been
funded by EPk Examples include the Los Angeles/Orange
County Metropolitan Area Regional Wastewater Solids
Management Program, the San Francisco Bay Regional
Wastewater Solids Study, and the New York/New Jersey
Interstate Sanitation Commission Study. These project-specific
assessments have not been collected or published by EPA in a
central location; however, if a sewerage authority official
requests information on the economic and technical feasibility of
a technology, the Agency can help to direct the official to
appropriate sources of information, and in many cases operating
facilities. While the assessments are generally project-specific,
the information can stifi provide a sewerage authority official with
an appreciation for the positive and negative trsiie-offs
associated with various technologies.
In some circumstances. EPA has conducted rt8 own economic
and technological assessments of proposed Construction Grants
projects through the preparation of environmental impact
statements. In eddition, EPA has supported state-of-the-art
assessments and issued design guidance s l id cost estimating
guidance applicable to most of the major sludge use and
dispossi technologies. (Some of the major reference ciocuments
that have been prepared are listed in Attachment 2) EPA is
5

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currently planning a technicai assessment of chemical fixation, a
technology selected by Middlesex County Utilities Auttiorrty and
under consideration by some of the other sewerage authorities
The study, which is being sponsored by OMEP and OMPC, will
be conducted in the summer of 1990 It will be useful to the
sewerage authorities that are still evaluating their long-term
disposal alternatives.
6

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ATTACHMENT 1
PROCEEDINGS OF THE
SLUDGE MANAGEMENT ROUNDTABLE
Held
November 26-27, 1989
East Rutherford, New Jersey
April 1990
U. S. Environmental Protection Agency
Office of Marine and Estuarine Protection
Washington, DC 20460

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EXECUTIVE SUMMARY
In 1968, the United States Congress amended the Marine
Protection, Research, and Sanctuaries Act (MPRSA) of 1972 by
enacting the Ocean Dumping Ban Act (ODBA) to end the practice
of ocean dumping of industrial waste and municipal sewage
sludge. The U S Environmental Protection Agency (EPA) is
delegated primary responsibility for the implementation of ODBA
Currently, all Industrial-wa.ste generators subject to ODBA have
stopped dumping, however, the following nine municipal sewerage
authorrties en New Jersey and New York are still ocean dumping
sewage sludge
New Jersey
• Bergen County Utilities Authority (BCUA)
• Joint Meeting of Essex and Union Counties (JMEUC)
• Linden Roselle Sewerage Authority (LPSA)
• Middlesex County Utilities Authority (MCUA)
• Passaic Valley Sewerage Commissioners (PVSC)
• Rahway Valley Sewerage Authority (RVSA)
New York
• Nassau County Department of Public Works (NCDPW
• New York City Department of Environmental Protection
(NYCOEP)
• WestchesterCounty Departmertof Environmental Facilities
(WCDEF)
ODBA established a framework for terminating ocean disposal of
sewage sludge and prohibited ocean dumping of sludge after
August 14, 1989, unless the municipal sewerage authorities had
received a permit and entered into a compliance or enforcement
agreement with EPA and the applicable state. EPA received
complete permit applications for the transport and disposal of
municipal sewage sludge from all nine municipal sewerage
atjthorrties. Final permits were issued and enforcement
agreements were signed by EPA, the states of New York and New
Jersey, and the nine municipal sewerage authorities on or before
August 4, 1989 The permits became effective on August 14, 1989;
the enforcement agreements, in the forni of judicial consent
decrees, were filed with the court by August 14, 1989
At an ODBA hearing on May 17, 1989, the U. S. House of
Representatives Committee on Merchant Marine and Fisheries and
the Natural Resources Defense Council (NRDC) asked EPA to
convene a roundtable on land-based alternatives to ocean
dumping of sewage sludge foi the nine sewerage authorities
affected by ODBA.. Members of the committee reiterated the
Attachment 1 1- e

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recommen ion to the Honorable William Reilly, EPA
Administrator, in a letter dated July 19, 1989, emphasi.zing the need
1o provide information and assistance to the authorities, ensuring
that all potential avenues to safely manage se vage sludge on land
are considered EPA. committed to the effective implementation
of ODBA and sensitive to the concerns of Congress, the public,
and the municipal sewerage authorities, agreed to host a sludge
management roundtable. The roundtable convened on November
27-28, 1989, in East Rutherford, New Jersey
This document summarizes the discussions that took place among
participants at the rounCtable. Participants included the New York
and New Jersey sewerage authority officials who are now faced
with implementing land-based sludge management alternatives,
guest speakers representing sewerage authorities already familiar
with operation of land-based sludge management systems, state
and federal regulatory officials acting as resources for the
participants, a representative of the NRDC, and a roundtable
facilitator. The public was invited to observe the proceedings The
opinions expressed by the roundtable participants arid described
herein do not necessarily reflect the opinions or policies of EPA.
EPA, with the support of New York and New Jersey state officials,
sponsored the roundtable and formed a planning group to develop
the agenda. The planning group recognized the importance of
acquiring input for the agenda. Thug, a questionnaire was
produced and distributed to all nine municipal sewerage authorities
and to NRDC. The respondents were encouraged to voice their
concerns arid priorities through the completion of this
questionnaire
Using results from the questionnaire, the planning group identrfled
three goals for the sludge management roundtable
1. To understand the factors contributing to the
challenges being experienced by the municipal
sewerage authorities in the development of Land-
based sludge management.
2. To define various strategies for handling the
challenges of land-based sludge management.
3. To define realistic actions to be pursued in the
succesaful implementation of land-based sludge
management alternatives.
Based on those issues rated as most challenging and other issues
identified by the respondents, the topic for discussion were
1-it Attachment 1

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focused on two rnaior areas (1) permitting and siting arid (2)
technologies in relalion to public health and enwonmental
concerns.
The planning group formatted the roundtable in a manner that
would stimulate productive discussion on strategies for
implementing land-based management alternatives for municipal
sewage sludges. The two-day roundtable consisted of three
sessions. In addrtjon, a presentation on the status of proposed
503 sludge regulations followed the conclusion of Round 1 on the
first day.
Round 1 opened with introductions arid comments by Richard
Caspe, EPA Region II Water Management Division Director He
identified three overall objectives to be accornplisl-ied at the
roundtable
I To establish a network of people experiencing similar
challenges.
2. To provide a forum for an open exchange of
information and ideas
3 To provide an increased sensitivity to the issues being
faced by the New York and New Jersey authorities
among all involved with sludge management.
Roger Dotan, general manager of the Central Contra Costa
Sewerage District, California, served as the primary roundtable
facilitator and began the dialogue with comments on the issues
affecting land-based sludge management. During the discussion
that followed, there was general consensus among the participants
that the schedules to terminate ocean dumping are tight and, in
most cases , more difficult than the schedules faced by the guest
speakers. The sewerage authority representatives expressed
confidence in their ability to meet the deadline for implementing
long-terni alternatives. Their moat critical concern was meeting
the agreed upon interim deadlines for ending ocean dumping. The
New Jersey authorities were concerned about the even more
stringent, state-mandated March 17, 1 1, deadline Producing
dewatered sludge and hauling it to landfills was identified as the
most realistic interim land-based alternative. The authorities noted
that numerous difficulties are associated with implementing this
disposal option, including siting dewstenng facilities and finding
landfill sites, gaining public acceptance. obtaining necessary state
and municipal permits, constructing the necessary facilities, and
transporting the dawatered sludge to landfills.
Members of EPA. the New Jersey Department of Environmental
Protection, and the New Yoik State Department of Environmental
Attachment I 1-ui

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Conservation joined the guest speakers, sewerage authorities, and
NRDC in the focus group diScussi n in Round 2 on the second
day The purpose of the break-out groups was to discuss the
issues introduced in Round i In greater detail The topica were
divided into two sactions (1) Focus Group A — Technologies in
Relation to Public Health and Environmental Concerns arid (2)
Focus Group B — Permitting and Siting
The two Focus Group A sessions addressed primarily public
misconception arid acceptance; traditional technologies such as
land application and incineration; less conventional technologies
such as chemical fixation or gasification; techniques used in the
successful implementation of a dewatering/laridfill disposal system,
and concern for using the best technologies for long-term Land-
based sludge management. The two Focus Group B sessions
centered on the challenge of siting and implementing sludge
management systems that adhere to both state agency permitting
procedures and the consent decree schedules
The sludge management roundtable addressed the concerns and
challenges presented by all of the groups involved in the
implementation of land-based sludge management alternatives
(1) the city, state, and federal legislators who will make, or have
made, decisions on sludge management, (2) the regulators who
enforce the legislative decisions, (3) the sewerage authorities
responsible for implementing sludge management alternatives, (4)
the private contractors employed for sludge management. (5) the
environmental and public health activists, and (6) the public, who,
in many instances, believe that their health and personal property
may be jeopardized by the recommended sludge management
methods. Consequently, the rouridtable provided EPA, the state
agencies, and NRDC with an increased sensit rty to the issues
being faced by the New York and New Jersey sewerage
authorities in pursuing and implementing interim arid long-term
alternatives.
The sewerage autnormes benefttteci from the in-depth information
exchange that took place during the roundtable. Many strategies
and possible endeavors were discussed. In addition to the
strategies listed in Section 3, the following suggestions were made
in the final round:
1 Establish an information eennghouse, possibly by
or with support from EPA.
2. Continue the networking process that began at this
roundtable.
3 Seek cooperation at all levels federal, state, local,
and private sector.
1-iv Attachment I

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4 Consider the possibility of reglonalization in the
development of IOng- .term sokrtions
5. Use multiple contractors and diversification in
implementing siudge management options
6 Increase Sewerage authonty staffs for the negotiation
and management of multiple contracts with the private
sector.
7 Involve a City attorney knowledgeable in the local
permitting regulations for negotiating contracts
8. Increase public awareness of the sewerage authorities’
decision-making Processes and sludge management
activities, EPA Should be more involved in providing
nlormation to the public on the public health and
environmental effects of various sludge management
technologies
The New York and New Jersey sewerage authorities expressed
their gratitude to EPA for holding the roundtable and reiterated a
firm commitment to m <’ting their deadlines and si .iccessfufly
terminating ocean durn g. The sewerage authorities strongly
voiced their desire to implement the most environmentally Sound
sJudge management alternatives and expressed a willingness to
remain Open-minded and flexible in their Implementation plans
They also expressed the hope that the regulators maintain the
same open-mindedn and flexibility
Attachment 1

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TABLE OF CONTENTS
Page
EXECUTiVE SUMMAPY . i-i
1 0 INTRODUCTiON 1-1
20 ROUNDTABLE ORGANIZATiON 1-5
2.1 Attendees . 1-5
22 Key Issues . 1-6
22.1 Results of the Questionnaire 1-6
222 Development of Key Issues Based on
Questionnaire Results 1-9
23 Roundtable Structure and Process 1-9
30 ROUNDTABLE DISCUSSION SUMMARY 1-12
3 1 Round 1 The Challenge 1-12
311 Facility and Landfill Siting 1-13
3 1 2 Public Acceptance 1-13
3 1 3 Private Contractors 1-14
3 1 4 Conclusion 1-15
3.1 5 New Sludge Management Regulations 1-15
32 Round 2 Developing Alternative Strategies 1-16
32.1 Focus Group A Technologies
in Relation to Public Health
and Environmental Concerns 1-16
3 2 11 Public Health and
Environmental Concerns 1-16
32.12 Technologies 1-17
3 2 1 3 Dewatering/Landfill
Disposal System 1-17
32.1 4 Alternative Selection 1-18
322 Focus Group B Siting arid Permitting 1-19
322 1 State Requirements 1-19
3.2.22 Time Constraints 1-20
32.23 Public Acceptance
and Siting Strategies 1-21
33 Round 3: Realistic Actions to Pursue 1-22
APPENDIX A
Roundtable Planning Group Members 1-24
APPENDIX B
Roundtable Attendees . 1-25
1 -vi Attach merit 1

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LIST OF TABLES
Page
TABLE 1 CURRENT SLUDGE MANAGEMENT
COMPUANCE SCHEDULES AND
PLANS FOR INTERIM AND
LONG-TERM IMPLEMENTATiON 1.3
TABLE 2. RESULTS OF THE QUESTiONNAIRE 1-7
TABLE 3. ROUNDTABLE AGENDA AND FORMAT 1-10
AttacS ment 1 1 -vii

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1.0 INTRODUCTION
In 1988, the United Stales Congress amended the Marine
Protection, Research, and Sanctuaries Act (MPRSA) of 1972 by
enacting the Ocean Dumping Ban Act (ODBA) to end the practice
of ocean dumping of industrial waste and municipal sewage
sludge The U S Environmental Protection Agency (EPA) is
assigned primary responsibility for the implementation of ODBA
The act assigns a number of tasl s to the agency, including
establishing compliance and enforcement agreements, issuing and
enforcing permrta: collecting ocean dumping fees, and conducting
monitoring, research and surveillance actryrties, as weB as
preparing Reporta to Congress.
ODBA requires a compliance or enforcement agreement for all
industries or sewerage authorities that use ocean disposal to
manage their waste. The agreements must include a negotiated
schedule to terminate ocean disposal by December 31, 1991 The
schedule must include plans for the design, Construclion, and full
implementation of a long-term, land-based, alternative system for
the management of industrial waste or sewage sludge
Currently, all industrial-waste generators subject to ODBA have
stopped dumping, howeier, the following nine municipal sewerage
authorities in New York and New Jersey are still ocean dumping
sewage sludge
New Jersey
• Bergen County Utilities Authority (BCUA)
• Joint Meeting of Essex and Union Counties (JMEUC)
• Linden Ros Ie Sewerage Authority (LRSA)
• MCClesax County Utilities Authority (MCUA)
• Passaic Valley Sewerage Commissioners (PVSC)
• Rahway Valley Sewerage Authority (RVSA)
New York
• Nassau County Department of Public Works (NCDPW)
• New York City Department of Environmental Protection
(NYC DEP)
• Westchester County DepartmentofEnvironmentai Faol ties
(WCDEF)
OOBA established a framework for terrniriathg ocean disposal of
sewage sludge and prohibited such dumprng after August 14,
1989, unless the muniopei sewerage authorttiee had received a
permit and entered into an agreement with EPA and the applicable
state EPA received complete permit applications for the transport
and disposal of municipal sewage sludge from all nine municipal
Attachment 1 1-1

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sewerage authorities. Enforcement agreements were signed by
EPA Region II, the U S Department of Justice, the states of New
York and New Jersey, and the nine municipal sewerage authorities
on or before August 4, 1989 Permits were issijed to the nine
authorities on or before August 4, 1969, arid became effective on
August 14, 1969.
EPA. along with the affected states, negotiated the enforcement
agreements with the municipal sewerage authorities to ensure that
the authorities will aggressively pursue the implementation of
alternative land-based sludge management methods as required by
O08& The enforcement agreements require that the municipal
aijthornies specificeil’y define thor long-term plans by May 1,1991
The municipal sewerage authorities’ interim and long-term plans of
action, as well as compliance dates, are detailed in Table 1
The New Jersey Oceen Sludge Dumping Elimination Act requires
a complete cessation of ocean disposal by March 17, 1991 A
companion piece of legislation, which amends the New Jersey
Water Pollution Control Act, requires the submittal of a plan for
land-based sludge management by Apnl 30, 1989 Currently, most
of the New Jersey sewerage authorities plan dewatering and Out-
of-state disposal as the interim land-based alternative, while
incineration is expected to be ther final land-based alternative
However, many of the New Jersey authorities are continuing to
investigate other alternatives. For rnpIe, PVSC is considering
a proposal for gasification, arid RVSA is considering a proposal for
pelletization.
The New York sewerage authorrties currently plan to dewater
sludge and utilize private vendors to manage their sewage sludge
in the iritenm. The majority of the responses received as a ree&itt
of the request for proposals (RFP) process comprise chemical
fixation, compostirig, pelletization, land application, and in a few
cas landfilling and incineration. Alternatives fo long-term
disposal are still under study
Land-based sludge management alternatives are use and disposal
technologies that do not involve dump4ng sludge ‘rita the ocean
Disposal methods include incineration of sludge with ash thspOaaI
in a landfill and direct landfilllng of sludge. Land application and
land reclamation are other common diepoesi method& 8ecause
of the benefits derived from land application and land reclamation,
these disposal m ods are commonly referred to as ‘beneficial
use.’ It shou be noted that benefits may be derived from other
alternatives as wet For mple, energy can be recovered from
some indnerators and landfills.
1-2 Attachment 1

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TABLE 1. CURRENT SWDGE MANAGEMENT COMPLIANCE SCHEDULES AND
PLANS FOR INTERIM AND LONG-TERM IMPlEMENTATiON
M
SA
A
LONG ERM
*TE
Bergen County 3/17/91 Dewatering/ 1/1/96 Incineration
ulilities Authority Out-of-state
disposal
Joint Meeting of 3/17/91 Dewatering/ 2/1 98 Incineration
Essex and Union
Counties disposal
Linden RosalIe 3/17/91 DawaterinaJ 1/11% Incineration
Sewerage Authority Out-of-state
disposal
Middlesex County 3/17/91 Chemical fixationl 3/17/91 Che mcal fixatiori/
Utilities Authorrty L.andflhl cover Landfill cover
Passaic Valley 3/17/91 Dewatenno/ 12131/96 Incineration
Sewerage Out-of-state
Commissioners disposal
Rahway Valley 3/17/91 Dewatenng/ 2 /1 W98 Incineration at Joint
Sewerage Authority Out-of-state Meeting of Essex
disposal and Union Counties
Nassau County 6/30/91 (50%) Dewatemmn / 12/31/94 Under study
Department of Public 12131/91 (100%) Private vent jre
Works
New York City 12/31/91 ( %)b Dg/ 12/31/96 ( 50 %)C Under study
Department of 6/3 (100%) Private venture &3Cd98 (100%)
Environmental
Protection
Westchester CourTty 12/31/91 DewatennaJ 15/96 Under study
Department of Private venture
EnvironmentaJ
Facilities
‘ Under its interim plan, NCDPW plans to phase out 50% of its ocean dumping by 6/30/91 and 100%
b nd rflenm plan, NYCDEP plans to phase out 20% of its ocean dumping by 12/31/91 and 100%
C nder its ‘ong-term plan, NYCOEP plans to phase ri 50% of its r pecfty by 12 /31/96 and 100% by
& 98.
Attachment 1 1-3

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The technologies for processing sludge prior to land application or
reclamation to control pathogen. very depending on site cond-
tions. end use, and sludge quality. Those in common use include
digestion or billzation, compostrng, heel or air drying, and
pelletization. Sludge must be dewatered prior to the implemen-
tioii 01 incin ratjon and the rnalorlty of land apphcation or
reclamation alte es.
Implen,en tjon of land-based sludge mar agemei-it alternatives, as
well as the proc aee used to prepare sludge for these options,
can be hindered by a variety of difficulties. For example, because
New York and New Jersey are such densely populated areas, land-
fill apace very lImited. Also, concerns regarding human health
and environmen J impacts casi create significant public opposition
to alternatives. EPA recognizes the difficulties associated with
implementing land-based sludge management alternatives. At an
ODBA hearing on May 17, 1969. the U S. House of Represenita-
trves Committee on Merchant Manna and Fisheries and the Natural
Resources Defense Council (NPDC) asked EPA to convene a
rourid ble on land-based alternatives to ocean dumping of sewage
sludge for the nine sewerage authorities affected by ODB&
Members of the committee reiterated the recommendation to
William Rally, EPA Administrator, in a letter dated July 19, 1969,
emphasizing the need to provide information and assis nce to
the authorities. ensuring that all potentiai avenues to safely manage
sewage sludge on land are Coneidered. EPA. committed to the
effective implemen tion of QOBA and sensitive to the concerns of
Congress, the public, and the muniopai sewerage authorities,
agreed to host a sludge management roundteble. The round ble
convened on November 27-28, 1969, in East Rutherford, New
Jersey.
This document summarizes the discussion that took place at the
rounC b1e. The roundteble participants included the New York
and New Jersey sewerage authority officials who are now faced
with implementing land-based sludge management alternatives,
guest speakers representing sewerage authorities aIr y familiar
with operation of land-based sludge management systems; te
and federal regulatory officials acting as resources for the
partidpants; a repreeentstive of NRDC; and a roundtable facililator.
The pub c invited to observe the proceedings. The oprnions
pre by the roundteble participants and described hereln do
not necessarily reflect the opinions or policies of EPA.
1-4 Attschmerit 1

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2.0 ROUNOTABLE ORGANIZATION
EPA, with the support of New Yorl and New Jersey state officials,
sponsored the roundtable and formed a planning group to d e4op
the agenda. The planning group consisted of person from EPA.
the New Jersey Department of Enwonmentaj Protection (NJDEP),
the New York State Department of Environmeritsi Conser,a on
(NYSDEC). and corisuttarn are shown in Appendix A. Planning
the roundtable involved three tasks (1) entffy1ng the roundtable
attendees, (2) Cemifying the key issues, and (3) determining the
roundtaole structure and process.
2.1 AUENDEES
Categonceily, there were three groups of attendees at the sludge
management roundtable:
1. DISCUSSION PAR11CIPANTS
The discusaion participants consisted of the rounctable
facilitators, guest speakers, sewerage authority officials,
and a rePresentative from NROC.
The primary facilitator had the responsibility for keeping
the roundtabie discussions directed to the appropriate
issues throughout Round I and Round 3 and for facilrtating
Focus Group A during Round 2. A second facilitator
directed Focus Group B dunng Round 2.
The gu speakers were officials from various arees of the
United States who had either successfully implemented
land-based sludge management systems o were in the
process of implementing such programs. They were invited
in order to share their penences with the New York and
New Jersey sewerage authorities.
The sewerage authority officials e from the nine New
Jersey arid New York municipalities affected by the 006k
A representative from NRDC was induded in the
discuseion group beceuse of the organizations
involvement in the initIation of the roundtable mestlng.
2. RESOURCE PEOPLE
Resource people consisted of regulatory and enforcement
officials arid technology ei perta involved with various
aspects of sludge management or ocean dumping. This
group Included repreeentatves from EPA H quarters,
EPA Region Ii, and the tes of New York, and New
Jersey.
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3. OBSERVERS
Obser,ers were representatjves from an array of
public arid pirvate interest groups concerned with the
issues of ocean dumping and sludge management
EPA Region I I provided the planning group with a list
of more than 800 indrvidual who had attended public
meetings and/or permit hearings on sludge manage-
ment Issues or who had otherwise pessed an
inta in 008A Implementetion during the past year
Invitations e sent to au names on the mailing list.
Names and organizations of all roundtable attendees are provided
in Appendix B.
22 KEY ISSUES
The planning group recognized the importance of acquiring riput
for the roundtable agenda from the nine New Jersey and New York
sewerage authorities. Their input was requested to more dearly
define the goals of the roundtable and increase their comm itment
to participation The planning group pi oduced a questionnaire and
distributed it to all nine municipal sewerage authorrties and NRDC.
The respondents were encouraged to voice their concerns and
priorities through the completion of this quest,rrriaire.
2 2. 1 Results of the Questionnaire
The planning group de eIoped a list of 10 items that the New York
and New Jersey authorities arid NRDC were asked to rate in terms
of their importance as maior challenges to the implementation of
land-based sludge management alternatives. The respondents
were also asked for suggestions regarding how the roundtable
cou assist in addressing these challenges and what other topics
they felt should be indudad in the roundtable discussions. Au nine
municipal sewerage authorities completed the questionnaire (see
Table 2).
Perceived environmental risks and public health concerns ranked
highest in the questionnaire responses. The publics misconceg-
tions and resulting opposition affects several areas of land-based
sludge management: facilfty siting, the ability to obtain necessary
permrts facility flnandng, and the need for immediate action. The
.ãAR U County Department of Public Woiis (NCDPW) sicpresaed
a specific concern regarding the siting of lftiea, daiming t
there wes no time allowed ki the consent decree for educeting the
public on erMronmentsl and health safety , and that the media
misrepresents sludge managernent osusing unnecessary public
apprehension. The Linden Roesile Sewerage A thortty (LRSA)
ted that they aipect ‘strong. . . negative reaction from various
groups arid the general public’ In itt1ee siting.
1-6 Attachment 1

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TA&E 2. RESULTS OF THE QUESTiONNAIRE
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AJong with the problem of public misConCept ns, there were
sed’er other concerns expressed regarding site location planning
The New York City Department of Er v,ronmen j Protection
(NYCDEP) noted that other states are beginning the process of
tightening their regulations for acceptance of out-of-state sludge
The NCDPW defined interim facilrty siting as their most drfficuft
challenge because landfill space may be Impossible to obtain
Since landfllling is a common irrWim solution, the NCDPW
suggested that EPA review and produce an up-to-date list of landfill
locations and their specifications as a resource for the sewerage
authorities. The Westchester County Department of Enwonmental
Facilities (WCDEF) also commented on having drfficutty finding an
acceptable interim landfill site.
Both the L.RSA and the NYCOEP noted that the public review
process nec c ry for obtaining permits hinders quick decisions
on permit applications. Respondents commented that facility
financing also depends on public support, negative reaction to rate
increases can have major implications for projects
Atthough present-day technologies proved to be the least challeng-
ing issue in the questionnaire, tne NYCDEP expr sed a concern
that the technologies available today could become unusable in
the future owing to changing sludge regulations. Sewerage
authorities commented that future federal and state regulations
may prevent the exporting of sludge products Out of state
The marketing of sludge products appeared to be another issue of
concern The LRSA felt that sludge marketing was not a realistic
possibility The WCDEF stated that sludge qualrty limrts marketing
options. The PVSC expressed concerns regarding the length of
time needed to develop markets for sludge products and how to
subcontract to private vendors. The NYCDEP pressed an
addrtionai concern regarding markets, stating that as more federal
sludge products are produced existing markets will suffer. The
NCDPW acknowledged that sludge product marketing would be a
viable alternative unless changes in the federal sludge regulations
affect current markets The authority requested that the roundtable
clarify the proposed EPA sludge management regulations and
provide information on how to effectively use private contractors!
vendors fo tasks such as con ucting and operating facilities,
transporting sludge, and marketing sludge products. The WCDEF
suggested that it would be helpful if the regulators would declare
a clear position on the acceptability of management options and
the necessary sludge characteflstlca for sach. (The bJs of the
federal sludge management regulations i discussed in Section
31.5.) The NCDPW strongly suggested induding Interim planning
fix product management in the roundtable discussions.
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The PVSC expreesed an Iritereet In C rYtracts that re4ate to large-.
scale lanafIlling or other thaposal optiona Suggestec thacussion
topics were single versus multiple contracts, the appropriate length
of contracts, performance bonds, and single versus multiple Sludge
rnanagemern options. It recommended that examples of various
critracts and Specifications for managernent alternatives be
brought to the roundtable for review by the participants
2 2.2 Development of
Key Issues Based on
Questionnaire Results
Using the information from the questionnaire, the planning group
identified three goals for the roundtable
1 To fully under nd the ctors contributing to the
challenges being experienced by the municipal
sewerage authorities in the development of land-
based sludge management.
2. To define various strategies for handling the
challenges of land-based sludge management
3. To define realistic actions to be pursued in the
sUCCes8fuI — lementabon of land-based Sludge
management aflernatives.
Based on those iseues rated as most challenging, and other issues
identified by the respondents, the topics for discussion were
focused on two rnaior areas: (1) permitting and siting and (2)
technologies in relation to public health and environmental
concerns.
2.3 ROUNDTABLE STRUCTURE
AND PROCESS
The planning group formatted the roundlable in a manner that
wou stimulate productive discussion on strategies for attaining
land-based management solutions for wastewater treatment plant
Sludges. The 2-day roundtable consisted of three sessions (see
Table 3). A presentation on the tu8 of future 503 sludge
regulations followed the condusion of Round 1 on the first day
During the first and third rounds, the sewerage authorities, the
olitator, and the guest speakers set at the table; the resource
people and observers were seated around them. The dialogue
induded the sewerage authorIties. guest speakers, and the
facilrtator. The resource people participated in the discussion only
at the request of those seated at the table.
Attachment 1 1-9

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TABLE 3 ROUPIDTABLE AGEN . AND FO AAT
DAY I
ROUND 1 THE CHALLENGE
OB,JECT1VE
To fully understand the factors contributing to the challenges being cpenenced by muniopal
sewerage authorities in developing land-based sludge management.
• Welcome and opening remarks
• Introduction of rouridtable participarita
• Discussion of roundlable procedures and issues
• Open discussion
• Conclusion and consensus of Round 1
• Reception
• Presentation regarding proposed 503 sludge regulations
DAY 2
ROUND 2: DEVELOPING ALTE 4AT1VE STRATEGIES
OBJECTiVE
To define various strategies for handling the challenges of land-b ed sludge management
• Rotation of sewerage authorities betwesn two focus groups
Focus Group A Permitting and Siting
Focus Group B Technologies in Relation to PublIc Health and Environmental Concerns
ROUND 3: ALJST1C ACTiONS TO PUASLE
OBIJECT1VE.
To define realistic actions to be taken for the implementation of land-based sludge management.
• Open d ecuse on
• Conduelons
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Round 2 consisted of two focus group8 Focus Group A
discussed pemlitbng and sitng, and Focus Group B discussed
technologies in relation to public health and en’ ,ronmen j risks
EacI group had two sessions, one in the morning and one in
the afternoon. The guest Speakers fld the resource people
were assigned to a focus group based on their expertise and
remained in that group for both sessions. The sewerage
authorities ro ted between the two focus groups to discuss
both groups topics. In the focus group sessions, the resource
people sat at the table and entered into the discussion wrth the
sewerage aUthorTbee, Quest Speakers, and the facilrtator in each
group. Although observers were not allowed to participate
directly in any of the Sessaon , they were invited to submit
questions or issues for discussion.
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3.0 ROUNDTABLE
DISCUSSION SUMMARY
The roundtable opened with iniroductioris and comm by
RIChard Caspe, EPA Region II Water Management Division
Director He identified three overall objectives to be
accomplished by the roundtable
1 To establish a ngtwork of people experiencing
similar challenges.
2. To provide a forum for an open exchange of
lnfo(Tnatlon and ideas.
3 To provide an increased sensitivity to the issues
being faced by the New York and New Jersey
authorrties among all involved with sludge
management
3.1 ROIJND1:
THE CHALLENGE
Roger Dolan, general manager of the Central Contra Costa
Sewerage District. Cairfomia, served as the pnmary roundtable
facilitator and began the dialogue with comments on the issues
affecting land-based sludge management He then requested that
the participants introduce themsetves to the other roundtable
members. The representatives of the sewerage authorities and
NRDC summanzed issues that they wished to see eddressed at the
roundtable. Guest speakers from other sewerage authorities from
around the country, invited beceuse of their experiences in
implenieriting land-based sludge management technologies,
provided brief descnptions of their backgrounds.
During the discussion that followed, there was general consensus
g the participants that the schedules to terminate ocean
dumping are tight and, n most ceses . more drfficult than the
schedules faced by the guest speakers. The sewerage authority
representatives expressed confidence in their ability to meat the
d line for implementing long-term alternatives. Their most
criticel concern was meeting the agreed upon inteiim d linee
for ending ocean dumping. The New Jersey authorities were
concerned about the ewen more stnngant, state-mandated March
17, 1991, d line. Producing dewatered sludge and Pieuling it to
landfills was idenVfied as the most resilatlc interim land-based
alternative. The authorities noted that numerous difficulties are
associated with implementing this dieposal option, induding siting
dewatenng facilities and finding landfill sites, gaining public
a ptence, obteining rieceeeary te arid mun permits.
con&ru ng the neceasary faoll es, and transporting the
dewatered sludge to landfifls.
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311 Facilityand
Landfill Siting
Landfill siting was Identrfied as a critical issue by all of the New
York and New Jersey sewerage authorities Landfill sites are
severely limited in both states In New Jersey, landfilling is
prohibited except in the case of emergency or overriding
circumstances. fl is becoming increasingly difficult to find out-of-
state landfills, Pennsylvania has recently enacted an executive
order temporarily banning other states from access to their
landfills
The authorities also stated that finding locations to build
dewatering facilities presents a significant challenge While it may
be possible for some of the needed facilities to be built at the
wastewater treatment plants producing the sludge, New Jersey and
New York authorities with facilities in residential areas may face
intense public opposition to potential odors and the increased
truck traffic necessary to haul the dewatered sludge to disposal
sites
The guest speakers discussed how facility siting can be undertaken
by either private contractors or the sewerage authorities In some
cases, a contractor may be more successful than the sewerage
authority in locating a facility or landfill site In other situations.
the authority’s ability to deal with municipal officials may be
needed to acquire a site Cooperation between the sewerage
authorities and political officials is clearly necessary Unfortunately,
most politicians do not typically become involved unless a site is
chosen in their locality
NJDEP officials have stated that selection and implementation of
a land-based management alternative is the responsibility of the
sewerage authorities, pursuant to the New Jersey Ocean Sludge
Dumping Elimination Act Consequently, the state has declined to
intercede in out-of-state management options This position is of
concern to the sewerage authorities, for they believe that a team
effort is needed to successfully implement land-based disposal
ahernatives.
3 1 2 Public Acceptance
Clearly, gaining public acceptance of sludge management
alternatives is not easy The public may equate sludge with
sewage and oppose any land-based disposal or use in their own
backyard - The participants agreed that it is essential to educate
the public about land-based sludge management alternatives.
However, credibility is a key issue; the public is reluctant to believe
the municipal sewerage authorities. The guest speakers pointed
out that it is far more effective to invotve independent sources that
have positive public images to answer the public’s questions and
provide information. The guest speaker from the State of
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Washington described a project whereby 118 sewerage authorities
funded the University of Washington and Washington State Univer-
sity to support research and public information/education pro-
grams It was suggested during the roundtable discussion that
EPA become more involved in educating the public and that per-
haps the ocean dumping fees paid by the sewerage authorities
could be used to implement a public, information/education
program
Public opposition can be a major impediment in using facility sites
Considering the short time frames for implementing New York’s
and New Jersey’s interim plans, gaining public acceptance may
be especially difficult The NCDPW commented that it appears to
the public that one is asking for the publics acceptance after the
plans have already been put into place NRDC stated that it is
critical to involve the public in the initial planning stages, and noted
that the NYCDEP has effectively involved the public via the forma-
tion of a citizens advisor-y committee Another sewerage authority
agreed with the value of having such a committee but also
pointed Out that once a site is chosen, the anticipated impact on
the affected local community will still cause Opposition
3.1 3 Private Contractors
Using private contractors to build facilities and/or provide for
ultimate disposal appears to be a viable solution for the New York
and New Jersey sewerage authorities in meeting their interim plan
deadlines, however, the sewerage authorities noted several areas
of concern regarding the use of private contractors the RFP
process, legal restrictions, contract writing, using multiple
contractors, contractor versus authority responsibilities, and staff
availability to coordinate and manage contractors Some of the
guest speakers provided examples of RFPs and contracts to the
participating roundtable sewerage authorities
In choosing a contractor through the RFP process, the issuing
sewerage authority first determines which proposals appear to be
reasonable and responsible and then interviews the candidates.
The authorities were advised by the guest speakers to look at the
contractor’s applicable experience, responsiveness to the proposal
request (e g, Do they have a permitted site’ Do they have the
necessary subcontractors who can pass regulatory requirements’ 7 ),
and the price for the job. In New York, accepting a higher bid
requires a legal opinion. In New Jersey, a higher bid can be
accepted if lower bids are not submitted by responsible bidders.
Several of the guest speakers emphasized the need for multiple
contractors If a contractor defaults on his contract or it is
determined that a contractor should be replaced because of poor
performance, a back-up plan must be in place. Ultimate
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management responsibility rests with the Sewerage authority, not
with the contractor
The guest speskers provided some veluable success stones
concerning the use of private contractors, but in many cases those
Sewerage authorities were not under the same time constraints that
the New York arid New Jersey authorities face Requesting
proposals from the private sector, Setting up contracts, and
providing effective management Of contractors 8 time-consuming
In ximo the New York and New Jersey authorities have low
staff levels as compared to the staffing levels of the guest speskers
and they may have to rely on consii nts to help manage
con acto
3.1.4 Condusion
In concluding Round 1, the sewerage authorrties identified the
f lIowing issues for continued discussion during the second day
sessions
• Attaining public acceptance of sites in order to meet
compliance schedules.
• Managing contracts (setting up contracts, handling sludge
production vanability, single versus multiple hauling
Contracts, spill prevention/response plans)
• Dealing with critical time constraints in the implementation
process.
• Exploring cooperative regional efforts.
• Identifying pubhdy acceptable short-term strategies for the
sludge management
• Under nding the perceived and reel public concerns of
marketing sludge producta
• Establishing an information network for land-based sludge
management
3.1 5 New Sludge M agement
Reguldons Following the condusion of Round 1 of the roundtable, a
repreaentetive of EPA’s Office of Water Regulations and Standards
presented an update on the tus of the proposed federal sludge
management regulations. Pursuant to a tutory directive in
SectIon 406 of the Cleen Water Act. EPA proposed new risk-based
technicel sludge regulations in February 1999. Comments on the
proposed regulations are now being eddreesed, and EPA cpects
to Issue the regulations in final form in October 1991 Once
Attachment 1 1-15

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IssUed, these regulations will appesr at 40 CFR Part 503 and will
esl an minimum federal standards for the use and disposel of
Sewage sludge when applied to land, thstnbuted and marketed,
placed in sludge-only landfills or on surface disposel sates, or
ifl flerated. In addition to the 503 regulations. EPA also propos
in August 1968 the Muniopal Solid Waste Landfill Rule. which
regulates all sewage sludge to be tandfllled EPA expects to issue
the final rule in May 1990.
32 ROUND 2:
DEVELOPING
ALTERNA11VE STRATEGIES
Members of EPA, N JDEP, and NYSDEC joined the guest speakers,
sewerage authorities. and NRDC in the focus group discussions on
the second clay of the roundtable. The purpose of these break-
out groups was to discuss the issues introduced in Round 1 in
greater detail. The topice were divided into two Sections (1)
technologies in relation to public health and environmen l
concerns and (2) permitting and siting
32.1 FocusGroupA:
Technologies ki Relation to
PublIc Health and
En*onmen
The two Focus Group A sessions primarily addressed the issues
of public misconception and acceptance; traditional technologies
such as land application and inaneratlon; less conventional
technologies such as chemical fixation or coal gasification, the
techniques used in the successful implementation of a dewatering/
landfill dispossl system: and the sewerage authorities’ concern for
using the best technologies for long-term land-based sludge
management plans.
3.2. 11 Public HeaWi and
Environmental Concerns
Guest speakers cpenenced in the use of land application,
con’tposting, and inonerabon discussed ther operations. These
pract)ces frequently generate public opposition: consequently.
the authonties often cannot enlist the support of the local
pollbcians or officials. In many cases , opposition stems from the
fact that many people equate sludge with hazardous waste. They
assume that if sludge is unesfe for ocesn disposal, it is also
unsafe tar nd-bssed management alternatives. The public fasrs
Uiet composted sludge will poison the food chein and sludge
incineration will release toians into the air.
It is essential to educate the public on the regulations conti ’olling
the quality of sludge and land-based management options No
matter what regulations are in place, h er, It will usuAlly be
difficult to gain public ptence, pertlcular$-y when matanal is
1-16 Attachment 1

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moved from one juriadiction to ariotj,e’ A poesible way to
convince people in another juriSdiction to accept sludge is to ShOw
them that the very Junathotion that produces the materiaj is aiso
using a substasmaj amount M authority should be aware that this
approach could backfire and leed to opposition to currer tJy
accepted in-etate pra cet
The sewerage authorities emphasized the need for credible
inrmanon sour and suggested that EPA become more
involved in educating the public, it is crucial to gaining public
acceptance that people receive ptanaijong in simple terms.
scientific jargon tends to ceuse confusion. Also, terminology
modifications were suggeet . The word s/udge Should be
replaced with a more positive word and the term solid waste
should be avoided. Ae(ernng to sludge as waste creetee a
problem in perception, it implies that sludge must be disposed of
and cannot be used for beneficial purposes.
[ EDITORLAL. NOTE. While adopting more positive
terminology may be beneficial from a public acceptance
standpoint, the use of s/udge or so/id waste can be
impor nt in maintaining disposel options. In New York
State, referring to sludge as solid wa_ste allows a
municipality to enter unto long-term cornracta for
privatization under the New York State Municipal Law
12 V. If the material was not c’ass’fled as a solid waste,
the sewerage authorities would not have this option]
32.1.2 Technologies
In the discussion of new technologies, it was evident that the
sewerage authorities were keenfy interested in au possible
alternatives, especiaRy beneficial use. Se.wal newer technologies
were mentioned, induding gasification of sludge to produce energy
and an inert, glaaallke material, and a Japanese process that turns
incinerator ash into glassy. sendy material suitable for use in tile.
Incineration is the long-term land-based alternative for many New
Jersey authorities. The sewerage authorities and guest speakers
discussed the venous types of furnaces and the quality of air
emissions and ash that each produ , as w l as the problems
associated with ash hauling and lanCflhIlng.
3.2.1 3 Dewe 1ng/Lanc1flhl
In 1987, the City of Los Mgeies ed time constreinta similar to
those of the New Jersey and New York authoit es’. To quickly
terminate oc durnp.ng, Los Angeles de eloged a program for
sludge dewataring and landfill dispoesi. The Los Angeles guest
speaker deacilbed the clty s cpenence in detail, answering
qu ons arid providing copies of RFPs.
Attachment 1 1.17

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The Loe AJ geles guest speakers description of the RFP process
for aecunng the services of multiple contractor S induded details
such as average contract size, duration of contracts, division of
work based on daily variabilmes of sludge volume, and meeting
city procurement requirements. The speaker explained that an
attorney from the Board of Public Works was assigned exclusively
to the s orage authority for the negotiation and compilation of
contracts. Thia helped to ensure that the authority was in
compliance with city requirements during every step of the
pr000as When the authority went before the Board of Public
Works with l recO imendatlons, the city attorney was present and
handled all legal questions, testst ang to the compliance of the re-
commendations with all city procurement requirements.
The landfill dispoesi process also described in detail, addressed
truck-hauling logistice that included establishing routes, monitoring,
weighing, spill-response plans, schedules, costs, and loading
facilities The guest speaker emphasized that using multiple
contractors established a competrtr e environment that promoted
better performance and re abilrty.
3.2.1 4 Aiternative Selection
The sewerage authorities discussed various sludge management
technologies currently available and the possibility of newer and
better technologies being developed. The New Jersey authorities
raised a concern that their choic für meeting the legislative
requirements to end ocean dumping might not be the best long-
tern alternatives with respect to the environment and public hesith
They commented that the consent decree schedules might not
allow than enough time to thoroughly investigate all possible
alternatives. There ls little time for the sewerage authorities to
effectively work together, sharing their knowledge of new
technologies and options and developing potential regional project
alternatives that might result in signrficent cost savings. In addition
to the consent decree scheduling constraints, there are other
pressures to move quickly into long-tern programs. For mple.
the high eicpenee of the intenm solution necessitates the
changeover to a long-term solutlon as quickly as possible. Also,
it ia not known how long landfills will continue to be available:
before the limited space filled, sewerage authorities must have
alternative solutions In place.
EPA belIeves V ’wt the negotiated agreements allow sufl .clent tlme
for the selection of long-term land-based technologies. Some of
the guest a rage authorities disagreed, based on their pest
cperlences in researching and Implementing related programs.
The group discussed further the reality of the cOnsent decree
estrainte In regard to making choices and the problems of
changing alternatives In m streem. With reference to technologi-
osi assessments It wes pointed out that the public often questions
1-18 Attachment 1

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*t y the authomi do not look at other technolo cal &terr ative
It was sugg ed that EPA might become involved in the research
and assessment of hriologies on a riatlonai lava Such involve-
ment wou hslp all sewerage authorities in the development of
long-term programs that are accepteble to the public NRDC
stated t it would support ailowrng more time for long-term
deosions if potential technologies could be adequately analyzed
3.22 Focus Group B:
S ng w Pe thng
The two Focus Group B sessions centered on the challenge of
sating arid implementing sludge management systems that adhere
to both te agency permitting procedures and the consent
decree acheduls. NIJOEP and NYSDEC differ in their required
deadlines for the sewerage authorities to identify their long-term
sludge management solutions and the degree of support given to
the authorities in this process. Descriptions of the efforts made
and time frames involved in devsioping and implementing sludge
management projects by the Seattle and Phi’adelphia guest
speakers emphasized the need for adequate time and flexibility to
suffloerttly analyze new technologies or multple systems. The
New Jersey statute imposes a ngid March 17, 1991. deadlIne
(Which NJDEP is not authorized to change) to cease ocean
dumping. The guest speakers presented some worthWhile
strategies for expediting the perrnittrng and siting of new faolities.
322.1 Slate Requirements
The New Jersey sewerage auttio.ltee were required by NJOEP to
identify both their interim and long-term sludge management plans
by Aplil 19w. Five out of the sax sewerage authorities h&ve
identified inonerabon as their long-term opbon. Their n step
involves going through th te permitting process, Which will
address the environmental and public health impacta of the
proposed teciftbes. These sewerage authorities behe.e that this
mandate and thor consequent commibTieni to inoneration
predudes them from further pursuing other technologies and
benefloal reuse The sewerage authonties indlceted that private
contraators have been unwilling to commit the ne ary large
sums of money in advance for protects with development schedule
durations of l ewi 1.5 to 2 years. UnfoaturieWy, that type of
schedule is flat within the tlme constrainta of the consent
deoree&eriforcemervt agreements.
NJDEP stated tl t the sludge management plans submItted in
April 1999 cen be mxftfled only if there is a strong demonati’atlon
that a dlf!erent alterristlve I prOerable and the designated
schedule w not be sçnlflcently disrupted. The sewerage
authontles ted that they feel pressure to implemerfl their
currently designated technologies In order to meat the mandated
Attachment 1 1-19

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schedules and are thus unable to explore oti ’ier lOng-tei’m
alternatives.
NYSDEC requires its sewerage authorities to complete an
enwOnrnentaj impact statement before they designate their long-
terni alternatives. NYSDEC acknowledged that the sewerage
authorities do need to have schedules in place to effectively
implement long-term plans. However, NYSDEC also recognizes
that there cou be events. such as the pending Federai 503
sludge regulations, that wou necessitate flexibility in enforcement
of the consent decrees. To rnmodate such potent changes.
they will monitor the Sit 8tlon, and be flexible dunng the planning
process. The planning process. however, cannot stop due to
pending changes In technology and regulations NYSDEC
representatives emphAsised that they recogrnze the difficulties that
the municipal authorities will encounter, and that they are fully
committed to overcoming the gridlock in the permit process,
particularly in venturing into new areas of technology -
Both states noted their inability to be involved in siting issues,
neither NYSDEC nor NJDEP has the authority to locate sites or
to overrule local zoning except in the case of hazardous wastes
NJDEP requsres under the State Solid Waste Management Act,
that each of the counties. in the solid waste districts. site sold
waste facilities. The responsibilrty for siting lies witti the sewerage
authorities until such time as the counties can implement the
sludge management components of its solid waste management
plans. None of the affected counties have yet implemented these
plans.
3.222 Time Constraints
The expenencee a land-based sludge management related by the
guest speakers suggested a realistic time frame for implementing
the New York and New Jersey sewerage authorities’ programs.
Much of the necessary permitting has aireedy been accomplished
by New Jeraey s sewerage authorities: all six authoritIes have
received d atering permits and have implemented pretreatment
programs. In genera, me amount of time required for guest
speaker authorTtles to obtain all of the state and local permits
necessary for both sites and full-scale facility operations was a
crucial factor For mp4e, the gu speaker from Phuledelpt ia
ted that me authority anticipated a ban on ocean dumping in
the 1970s and thus began developing a 10-point alternatrve
program dunng 1977. In 1979, when its ewatar b’eaunem
plant facilities were required to be upgreded to secondary
treatment, the city in tuted atnngent Pretreatment programs.
Over a 5-year perIod, research was funded on vetious projects
such as strip-mine reclamation: a paridand od factory’ protect,
using compost on city facilities; an un u 6&ul liqu nd
appl tion: and trying an Eco-rock process of fusing dewatered
1-20 Attachment 1

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sludge with mun apaJ refuse to produce pavement aggregate
Thu& in 1980, w1 en Philadelphia was Informed tliat the city cou
no longer dump in the ocean, the city was prepared, these test
programs allowed the city to determine their most effective
alternative and to Subsequently implement these alternatrves.
The gu speaker from Seattle stated that the authorrty faced
similar challenges in 1972 when the city was forced, under ngt it
time constraints, to end ocean disposal At the time, it had a
lagoon with only a 1-year sludge storage capacity arid was looking
at Innovative ways of dewatenng sludge. M RFP was issued to
solicit private seCtor propo a The University of Washington,
which had a small pilot sludge application program under way on
forest land, cam . forward with a 2-year proposal to taIe Seattles
sludge and. In tam, use the monies received to perform resaercri
and answer public health questions related to land application In
1973, Seattle ceased ocean dumping with only the university
research program under way: the lagoon was used as a backup
disposal option From that time through 1982, Seattle continued
its efforts to find addrt;onal sludge management methods. By
1984, strip mines were taking 25 percent of Seattle’s sludge for
use in land reclamation. In 1988, Seattle awarded a contract to a
private company for sludge d atenng It now owns and manages
for land that is used to recycle sludge and has contracts with a
private company to apply sludge to the company s property
Overall, Seattle’s strategy has been to avoid high-cost facilities and
to keep options open. Seethes Current sludge management
program has taken 17 years to ewolve. In concluding, Seattle
stated that sludge management costs money, requires enormous
amounts of time to pursue, and 8 very challenging in terms of
budgeting.
3 2 2.3 Public Accept8ilce
and Siting Strategies
The guest speakers discussed numerous public acceptance and
siting strategies. The following points were stressed
1. Keep alert to opportunities and have a planning
process that contains some fiexibilfty for change.
2. If poselbie, find and use a sate that Is already owned
by the authority.
3. For an out-of-state elte, secure a local sponsor who
wante the material and will personally represent the
pr eot and pursue any neceasery pe
4. Advertise In other localities for available sites.
5. Regional cooperation necessary for siting and
Attachment 1 1-21

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ng iii of state landfills, meet iriformaily wrtti
elected and appointed officials early-on ri the process
6. Maintain contacts with key regulatory agency staff
members to ensure that permit applications receive
pnorTty attention and expeditious handling
7 Obtain clear directions from the appropriate states
regarding requirements for facility permitting
& Obtain support of state and local agencies to
coordInate and allow for expedrtous handling of
permr
9. Pursue public education through a cooperative
regional effort
10 Take a proactive stance to address misinformation
spread by project opponents, to help generate
positive press, find sympathetic arid knowledgeable
reporters and take them to model operations.
11. Work with the state regulators and legislators to
redefine sludge classifications, current classification
of sludge as solid waste generally limits management
options and creates a negative public image
12. Produce appealing public displays of sludge products
to hep provide a positive image and promote
beneficial use
3.3 ROUND 3:
REAUST1C ACT)ONS
TO PURSUE
The sludge management roundtable addressed the concerns arid
challenges presented by all of the groups involved in the struggle
to implement land-based sludge management alternatives. (1) the
city, state, and federal legislators who will make, or have made,
decisions on sludge management. (2) the regulators who enforce
the legislative decisions, (3) the sewerage authorities responsible
for implementing sludge management altamatrves (4) the private
contractors employed for sludge management, (5) the en-
wonmentai and public health activists, and (6) the public, who, in
many in ncee, beli e that their health and personal properly
may be jeopardized by the recommended sludge management
methods. The roundtable provIded EPA. the te agencies and
NRDC with an increased sensitivity to the ieaues being ed by
the New York and New Jersey sewerage authorIties in pursuing
and implementing interim and long-term alternatives. The
sewerage authorities benefitted from the in-depth information
1-22 Attachment 1

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exchange that took place during the roundtable, as many
strategies and POssible endeavors were the ssed . In ed irtion to
the strategies diso’ss 1 in the Permitting and Siting secton
(Section 322), the following sugg ons were mede.
1. Establish as, information deennghouse. possibly by
or with support from EPA.
2. Continue the network poces that began 8t this
roundtab le.
3. Seek cooperation at all leials: federal, state. locel,
and pnvate sector.
4. Consider the po 8ibdlty of regionaiization in the
development of long-term solutions.
5. Increase sewerage authority staffs for the negotiation
and management of multiple contracts with the private
sector
6. Use multiple contractors and diversilicetion in sludge
management options.
7 Involve a city attorney knowledgeable in the oca
permitting regulations for negotiating contracta
8. Inc-ease public awareness of the sewerage authorities’
decision-making processes and sludge management
acv .itiee along with the effect on public health and the
environment, possibly through more involvement by
EPA.
The New York and New Jersey sewerage authorities expressed
their gratitude to EPA for holding the roundtable arid reiterated a
firm commitment to meeting their deadlines arid succe ulty
terminating ocean dumping. The sewerage authorities strongly
voiced their desire to implement the most environmentally sound
sludge management alternatives arid expressed a willingness to
remain open-minded arid f exibie in their implementation plans.
They also expressed the hope that the regulators maintain the
seine open-mindedness and flaiab4lfty.
Attachment 1 1-23

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APP€ND X A
ROUNDTAELE PL N NG GROUP MD
Fe er i Bruce Kiselica Enwonmentei Protection Agency Region I I
Ekzabeth Lonoff Enwonmentej Protection Agency Region II
Karen Kiima Office of Marine & Estuarine Protection
Sandy Germann Office of Mailne & Estuanne Protection
Lee Pasarew Office of Municipai Pollubon Control
Bob Bastian Office of Muniapai Pollution Control
State Helen Pettrt New Jersey Department of Environmental Protection
Penny H ferty New Jersey Department of Environmental Protection
Bob Hampston New York State Department at Environmental Conservation
Consultanis Car ton Hunt Battelle Memorial Institute. Duxbury Operations
Eksabeth Smoiski Battelle Memorial Institute. Duxbury Operations
Linda Hanrfin Hanifin Aseociatee, Inc.
Nola Sparks Han n Associatee. Inc.
1-24 Aflacflment I

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APP D X B
ROUNOTABLE ATTEICEES
Name Organizat ion
DISCUSSION PARflC IPANTS :
FACIIJTATORS.
Primary & Focus Group B
Roger Dolan Central Contra Costa Sewerage DistrIct
Focus Group A
Urida Hanrfin Hanrfin Associates, Inc.
SPEMERS
Eric Buehrens Massachusetts Water Resources Authority
Peter Machno Municipality of Metropo1rtas Seattle
Gary Gagnon Mitwaukee Metropolitan Sewerage Digtnct
Michae’ J Wallis East Bay Muniopal Ubilbes DistrIct
Thomas E. Walton, III formerly with City of PhiledOphia
Ray Kearney City of Los Mge ee
SEWERAGE AUTHO 1Y OFFICIALS & C
Edward 0 Wagner NY City Dept of Environmental Protection
Steven A Fangrnann Nassau County Dept. of Public Worica
Nicholas R. Smolney Middlesex County Udkbee Authority
Jerome Sheehan Bergen County Utilthee Authority
Richard P Tokarskl Rahway Vafley Sewerage Authority
Michae’ J. Brinker, Jr. Joint Meeting of Essex end Union Counties
Gary G Fare Linden Rosalie Sewerage Authority
Joseph La Vigna Westchester County Dept at Ervv. Facilftlee
Sheldon Lipice Peesaic Valley Sewerage Comm aionera
Nina M. Sankovitch Natur i Resources Defense Council
lliam R. Dl nond EPA HO
ftJanRub n EPAHO
Robert Bastlan EPA HO
Martha KrkpatncM EPA HO
Richard Caspe EPA Region N
Charles E. Hoffmann EPA Region N
Attachment 1 1-25

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ROUNDTA8LE ATT DEES
Name Organization
RESOIJRCE PEOPLE (continued)
Bruce K se1ice EPA Re on II
Robert G. Hampston NY State Dept of Enwonmental Coneervaton
Richard J Hammond NY State Dept. of Enwonmentai Conserveton
Helen Pettit NJ Dept of Environmental Protection
OBSERVERS
Robert E Adams.’i Borough of Brooktyn
Kelley Augustine NJ Dept. of Environmental Protection
Iclal Atay NJ Dept of Environmental Protection
Nicholas Bartilucci Dvirka & Bartilucci
Diane Black Leegue of Women Voters
Marci L Bortman U.S House of Rep. Committee on Merchant Manne & Fisheries
Laurel Bryant U S. House of Rep. Committee on Merchant Manna & Fisheries
Marjorie Bryant New York City Coun l
Julian Capik Middlesex County Environmental Coalition
Henry J. Chiupsa Ovirka & Bartilucci
Chris Clark Apex Resources/NSI
Don Clark Cornucopia of New Jersey
James I Collins Industrial Innovatons, Inc..
Kevin Cant Demetrakis, Sinisi & Carn el
Vincent Corrado Pas8aic Valley Sewerage Commtss oners
C J Crumm Foster Wheeler USA
Rutgers University/Cook College
John Dedyc Seelye, Stevenson, Value & Knecht
Bonnie Delaney Asbury Park Press
Chris Dollase U.S. House of Rep. Committee on Merchant Mailne & Fisheries
Arid rew L Do 1e Rahwey Valley Sewerage Authority
jennifer Epp NY State Senate Subcommittee on Long Island Mailne D stnct
Hugh Ettinger Bedminster Bioconversaon Corporation
Tracy Faulkner Chem x Technologies, Inc.
Rod Fujrta Environmental Defense Fund
Sandy (3ermann EPA HO
Karen J. GlroL Rutgers University/Cook College
Penny Hitferty NJ Dept of Environmental Protection
Canton Hunt Battelle Memorial Institute, D ury Operations
Thomas & Immerso N* ii County Dept of Public Works
Stephen Johnson Pennaytvania O.E.M.
Natasha Kaplan Thomas E. Walton Associates, L .
1-25 Attachment 1

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AOUNDTA&E AT1D4C€ES
Name Or an,zation
OBSERVERS (continued)
Herbert L Kaufman Clinton Bogert Associates
Carl Koch Greeley & Hansen Engineers
Ernest A. KoIIr des Dehydro-Tecti Corporation
Bob Kukenbecger Blasland, Bouck & Lee
Ellen Lane Gannett Westchester Newspapers
Elizabeth LOI’ir Sludge Newsletter
Elizabeth Lonoff EPA Region II
AIlonso Lopez NY City Dept. of Enwonmental Protection
Per A. Loren en, Jr Global Energy, Inc
George Lutzic NY City Dept of Environmental Protection
Larry McClure Bergen County Utilities Authority
Wilkam Mikul Blasland, Bouck & Lee
Percival Miller NY State Legislative Commission on Sold Waste Management
Fred Munson Greenpeace USA
Barbar Novick League of Women Voters
Lee Pasarew EPA HO
John J Pascucci Nassau County Dept of Public Works
Herman P Phillips, Jr EPA Region II
Mahest Podar EPA HO
Robert L Raab City of Long Beach, NY
Gerald 0 Rennerts Sludge Disposal International, Ltd
Kevin Richardson Star Laiga’
Peter Ruffier Association of Metro Sewerage Agencies
He4rnut W Schulz Global Energy, Inc.
Irving F Shaw Mayor, Village of East Rockaway, NY
Tim Shea Engineering Science. Inc.
Elisabeth Smoiski Battefle Memonai Institite, Duxbury Operations
Nola Sparks HanMn Asaociate , Inc.
William C Sullivan, Jr Gordon, Gordon & Haley
Pate Tortonci Bay Park Civic Association
Judith Wells U S. Houae of Rep Committee on Merchant Manne & Fisheries
Vicki W___ HanifIn Associates. Inc.
Can Wild J Dept. of Enwonmental Protection
Attachment 1 1-27

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ATTACHMENT 2
MAJOR REFERENCE DOCUMENTS PREPARED BY EPA
ON SLUDGE MANAGEMENT ISSUES
April 1990
U. S. Environmental Protection Agency
Office of Marine and Estuarine Protection
Washington, DC 20460

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EPA 1989 EPA’s Policy Promoting the Beneficial Use of Sewage Sludge and the New Proposed
Technical Regulations Office of Water, U S Environmental Protection Agency, Washington DC
EPA 1989 Environmental Regulations and Technology Control of Pathogens in Municipal Wastewater
Sludge EPA 625/10-89-006 Center for Environmental Research Information u S
Environmental Protection Agency, Cincinnati, OH
EPA 1989 Summary Report In-Vessel Composting of Municipal Wastewater Sludge EPA 625/8-89-
016 Center for Environmental Research Information, U S Environmental Protection Agency.
Cincinnati, OH
EPA 1989 Start-up and Operation of Chemical Process Technologies in the Municipal Sector The
Carver-Greenfield Process for Sludge Drying EPA 430/09-90-007 Office of Water, U S
Environmental Protection Agency, Washington, DC
Epstein, E and J Alpert 1987 Composting Municipal Sludge. A Technology Evaluation Water
Environmental Research Laboratory, U S Environmental Protection Agency, Cincinnati, OH
EPA 1987 Dewatering Municipal Wastewater Sludges Design Manual EPA 625/1-87-014 Center for
Environmental Research Information, U S Environmental Protection Agency, Cincinnati, OH
Page. A L, I Logan and J Ryan (eds) 1987 Land Application of Sludge Lewis Publishers, Inc.
Chelsa, MI (EPA sponsored)
Cole, W D. Henry. C L and W L Nutter (eds) 1986 The Forest Alternative for Treatment and Utilization
of Municipal and Industrial Waste. University of Washington Press, Seattle, WA (EPA sponsored)
EPA 1985 Handbook Estimating Sludge Management Costs EPA 625/6-85-010 Water
Environmental Engineering Laboratory and Center for Environmental Research Information, U S
Environmental Protection Agency, Cincinnati, OH
Kowal, N E 1985 Health Effects of Land Application of Municipal Sludge EPA 600/1-85-015 Health
Eftects Research Laboratory, U S Environmental Protection Agency, Research Triangle Park,
NC
EPA 1985 Composting of Municipal Wastewa’ter Sludges (Technology Transfer Seminar Publication)
EPA 625/4-85-014 Center for Environmental Research Information, U S Environmental
Protection Agency, Cincinnati, OH
EPA 1985 Composting of Municipal Wastewater Sludges (Technology Transfer Seminar Publication)
EPA 625/4-85-014 Center for Environmental Research Information, U. S. Environmental
ProtectIon Agency, Cincinnati, OH
EPA 1985 Handbook Estimating Sludge Management Costs. EPA 625/6-85-010. Water
Environmental Engineering Laboratory and Center for Enwonmental Research Information, U S
Environmental Protection Agency, CincinnatI, OH
EP& 1984 Municipal Sludge Combustion Technology (Technology Transfer Seminar Publication) EPA
625/4-85-015 Center for Environmentai Research lrrformation, U S Enwonmental Protection
Agency, Cincinnati, OH
Attachment 2 2-1

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EPA 1984 Municipal Sludge Combustion Technology (Technology Transfer Seminar Publication) EPA
625/4_35.-015 Center for Environmental Research Information, U S Environmental Protection
Agency. Cincinnati, OH
EPA i984 Environmental Regulations and Technology Use and Disposal of Municipal Wastewater
Sludge EPA 430/10-84-003 Intra-Agency Sludge Task Force, Washington, DC
EPA 1984 Septage Treatment and Disposal Handbook EPA 625/6-84-009 Municipal Environmental
Research Laboratory and Center for Environmental Research Information, U S Environmental
Protection Agency, Cincinnati, OH
Page, A L. T L Gleason, III, J E. Smith, Jr. I K Iskandar and LE Sommers (eds) 1983 Proceedings of
the 1983 Workshop on Utilization of Municipal Wastewater and Sludge on Land University of
California, Riverside, CA (EPA sponsored)
EPA 1983 Land Application of Municipal Sludge Process Design Manual EPA 625/1-83-016 Center
for Environmental Research Information, U S Environmental Protection Agency, Cincinnati. OH
Sapper. WE, E M Seaker and R K Bastian (eds) 1982 Land Reclamation and Biomass Production
with Municipal Wastewater and Sludge The Pennsylvania State University Press University
Park PA (EPA sponsored)
EPA 1982 Sludge Recycling for Agricultural Use EPA 430/9-82-008 Office of Water Program
Operations U S Environmental Protection Agency, Washington, DC.
EPA 1982 Sludge and the Land The Role of Soil and Water Conservation Districts in Land Application
of Sewage Sludge
EPA 430/9-82-007 Office of Water Program Operations, U S Environmental Protection Agency,
Washington, DC
CAST ‘1981 Effects of Sewage Sludge on the Cadmium and Zinc Content of Crops. EPA 600/8-81-
003 Municipal Environmental Research Laboratory, U S Environmental Protection Agency,
Cincinnati, OH
EPA 1980 Innovative and Alternative Technology Assessment Manual EPA 430/9-78-009 Office of
Water Program Operations, U S Environmental Protection Agency, Washington, DC, and
Center for Environmental Research Information, U. S. Environmental Protection Agency,
Cincinnati, OH
Brittcn, G, B L Damron, G.T Edds and J M Davidson 1980. Sludge - Health Risks of Land Application
Ann Arbor Science Pubi Inc /The Butterworth Group Ann Arbor, Ml (EPA sponsored)
EPA 1980 Evaluation of Sludge Management Systems: Evaluation Checklist and Supporting
Commentary EPA 430/9-89-001. Office of Water Program Operations. U S. Environmental
Protection Agency, Washington, DC
Sapper, W E and S N Kerr (eds). 1979. Utilization of Municipal Sewage Effluent and Sludge on Forest
and Disturbed Land The Pennsylvania State Unr ersity Press. Universdy Park, PA. (EPA
sponsored)
2-2 Attachment 2

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EPA 1979 Sludge Treatment and Disposal Process Design Manual EPA 625/l79. 0i 1 Municipa’
Environmental Research Laboratory and Center for Environmental Research Information U S
Environmental Protection Agency, Cincinnati, OH
EPA 1978 Municipal Sludge Landfills Process Design Manual EPA 625/1-78-010 Center for
Environmental Research Information, U S Environmental Protection Agency, Cincinnati, OH
EPA 1978 Sludge Treatment and Disposal EPA 625/4-78-012 Vols 1 & 2 Center for Environmental
Research Information, U S Environmental Protection Agency, Cincinnati, OH
NAS 1978 Multimediurn Management of Municipal Sludge Vol IX Analytical Studies for the U S
EPA, National Academy of Sciences, Washington, DC (EPA Sponsored)
C A S T 1976 Application of Sewage Sludge to Croplarid Appraisal of Potential Hazards of the Heavy
Metals to Plants and Animals EPA 430/9-76-013 (MCD -33) Office of Water Program
Operations. U S Environmental Protection Agency, Washington, DC
EPA 1977 Municipal Sludge Management Environmental Factors EPA 430/9-77-004 (MCD-28)
Office of Water Program Operations, U S Environmental Protection Agency, Washington, DC
Attachment 2 2-3

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