Number: 1983-02
WHEREAS, enormous quantities of sewage sludge are produced in the United States as a by-product of sewage treatment; production levels are increasing dramatically; such sludges are often highly contaminated with industrial chemicals; and the environmentally sound disposition of these sludges is becoming an increasingly difficult problem throughout the nation; and
WHEREAS, economic and political pressures are growing to dispose of contaminated sewage sludge in the oceans–as a free and easy, “out-of-sight-out-of-mind” dumping ground–and the federal government has failed to adequately enforce existing restriction on such disposal under U.S. and International Law; and
WHEREAS, pretreatment of industrial discharges into publicly-owned treatment works can often result in greatly reduced contaminant levels in sewage sludges and is thereby the key to safe sludge management, regardless of the disposal or use alternative chosen; and
WHEREAS, state-of-the-art thermal reduction techniques (including incineration and pyrolysis) for sewage sludge, coupled with adequate air pollution controls and industrial pretreatment, provide a safe means of destroying or reducing even highly contaminated sludges, often with the production of useful energy;
NOW, THEREFORE, BE IT RESOLVED that the National Wildlife Federation, in annual meeting assembled March 17-20, 1983, in Albuquerque, New Mexico, strongly urges the U.S. Environmental Protection Agency (“EPA”) to expeditiously promulgate regulations, as required by Section 405 of the Clean Water Act, establishing guidelines for the safe multimedia management of sewage sludge; and
BE IT FURTHER RESOLVED that the National Wildlife Federation urges EPA, in revising its regulations under the Ocean Dumping Act and in pro- mulgating its sludge management regulations, to give appropriate recognition to the special economic and political vulnerability of the ocean and, consequently, to discourage use of the ocean as a first-choice sludge disposal alternative for coastal municipalities; and
BE IT FURTHER RESOLVED that the National Wildlife Federation urges EPA and the Congress of the United States to support a policy of discontinuing the ongoing ocean disposal of highly contaminated sewage sludge and of prohibiting the initiation of such disposal by new sources; and
BE IT FURTHER RESOLVED that the National Wildlife Federation urges EPA to expeditiously promulgate regulations governing the marketing and distribution of sewage sludge as a fertilizer or soil conditioner, and that such regulations: (a) provide adequate safeguards (including labeling requirements) against the misuse of such sludges in home gardens and on cropland, and (b) do not unduly restrict such marketing and distribution of composted or treated sludge; and
BE IT FURTHER RESOLVED that the National Wildlife Federation urges EPA and state governments to promote the development and use of state-of-the-art thermal reduction processes (with energy recovery where possible) for treatment and disposal of contaminated sludges that are not suitable for direct land application; and
BE IT FURTHER RESOLVED that the Federation recognizing that removing industrial contaminants at the source is the key to safe sludge management, urges EPA and state and local governments to immediately formulate, implement, and enforce total industrial pretreatment programs to avoid interference with sewage treatment and sludge management programs.