519 
and now as a senior member of an implementing agency, on the 
very question of how do we manage our sludge. And the key word 
is management, not dump. 
We urge this committee not to adopt legislation which would pre- 
clude a thorough evaluation of the limited number of viable op- 
tions that are available to managing this very, very difficult ques- 
tion, including managing ocean disposal. The most satisfactory so- 
lution to this major environmental problem cannot, in my judg- 
ment be achieved if the use of any of the media, air, ocean, or land, 
were to be removed from consideration by legislation which phased 
out or prohibited its use. A legislated phase-out or prohibition of 
managed ocean disposal of sludge would eliminate the opportunity 
to weigh the costs, both economic and social, and the environmen- 
tal consequences of the various land based alternatives versus the 
cost and environmental effects of ocean disposal. 
Since I think we can at least agree on one thing, that the produc- 
tion of sludge must continue, the legislation should enable the most 
satisfactory solution from society’s point of view, considering both 
the environmental and economic cost to be carried out. I want to 
stress, and I think it has been highlighted here, particularly by Dr. 
Goldberg, that at this point in time we simply do not know enough 
to establish the environmental effects of the two viable options that 
we have in our coastal area. That is our part of the coast, Congress- 
man Hughes, namely, some form of thermal destruction or man- 
aged ocean disposal. 
There are very significant gaps in our knowledge of the use of 
the land for ultimate disposal, incineration, and particularly with 
reference to incineration, the air quality impacts and what do we 
do with the ashes produced through thermal destruction, because 
you will ultimately be left with approximately one-third of the 
amount of product that you put into the incinerator. There is 
where the sludge question, using thermal destruction is translated 
into a solid waste disposal question, which in turn gets into an- 
other whole series of unknowns. 
There is a need in our judgment to adopt a well thought-out 
strategy to fill in the gaps, answering such questions as what crite- 
ria should be applied for determining unreasonable degradation, 
what is a significant environmental effect, what are reasonable 
risks for society to accept, whether it be incineration or managed 
ocean disposal of sludge. 
Ultimately, in my opinion, there has to be a tradeoff with regard 
to the cost and environmental impacts of the two viable options for 
our agencies in northern New Jersey, namely, ocean disposal or 
some form of thermal destruction. Direct application to the land is 
not a viable option, since the land areas which are required are 
massive, particularly land areas with suitable geology, none of 
which are available in the State of New Jersey, although we must 
say that someone did suggest to us that we see if New York State 
and Pennsylvania would like to take our sludge and dispose of it on 
their land, and we were obligated to raise the question. I daresay 
we got back the expected answer. 
Several years ago when the Federal law required us to cease 
ocean disposal of sludge by the end of 1981, we did not have the 
benefit of the many engineering studies that have been undertaken 
