521 
getting out of the ocean in 1981, plus the environmental studies 
and an air pollution control consultant whom we retained for our 
proposed incinerator, and we proposed that at a cost of somewhere 
perhaps around the $18 or $19 million figure, we made a promise 
to the State of New Jersey and to the Federal Government over a 
year ago. We have still not had any response from these agencies, I 
believe because there are so many gaps in the knowledge, particu- 
larly as it relates to the health effects of proposed emissions even 
applying to the best air pollution control technology. 
What are the health effects on human beings? What this leads 
up to is that we need time to address the large number of issues 
which I have at this time briefly to highlight. We recommend that 
the legislation which you are considering requires the USEPA, the 
States and the affected operating authorities to undertake coopera- 
tively the required work to arrive at the most satisfactory environ- 
mental solution for this very, very complex and severe problem. 
We recommend that the approach include a realistic timeframe. 
You must keep our feet to the fire as well as the agencies them- 
selves, the EPA and the States. And we believe that the program 
should include a carefully done scientific assessment of the envi- 
ronmental impacts of controlled ocean disposal of sludge. Now, this 
includes the question of how do you arrive at what is an acceptable 
impact so to speak on the marine environment? What are the crite- 
ria that you are looking to comply with? What are the impacts that 
one must be concerned with? What are the risks in the marine en- 
vironment that society should be willing to accept as part of the 
tradeoff picture? 
The same things I have said about the marine environment I say 
must be applied to the atmospheric ocean when one considers the 
incineration option. And this also leads me to say that a proposed 
program should include an identification of all of the unresolved 
issues relative to the land-based processes, especially the human 
health questions. And we should be required jointly to go a defined 
path to arrive at a decision on all of these issues once we have de- 
fined the issues again, in accordance with a prescribed timeframe. 
And one must in this context deal with air emissions as an exam- 
ple, on an area wide basis. The EPA must complete their business 
with reference to the industrial waste treatment program and the 
operating authorities must be required again to keep their feet to 
the fire to implement them. Then we must have the weighing of 
the negative and positive impacts of thermal destruction versus 
ocean disposal and then make a rational decision as to which is the 
most cost effective both from an environmental point of view and 
also a dollar point of view. 
We also indicate that managed ocean disposal of sludge, which 
should gradually become better in quality, providing we are suc- 
cessful in the sludge treatment program, should be continued until 
such time as the environmental tradeoff work has reached some 
firm condition and then those recommendations must be imple- 
mented. 
I would also recommend that there be no arbitrary decision to 
move the disposal site from the existing 12-mile site because again 
of the many unkowns in terms of what we may do to a new site, a 
scenario that I am not expert in, but I have read a lot of papers, 
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