523 
Several years ago, when the Federal Law required us to cease ocean disposal of 
sludge by December 31, 1981, we did not have the benefit of the many engineering 
studies that have been undertaken in response to that law. Passaic Valley Sewerage 
Commissioners has been in the forefront of things in carrying out the necessary 
studies. This work has enabled us to highlight the pros and cons of the viable land 
based alternatives. We have established that thermal destruction is in fact the only 
viable solution on land for our area, but that it is not without its environmental 
problems. The same conclusions have been reached by the other New Jersey agen- 
cies. The studies have also enabled us to highlight the issues for which more work is 
required to enable rational judgements to be made. The unresolved questions and 
issues include the following: 
1. The State and Federal regulatory agencies do not, as yet, know what emission 
standards are to be applied to these sludge incinerators. Of particular concern are 
the health effects on humans for various levels of emissions. 
2. The State and Federal regulatory agencies do not as yet know what materials 
they should be concerned with and in what concentrations in the atmosphere. 
3. The State and Federal regulatory agencies do not know, on a region-wide basis, 
those emissions which they consider to be acceptable for such things as sludge incin- 
erators, resource recovery facilities and coal burning power plants. These are all 
competing public needs and require an area-wide analysis including an evaluation 
of the public benefits to be derived from each of the various emissions sources and 
their environmental impacts. Judgements must be made as to which provide the 
greatest public benefit while at the same time protecting the environment. The Fed- 
eral and State agencies must coordinate their work so that we can make rational 
decisions to meet these vital social needs. There obviously must be a tradeoff and it 
is up to the Federal and State agencies to see that a full evaluation is made. 
4. The future quality of our sludges will depend upon the implementation of the 
industrial waste pretreatment program. Judgements have been made as to the prob- 
able reduction of heavy metals through the application of the pretreatment pro- 
gram; however, the effectiveness of the pretreatment program can only be predicted 
on the basis of our best judgements today. The effectiveness of the program can only 
be judged after the USEPA has promulgated the required standards and industries 
are given sufficient time to implement the necessary pretreatment programs. The 
ultimate disposal of these concentrated industrial wastes and sludges from these 
pretreatment facilities is another important part of the total problem and must be 
dealt with on the Statewide basis. 
5. PVSC, as part of its Sludge Management Planning, retained an air pollution 
control consulting firm for an evaluation of the proposed sludge incinerator alterna- 
tive. A recommendation was made which included the application of the best availa- 
ble control technologies and which would result in the lowest achievable emissions 
rate. The State has similarly contracted with another consulting firm to provide 
emissions information. The basic work of our consultant was completed over a year 
ago and we are still waiting for a response from the State and Federal governments 
on our proposal. I am sure that the unresolved questions regarding the health ef- 
fects of the proposed emissions is contributing greatly to the indecisiveness of the 
State and Federal governments. 
Time is needed to address a large number of issues, including those which I have 
enumerated above with reference to incineration and relative to managed ocean dis- 
posal. We recommend that the legislation which you are considering require the 
USEPA, the States and the affected sewerage authorities to undertake the required 
work to arrive at the most satisfactory environmental solution for this severe prob- 
lem. The approach, including a realistic time-frame, should include the following: 
1. A carefully developed scientific assessment of the environmental impacts of 
controlled ocean disposal of sludge. 
2. An identification of all unresolved issues relative to the land based processes, 
especially the human health question, and a defined path to render decisions on 
each of these matters. This would include the areawide Interstate Air Pollution 
Control considerations. , 
3. The USEPA must complete the requirements for the industrial waste pretreat- 
ment program and operating authorities must then move forward expeditiously 
with the development and implementation of their industrial waste pretreatment 
programs. 
4. Preparation of an Environmental Impact Statement which would undertake the 
necessary weighing of environmental and fiscal costs for each of the options, includ- 
ing ocean disposal of sludge and the rendering of a judgement as to which is the 
most cost effective and environmentally sound solution. 
