546 
"While three alternative methods of disposal are technically feasible, they are 
not available at reasonable incremental costs and energy soanheires....7 
In another chemical dumping application submitted by National Lead Industries, the EPA 
has tentatively appwed limited but continued acid-iron waste dumping. Energy Resources 
Company, Inc. submitted a "Demonstration of Compliance" document on behalf of 
National Lead Industries detailing the effects of acid dumping on marine life. 
In this report ERCO states: "these acid-iron wastes contain several constituents 
that are potentially lethal to aquatic organisms under conditions of acute as 
well as chronic exposure." 
In New Jersey where both of these dumpers are based, recent efforts by 
the State Department of Environmental Protection to encourage and regulate land- 
based disposal of industrial wastes have been hampered by the continuation of 
" 
a policy of "special consideration" for certain waste producers by the Environmental 
Protection Agency. This unique bias is in direct opposition to the policy of 
aggressively seeking land-based alternatives by the New Jersey Department of 
Environmental Protection. With an average yearly input of 1,545,000 tons of acid- 
iron wastes between 1973 and 1978 and a record of dumping since 1948, it is clear 
that the time has arrived for the cessation of acid-iron dumping. 
In March 1977, the Fishery Conservation and Management Act of 1976 became 
effective, extending U.S. jurisdiction over offshore fisheries within 200 miles 
of its coast and possessions, and making it the policy of the land to use some 
of the most sigencda ideas available about ways to manage marine fisheries. 
The management of our fisheries and the extraordinary efforts by those concerned 
with the. environment will have gone unrewarded if EPA is allowed to circumvent 
the law and allow sludge and chemical dumping to continue. At stake is not only 
a major supply of animal protein, but also an American industry which provides 
