172 



metal content of sewage sludge is very misleading. The sewage 

 sludge heavy metal composition with its enriched organic compo- 

 nent is vastly more readily available to organisms than the heavy 

 metals in dredged material. 



Mr. FoRSYTHE. Have you had an opportunity to review New Jer- 

 sey's six-point program? How does the Federation feel about it? 



Mr. Kamlet. I have not. I understand it was not officially re- 

 leased until 12 o'clock today. From what I understand of it, it does 

 not differ in a tremendous degree from the Hughes-Forsythe pro- 

 posal. There are details that I would like to study. I would be glad 

 to respond for the record with our reactions to that proposal. 



There are elements of it including more aggressive resort to in- 

 dustrial pretreatment that make a great deal of sense and other as- 

 pects that coincide closely with elements of the Hughes-Forsythe 

 proposal that we have already indicated we support. I would be 

 happy to respond for the record. 



[The information follows:] 



NWF's Analysis of New Jersey's Six-Point Program 



New Jersey DEP has proposed a six-point program which it believes "may form a 

 basis for decision-making on disposal of sewage sludge into the New York Bight 

 Apex." The six points are: 



(1) Congressional designation of the 12-Mile Site for continuing use for up to 5 

 years. 



(2) A Congressional mandate that EPA prepare within three years a "comprehen- 

 sive multi-media assessment" of the various land-based and ocean-based alternatives 

 "to determine the most environmentally acceptable disposal method and the techno- 

 logical, economic, and legal requirements necessary to produce acceptability," with 

 implementation of the most acceptable disposal method or methods to begin within 

 five years (of enactment). 



(3) Establishment of "user fees for ocean disposal at the 12-Mile Site," with 85-90 

 percent of the fees to be "levied but not collected by the federal government," but 

 "placed in special trust accounts established by each of the sewerage agencies and 

 dedicated for the financing of long term sludge disposal methods." ("A fee tied to a 

 portion of the estimated short term cost differential from dumping at the 12 Mile 

 Site versus the 106 Mile Site may be an equitable starting point"). 



(4) Promulgation, within one year of reauthorization of the MPRSA of "interim 

 sewage sludge quality standards" which "may . . . vary for ocean disposal versus 

 on-land disposal." These standards "should speed-up implementation of industrial 

 pretreatment programs [under the Clean Water Act] ... by giving the sewer au- 

 thorities a target to shoot at." The standards "should be tied to a four year compli- 

 ance schedule designed to improve the quality of the sludges to the point of expand- 

 ing treatment and disposal options." 



(5) Continued direction by Congress for EPA to develop and promulgate categori- 

 cal industrial pretreatment standards. 



(6) Direction by Congress that EPA develop and promulgate national ambient air 

 quality standards for heavy metals and toxic organics — "necessary to evaluate the 

 land based option of thermal reduction." 



New Jersey DEP also proposes "phasing in the restoration analysis" [i.e., develop- 

 ment of a plan for rehabilitating the Bight Apex] until after a decision is made on 

 sludge disposal (i.e., putting it off for 5 years or more). However, DEP expresses the 

 belief that "with additional discussions, a consensus position could be attained" be- 

 tween the Hughes-Forsythe proposal and DEP's. 

 The National Wildlife Federation's reactions to each of these points are as follows: 

 (1) Continued 5-Year Designation of the 12-Mile Site: We prefer the Hughes-For- 

 sjd;he approach of phsising-out use of the 12-Mile Site within 3 years in conjunction 

 with an overall plan for rehabilitation of the Bight Apex. The New Jersey proposal 

 does not really address the benefits of restoring the Bight Apex to an undegraded 

 condition and the inability to accomplish meaningful restoration of the Apex as long 

 as sludge dumping continues at the 12-Mile Site. The New Jersey proposal, more- 

 over, would perpetuate an unacceptable status quo for at least 5 years (before cor- 

 rective action is even initiated), while the Hughes-Forsythe approach takes firm (al- 



