311 



d) Within one year of reauthorization of the MPRSA, the 

 promulgation of interim sewage sludge quality standards. 

 The standards could be developed through a regional rule- 

 making process in which EPA would invite technical participation 

 by New Jersey and New York, The interim sludge quality 

 standards should speed-up implementation of industrial pre- 

 treatment programs consistent with Section 307 of the Clean 

 Water Act. By giving the sewer authorities a target to shoot 

 at, the standards may also vary for ocean disposal versus on- 

 land disposal. The interim standards should be tied to a 



four year compliance schedule designed to improve the quality 

 of the sludges to the point of expanding treatment and disposal 

 options, 



e) Continued direction by Congress for EPA to develop and promulgate 

 national categorical pretreatment standards for industries to 

 implement, 



f) Direction by Congress that EPA develop and promulgate national 

 ambient air quality standards for heavy metals and toxic organics. 

 These standards are necessary to evaluate the land based option 

 of thermal reduction. 



Our strategy is predicated on two premises. First, we need a compre- 

 hensive basis for decision-making which can only be brought forth in a multi- 

 media assessment that evaluates both the land based alternatives and the several 

 ocean disposal sites. Second, by improving the quality of the sludges, the 

 disposal options should be expanded and the decision-making process made easier. 



This six point program is a product of the DEP's Committee on Ocean 

 Waste Management. The Committee has representation from seven diverse elements 

 of the Department with members bringing technical expertise in disciplines 

 ranging from the marine sciences to air pollution and industrial pretreatment. 

 The initial set of recommendations was developed over three months ago. Rather 

 than releasing it as the State's portion, we have sought to meet informally with 

 the affected parties in an effort to seek a consensus. The six current ocean 

 dumpers in our State, the City of New York, lawmakers, and selected environmental 

 and business groups each have had an opportunity to listen and react to our 

 proposals. We are convinced, now more than ever, that the State's set of 

 recommendations represent a solid middle ground, one in which rational decision- 

 making can take place over a sensible timeframe. 



In addition to our formal comments, the Subcommittees have asked three 

 specific questions of the State of New Jersey. Our responses are as follow: 



1) Is it realistic to adopt the stated goal of environmental 



restoration of the New York Bight? Representatives Hughes and 

 Forsythe have proposed a New York Bight Restoration Plan to be 

 developed by the EPA within a three year period following 

 reauthorization of the MPRSA. We agree that such a plan would 

 be worthwhile provided that the planning process determines 

 achievable goals and sets forth specific proposals for imple- 

 mentation. Intuitively, it is difficult to postulate restora- 

 tion as an achievable goal given the degree of urbanization in 

 the New York Metropolitian areas. The contaminant loadings of 



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