314 



Mr. EiCHLER. I don't think we have evidence beyond what we 

 have in other people's reports. We know from the EIS that EPA 

 said to open it up for 5 years to evaluate impacts. We are not con- 

 vinced anyone really knows what it will mean. We would be reluc- 

 tant to have that experiment conducted off our shores. 



Mr. D' Amours. I appreciate your answer. 



Mr. Arbesman, the Passaic Valley Sewerage Commission is going 

 to testify just after you finish with questions and answers here, 

 that they had developed land alternatives pursuant to EPA direc- 

 tion but that the New Jersey Department of Environmental Protec- 

 tion wouldn't permit implementation of that plan due to what they 

 found to be environmental considerations. 



Where were the State policies inconsistent with the national 

 policy? 



Mr. Arbesman. I don't think they were. I don't think there was a 

 national policy across the media. That is why we talk about a mul- 

 timedia assessment now. It is an excellent question. I will give you 

 examples. 



We have five sewer authorities proposing to build incinerators, 

 who received grants similar to New York City's, as Mayor Koch 

 testified. We were presented with five permit applications for 

 onland incinerators to burn sludge. We looked at the heavy metals 

 and they would have been the largest source of air pollution ever 

 permitted in New Jersey, surpassing our powerplants, over any- 

 thing else we have. 



The lead emissions alone from the proposals would have almost 

 equaled 200 tons per year of lead into the environment. That was 

 after appropriate air pollution control devices. This is the sludge 

 that is being put out in the ocean today. With pretreatment, the 

 numbers will probably get better and that is why we would like to 

 see the pretreatment program instituted but we still are going to 

 have problems with heavy metals and various organics that will 

 necessitate the permit review for any thermal reduction or inciner- 

 ation process. 



That is why we also would like EPA to set the national air stand- 

 ards so we have a target to shoot at for the onland alternatives 

 which is another piece of our strategy. 



Mr. D'Amours. I should have raised this with EPA and unfortu- 

 nately I didn't. Do I understand that EPA had approved Passaic 

 Valley procedures and that they did meet EPA policy standards? 



Mr. Arbesman. EPA approved the concept of Passaic Valley 

 going forward with the design of the incinerator. We didn't have 

 the specific numbers that would be emitted from the incinerator 

 until the designs were complete. What I am giving you are the end- 

 of-the-line design numbers as presented to us in the permit process. 



Mr. D'Amours. Weren't they presented to EPA in the EIS? 



Mr. Arbesman. No. 



Mr. D'Amours. They were not, OK. 



Mr. Arbesman. One of the failings of the EIS in my opinion was 

 that it looked at impacts on the ocean mostly and did little in 

 terms of the regard for impacts from land-based alternatives. That 

 was left up to the individual sewer authorities to struggle with. 



Mr. D'Amours. Thank you. 



Mr. Fors3rthe. 



