322 



The PVSC, together with the other above-referenced New Jersey 

 sewerage authorities, treats the wastewater of a total of 122 New 

 Jersey municipaUties with a total population of approximately 3.2 

 million people or about 50 percent of New Jersey's population. 



The PVSC and the other New Jersey sewerage authorities are 

 committed to the treatment of wastewater in an environmentally 

 acceptable and responsible manner. In that regard, PVSC and the 

 other New Jersey authorities, under the 75 percent grants program 

 of the USEPA, have spent over $650 million in construction of sec- 

 ondary treatment facilities to comply with the mandate contained 

 in the Clean Water Act. The PVSC and the other New Jersey au- 

 thorities have seen their total annual operating expenses, which 

 are borne solely by the taxpayers in our respective districts, in- 

 crease from $24 million to over $100 million. 



Moreover, the commitment of the PVSC and the other New 

 Jersey authorities concerning disposal of sludge is equally clear. At 

 the direction of USEPA, the PVSC, and the other New Jersey au- 

 thorities, since at least as early as 1976, have conducted extensive 

 studies aimed at developing alternatives to the ocean dumping of 

 sludge. 



Subsequent to the completion of those studies, the PVSC and the 

 other New Jersey authorities developed various land-based alterna- 

 tives to ocean disposal such as incineration, composting, and codis- 

 posal. In some cases, the alternatives to ocean disposal have been 

 partially constructed. The study, development, and construction of 

 land-based alternatives to ocean dumping was carried out on each 

 occasion under the direction, supervision, and funding of the 

 USEPA. 



Nothwithstanding the cooperation and efforts of the PVSC and 

 the other New Jersey authorities, the implementation of land- 

 based alternatives to ocean dumping came to an abrupt and 

 screeching halt. Quite simply, after the land-based alternatives 

 were developed at the direction of EPA, the NJDEP could not 

 permit the implementation of the alternatives due to environmen- 

 tal considerations associated with the land-based alternatives. 



Thus, we believe that the PVSC and the other New Jersey au- 

 thorities have been placed in a catch-22 position as a result of the 

 lack of mutually consistent policies by the USEPA and NJDEP 

 concerning the disposal of sludge. As a result, while the authorities 

 are willing to comply with the directives of regulatory agencies, we 

 are unable to do so because of the lack of guidance and mutually 

 consistent policies of the regulatory agencies. 



You requested that I address the following subject matter: "What 

 actions have been pursued since our former chief engineer testified 

 before these subcommittees in March 1982 to identify and develop 

 long-term disposal options?" 



As we have previously stated, PVSC and the other authorities 

 have studied various land-based alternatives to ocean dumping of 

 sludge. These studies indicated that, for a densely populated and 

 industrial area such as ours, the only feasible alternative would be 

 some form of incineration of dewatered sludge. However, because of 

 the industrial nature of our district, NJDEP claims that our sludge 

 contains unacceptable amounts of heavy metals such as mercury, 

 cadmium, chromium and lead. 



