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During incineration, according to NJDEP, some of these metals 

 would be vaporized and released to the air. Although PVSC would 

 use state-of-the-art air pollution control devices, NJDEP maintains 

 that low levels of metals would still be released. Because the 

 NJDEP feels that the long-term effects of these emissions are not 

 well understood, PVSC and the other authorities have not been 

 given permits to build the incinerators. 



USEPA is engaged in the promulgation of industrial wastewater 

 pretreatment standards. We understand that USEPA believes that 

 when pretreatment of industrial wastes have been implemented, 

 the heavy metals content of sludge may be low enough to permit 

 incineration. At this time, however, there is no assurance that, 

 even if the PVSC and the other authorities comply with whatever 

 pretreatment standards USEPA may promulgate, NJDEP will 

 permit the incineration of pretreated sludge. 



In any event, the PVSC and the other New Jersey authorities 

 have prepared their own pretreatment programs, in anticipation of 

 the promulgation of USEPA pretreatment standards. Again, this 

 has been done in a spirit of cooperation. PVSC's program is pres- 

 ently up for public hearings by the NJDEP and the PVSC expects 

 approval of same within the next 2 months. As soon as USEPA 

 proposes categorical pretreatment standards, we will immediately 

 go through our files and notify the industries in our district con- 

 cerning same so that they can be prepared to comment at the 

 public sessions and also get ready to implement the rules when 

 they are promulgated. 



In addition to our progress in the removal of heavy metals by 

 conventional treatment methods, we are also seeking innovative 

 methods to solve this problem. An example of this is our involve- 

 ment with the metal plating industry. These were the first rules 

 promulgated by EPA back in 1979, but as a result of court deci- 

 sions, et cetera, the deadline has been extended to 1984. 



In conjunction with NJDEP, the metal platers, and a professor at 

 Princeton University, the PVSC is exploring the use of a process to 

 economically recover the heavy metals used by the plating indus- 

 try, before the metals enter the wastewater stream. 



This program looks very encouraging at this time. If the concept 

 is successful with the plating industry, it could be applied to other 

 industrial users who will be required to pretreat for heavy metals, 

 such as leather tanners, inorganic chemical manufacturers, textile 

 dyers, et cetera. If a significant quantity of heavy metals are recy- 

 cled and reused, it would not only greatly reduce the amount of 

 metals introduced into our sludge, but also improve the competitive 

 position of the aging industries located in our district. 



Moreover, the PVSC is continuing to search for and develop envi- 

 ronmentally acceptable and responsible long-term solutions to 

 sludge disposal. We at the PVSC believe that solutions must take 

 into account and balance the relative environmental impact of 

 land-based versus ocean disposal methods. Indeed, we believe that 

 the only responsible approach to the sludge disposal problems is to 

 balance the risks of each alternative versus its anticipated environ- 

 mental benefit. 



We would like to commend Commissioner Hughey of the NJDEP 

 who, to put it simply, has "taken the bull by the horns" and pro- 



