326 



Mr. Carella. I am unaware of the facts that would answer that. 

 However, if I may suggest and respectfully request, I can provide 

 an answer to that in writing to the committee if you so permit. 



[The information follows:] 



Questions of Mr. Forsythe and Answers by Passaic Valley Sewerage 



Commissioners 



Question 1. On page 2 and 3 of your testimony, you indicate that land-based alter- 

 natives (incineration, composting and co-disposal) were unacceptable to the New 

 Jersey Department of Environmental Protection due to the environmental consider- 

 ations. Later in your testimony, you explain precisely why incineration was unac- 

 ceptable. Could you elaborate on why composting and co-disposal were considered 

 infeasible? Would these objections be removed if you pretreated industrial wastes 

 entering Northern New Jersey sewage treatment systems? 



Answer. During the preparation of PVSC's "Facilities plan for land-based sludge 

 alternatives," dozens of various alternatives to ocean dumping of sludge were ex- 

 plored, some of which were composting and co-disposal of sludge. * 



Composting provides for stabilization and volume reduction of sludge. In the case 

 of PVSC, however, we employ a wet air oxidation system that produces a product 

 similar to compost. We therefore looked into the possibility of using our sludge in 

 the same manner as compost. 



Various methods of disposal of our compost-like sludge in land application uses 

 were looked into. Compost or sludge can either be used for agricultural or non-agri- 

 cultural use. If PVSC were to dispose of our treated sludge by application to agricul- 

 tural land, we would require approximately 120,700 acres without pre-treatment, or 

 57,000 acres with pre-treatment. This area, even with pre-treatment, amounts to 

 over 50% of the land area of the county in with pre-treatment, amounts to over 

 50% of the land area of the county in which the plant is located. Non-agricultural 

 land application would use a total of 27,000 acres without pre-treatment and 11,000 

 acres with pre-treatment. 



The amount of land needed for any type of land application is greater than that 

 available anywhere in the State of New Jersey. We have gone so far as to seek per- 

 mission of the States of New York and Pennsylvania for possible land application in 

 those states. That permission was denied. We therefore had to abandon the land ap- 

 plication alternative due to the lack of any possible application site. 



At the time our facilities plan was prepared (December, 1978), a number of co- 

 disposal options were investigated. The Port Authority of New York and New 

 Jersey, the Hackensack Meadowlands Development Commission, Public Service 

 Electric & Gas Co., and the Essex County Improvement Authority were contacted in 

 an effort to explore the co-disposal of PVSC's sludge with the solid waste produced 

 in PVSC's area. Although the disposal of solid waste is a critical problem for this 

 area, firm plans were not and still are not in place for the design and construction 

 of solid waste facilities. The time constraints imposed upon PVSC at the time of the 

 preparation of our facilities plan did not give us the luxury of waiting for these 

 other agencies to move forward on their solid waste disposal facilities. Therefore, 

 this option was ruled out at the time of the preparation of our facilities plan. 



We recently contacted the agencies that were responsible for the disposal of solid 

 waste in the PVSC area and have discovered that their plans are still in the formu- 

 lation stage. We cannot rely upon these agencies to dispose of our sludge when they 

 still do not know how they will dispose of their primary responsibility of solid waste 

 disposal. However, we face the same problem of emissions standards with co-disposal 

 as we do with on-site sludge incineration. If the emission question were to be an- 

 swered, both alternatives could be considered viable. 



Question 2. On page 3 of your testimony, you indicate that the New Jersey De^ 

 partment of Environmental Protection found your sludge to contain "unacceptable" 

 levels of heavy metals such as mercury, cadmium, chromium, and lead. Has the 

 New Jersey Department of Environmental Protection defined "acceptable" levels of 

 these metals? If so, could you achieve these levels under a pretreatment program? 



Answer. In order to construct a sludge incinerator, PVSC prepared applications to 

 construct sludge incinerators and applied to the NJDEP and USEPA for a review of 

 these applications on June 26, 1981. The NJDEP and USEPA have studied the issue 

 of heavy metal concentrations of sludge and their affects on air quality after incin- 

 eration. The DEP continues to study this extremely complex subject and as of this 

 date, has not yet decided whether the levels present in PVSC sludge are of such a 

 level that they can permit the construction of a sludge incinerator. The submittal 



