-------
OCEAN DUMPING PROGRAM
Dredged Material Disposal
At present, over 90 percent of the total volume
of material dumped in the ocean consists of
sediment dredged from U.S. harbors and
channels. The U.S. Army Corps of Engineers
issues permits for disposal of dredged material
using human health and marine impact criteria
developed by EPA. Environmental aspects are
taken into account when sites are selected,
during the permitting process, and through
EPA's management and monitoring programs.
WHERE?
465 Million
Cubic Yards
Total I
:**-J
265 MCY
Inland
Open waters/Upland
135 MCY
Coastal, Upland
65 MCY Oceans
Ocean Dumping Sites
A large number of ocean dumping sites
existed in 1972 when the MPRSA was passed.
Based on their historical use, EPA designated a
few of these sites for disposal of nondredged
material (for sewage sludge, woodburning, fish
waste, and acid waste), and a larger number for
disposal of dredged material. Designations
were made on an interim basis until
environmental evaluations could be completed.
In 1977, a program was initiated for
permanently designating the sites pending
completion of environmental impact statements
or site designation studies.
The site designation process takes about 2.5 years
and is designed to minimize adverse environmental
effects and to ensure that dumping interferes as little
as possible with other activities in the marine environ-
ment. OMEP has now completed final designation for
60 sites (Figure 4).
Figure 3.
Of the approximately 465 million cubic yards of sediment dredged
in the United Slates each year, about 65 million cubic yards are
disposed in ocean waters.
11
-------
OCEAN DUMPING PROGRAM
Industrial Waste Disposal Site
Total Number of Sites jpffl 18
Draft EIS Completed E312
Final EIS Completed fai?12
Proposed Rule jgB| 12
Final Designation • 9
Dredged Material Disposal Site Status
Total Number of Sites
Draft EIS Completed _________
Final EIS Completed tmmmmxiFQrsa 64
Proposed Rule
inal Designation
Figure 4.
Completion status of industrial waste and dredged material
disposal site desigtiations.
In 1986, OMEP delegated responsibility to the seven
coastal EPA Regional Offices for the designation of
ocean dumping sites for dredged material. Regional
delegation will enhance local coordination and ex-
pedite decisions about site designation. To speed up
the process still more, in 1987 OMEP negotiated a
national umbrella Agreement with the Corps of En-
gineers. This Agreement makes 1991 the deadline for
final action on all existing ocean disposal sites and
establishes priorities for designating sites at the
regional level.
Ocean Monitoring
An underlying assumption of the ocean
dumping program is that the ocean
environment will be protected if those who
receive permits for dumping obey the
conditions written into the permit and the
requirements for managing the dumpsite.
Monitoring programs are conducted to
determine (1) whether dumpers are complying
with their permits, and (2) whether the waste
disposal is causing any unexpected adverse
effects.
The Ocean Dumping Ban Act of 1988 requires EPA,
in cooperation with NOAA, to design and conduct
programs for monitoring environmental conditions at
dump sites for sewage sludge and industrial waste.
OMEP operates an Ocean Survey Vessel, the
Peter W. Anderson (Figure 5), for ocean monitoring
and site designation field studies.
12
-------
OCEAN DUMPING PROGRAM
Enforcement
The U.S. Coast Guard has overall
responsibility under the MPRSA for
surveillance to prevent unlawful ocean
dumping and to ensure that authorized
dumping complies with permit conditions. The
Coast Guard uses several surveillance
methods including vessel and aircraft patrols,
shipriders on dumping vessels, in-port
boardings and inspections, and radar.
Permittees must notify authorities in advance
of dumping operations.
The Ocean Dumping Ban Act of 1988 requires each
dumper of sewage sludge or industrial waste to enter
into a compliance and enforcement agreement to
phase out ocean dumping by 1991 and to establish
an administrative and punitive fee structure.
Approximately 117 civil enforcement actions
have been brought under the MPRSA since
1973. The violations have ranged from failure to
meet permit reporting requirements to dumping
without a permit. One criminal enforcement
action filed in 1987 is awaiting trial.
Civil and criminal penalties will continue to be im-
posed for dumping without a permit. Beginning in
1992, civil penalties will be imposed on all ocean
dumpers of sewage sludge and industrial wastes,
whether or not they have received a permit. This fee
will increase yearly. Illegal dumpers are also subject
to criminal penalties.
Figure 5.
TlieOSV Peter W. Anderson is equipped to sample the
water column, sediments on the seafloor, and
emissions from incinerator vessels. She can collect
samples of dredged material, industrial waste, or
sewage sludge.
13
-------
PLASTICS PROGRAM
OMEP SUPPORTS THE OVERALL EPA OBJECTIVE TO ENSURE THAT
PLASTIC DEBRIS DOES NOT ENTER THE MARINE ENVIRONMENT.
The Marine Plastic Pollution Research and
Control Act of 1987 requires that the effects of
plastic pollution on the marine environment be
identified and reduced. Under this law, EPA is
studying ways to abate plastic pollution. OMEP
is responsible for the marine aspects of this
study, which includes several elements:
A listing of improper disposal practices
and specific plastic materials that may in-
jure fish and wildlife, degrade or cause
economic loss to coastal waterfront areas,
or cause other impacts
A description of EPA's authority and on-
going reduction measures to reduce
plastics in the marine environment
An evaluation of substitutes for some
plastic materials, recycling incentives, and
use ofdegradable materials.
In 1988, Congress passed another law dealing with
plastic pollution. Commonly called the Degradable
Plastic Ring Carrier Act, this legislation directs EPA
to require by regulation that plastic ring carriers be
made of naturally degradable material that, when dis-
carded, will decompose within a reasonable time.
The Marine Plastic Pollution Research and
ControlActimplementsAnnexVoftheProtocol
of 1978 Relating to the International Convention
for the Prevention of Pollution from Ships
(MARPOL). MARPOL prohibits discharge
into the sea of all plastics including, but not
limited to, synthetic ropes, synthetic fishing nets,
and plastic garbage bags. It also prohibits
discharge of food wastes and other floating
materials within specified distances from land.
In conducting these studies and analyses, OMEP
will work with other EPA programs, particularly those
dealing with waste minimization policies, and with
other Federal agencies that have related respon-
sibilities under the law. The Department of
Commerce is charged with conducting an analysis
on the effects of plastic materials on the marine
environment and recommending appropriate legisla-
tion. NOAA, the Department of Transportation (DOT)
and EPA are charged with running a three-year
program to educate the public about plastic pollu-
tion.
-------
POINT SOURCE CONTROL ACTIVITIES
IT IS OMEP'S OBJECTIVE TO ENSURE PROTECTION OF THE MARINE
ECOSYSTEM THROUGH STRINGENT CONTROLS ON POINT SOURCE
DISCHARGES.
The Clean Water Act
The Clean Water Act is the single most
important law dealing with the environmental
quality of all United States surface waters, both
marine and fresh. This Act sets a national goal
to restore and maintain the physical, chemical,
and biological integrity of the Nation's waters.
For many years, EPA and the States have
engaged in an array of activities under the
Clean Water Act, including development of
standards for municipal and industrial point
sources of pollution, grants for the
construction of sewage treatment facilities, and
compliance monitoring and enforcement.
A point source of pollution is one that can be
pinpointed specifically, for example, the
discharge coming from a sewage treatment
facility or a manufacturing plant.
A central feature of the Clean Water Act is the
National Pollutant Discharge Elimination System
(NPDES). This provision establishes a procedure by
which point sources discharging pollutants to
navigable waters receive permits authorizing the dis-
charge. Without permits issued either by EPA or
States delegated responsibility for the permit
program, dumping or other discharge of any non-
dredged materials is illegal within 3 miles of the coast
and inland, and point source discharges are illegal
beyond 3 miles.
OMEP is directly responsible, under two
provisions of the Clean Water Act, for protection
of the marine ecosystem.
Section 301 (h) of the Act allows qualified
publicly owned treatment works (POTWs)
thatdischarge into coastal or ocean waters
to provide less than secondary treatment if
certain conditions are_ met. Secondary
treatment removes 90 percent of all solid
waste from sewage effluent.
Section 403(c) requires that all NPDES-
permitted discharges from point sources
into the territorial seas, the contiguous
zone, and the oceans must not "un-
reasonably degrade the marine environ-
ment." This requirement can only be met
15
-------
POINT SOURCE CONTROL ACTIVITIES
after considering the effects of pollutant
disposal on human health and welfare,
marine life, and aesthetic, recreational,
and commercial values; the persistence
and permanence of these effects; and the
effects of varying disposal rates.
Section 404 of the Clean Water Act controls the dis-
charge of dredged materials. This provision is regu-
lated by the Army Corps of Engineers, using
evaluation criteria developed jointly with EPA.
These provisions are intended to coverall pollutants
of concern to the marine and estuarine environment.
OMEP policy requires that, at a minimum, decisions
about granting permits under the Clean Water Act be
made on the basis of water quality. This approach in-
cludes a site-specific assessment to ensure that
public water supplies and recreational activities are
protected and a balanced fish population is main-
tained. Section 403(c) goes still further, requiring a
more thorough assessment based on overall en-
vironmental effects such as ecosystem diversity and
productivity and considering effects on sediment as
well as in the water column.
18 Ponding
6 9 Withdrawn-..
,,40 Approved
73 Dtni.d
An Agency strategy for implementation of Section
403(c) of the Clean Water Act is under development.
The strategy will be discussed in a report to be sub-
mitted to Congress in May 1989 as required by the
Ocean Dumping Ban Act of 1988. The Act requires
that the report include a schedule for implementing
403(c), an estimate of the resources needed for im-
plementation, and recommendations, if any, for
statutory changes.
Discharger Status
Very few U.S. municipal dischargers to coastal
or ocean waters qualify for a 301 (h) permit. A
total of 208 dischargers applied for these
permits by the Clean Water Act's 1982
deadline. No new applications are allowed.
As of December 1988, EPA had made 190 final
decisions, approving 48 permits and denying 73, the
remaining applications having been withdrawn.
Denied permit applicants are required to meet secon-
dary treatment requirements (Figure 6).
The Water Quality Act of 1987 modified the 301 (h)
program by, among other changes, requiring a min-
imum of primary treatment and compliance with all
pretreatment requirements. A number of permittees
will probably not be able to achieve the new stand-
ards and will need to install additional treatment.
Figure 6.
Tlie current slants of 301 (h) Penult Applications
16
-------
NEAR COASTAL WATERS ACTIVITIES
IT IS OMEP'S OBJECTIVE TO PREVENT FURTHER DEGRADATION OF ESTUARIES
AND OTHER NEAR COASTAL WATERS, AND TO PROTECT AND RESTORE THE
ENVIRONMENTAL QUALITY OF THESE WATERS THROUGH THE DEVELOPMENT
AND IMPLEMENTATION OF A NATIONAL PLANNING AND DEMONSTRATION
PROGRAM.
In addition to managing programs to protect
the coastal and ocean environment from any
impacts of direct discharges, OMEP also
provides the primary focus within EPA for
comprehensive planning to restore and protect
coastal resources. It is this combination of
activities that will, over the long term, enable
EPA to meet its goals.
The Water Quality Act
In 1987, Congress amended the Clean Water Act
with the Water Quality Act. This new law offers op-
portunities for regulatory agencies, the regulated
community, and the public to expand ongoing
programs with new initiatives, including programs to
control toxic materials in surface water and pollution
from nonpoint sources, and to protect and restore
lakes and estuaries.
The Water Quality Act places a new emphasis on
going beyond national pollution control standards to
address site-specific problems and maximize en-
vironmental results. Three of its provisions focus at-
tention on protecting and restoring important coastal
resources: the National Estuary Program, the Great
Lakes Program, and the Chesapeake Bay Program.
OMEP is directly responsible for carrying out the Na-
tional Estuary Program, and for overseeing and sup-
porting the Chesapeake Bay and Great Lakes
Programs.
A nonpoint source of pollution is one that
cannot be precisely pinpointed; it is diffuse, like
runoff of nutrients from agricultural land or
deposition of contaminants from the air.
17
-------
NEAR COASTAL WATERS ACTIVITIES
A Resource Focus
E.PA programs are typically based on the
uniform application of controls nationwide. But
coastal problems and solutions tend to be
specific to a given site. The resource is a
complex ecological system with subtle
interdependencies among many species and
habitats. Agricultural runoff and other nonpoint
sources contribute pesticides and excess
phosphorus and nitrogen to bays hundreds of
miles away; the wind carries toxic materials to
contaminate bottom sediments in otherwise
pristine waters. Conventional, "end of pipe"
pollution controls are not typically enough.
As a result of these factors, OMEP has developed
programs and approaches that are in many ways uni-
que. Its programs zero in on a specific coastal area.
The OMEP approach is a fresh, creative way of solv-
ing environmental problems, one that recognizes an
integrated ecosystem, not clusters of isolated
problems. As problems are identified within an area,
all legal authorities and the regulatory and manage-
ment tools of other EPA, Federal, State, and local
agencies must be put to work for maximum results.
Furthermore, those results, and the success of the
program, are measured in terms of the environmen-
tal health and living resources of the ecosystem,
rather than by surrogate measures such as com-
pliance statistics.
Over its four-year life, OMEP has initiated or sup-
ported such programs in 18 coastal areas
(Figure 7). Although the approach could be con-
sidered an experiment, it is clearly an opportunity for
innovation. EPA's experiences in the Great Lakes
and Chesapeake Bay offer a successful environmen-
tal model to emulate and build on.
-------
NEAR COASTAL WATERS ACTIVITIES
Puget Sound, WA
Oregon Coast
Buzzards Bay, MA
Narragansett Bay, Rl
Long Island Sound, NY/CT
NY Bight
San Francisco Bay, CA
NY/NJ Harbor
Delaware Inland Bays
Delaware Bay
Chesapeake Bay
Albemarle-Pamllco Sounds, NC
Santa Monica Bay, CA
Sarasota Bay, FL
Galveston Bay, TX Perdido Bay, FL/AL
Gulf of Mexico
Figure 7.
1988: Waters covered under Agency initiatives
19
-------
NEAR COASTAL WATERS ACTIVITIES
The Great Lakes Program
The Great Lakes system is the largest
reservoir of fresh surface water in North
America and contains about 18 percent of the
world's supply. The Great Lakes are a fishery
resource, a transportation system, a water
supply, a recreation resource, a modifier of
climate, and a means of waste disposal. In both
Canada and the United States, all of these uses
have contributed to the development of one of
the world's largest inland concentrations of
population and industry.
One third of the 300,000-square-mile drainage basin
is covered by water. The numerous tributaries
receive drainage from many land uses and types of
soil, resulting in a variety of pollution problems.
Despite their size, the Lakes are especially sensitive
to pollution. Less than 1 percent of the total volume
of water in the system flows out the St. Lawrence
each year, thus toxic pollutants are left to accumu-
late in bottom sediments and fish. The relatively
closed nature of the system makes the Great Lakes
vulnerable to pollution over the long term and their
huge volume of water makes reversal of change due
to pollution very difficult.
Launched in 1970, the Great Lakes Program is the
oldest geographically focused environmental
program in the United States. A cooperative effort be-
tween the United States and Canada, the program
fulfills the Great Lakes Water Quality Agreement
between the two countries.
Tlie goal of the Great Lakes Water Quality
Agreement is "to restore and maintain the
physical, chemical, and biological integrity of
the Great Lakes Basin ecosystem." This
emphasis on a comprehensive ecosystem
approach is the cornerstone of both GLNPO
operations and OMEP's overall approach to
coastal environmental management.
20
-------
NEAR COASTAL WATERS ACTIVITIES
The Great Lakes National Program Office (GLNPO)
was created in 1978 to oversee the United States' ful-
fillment of its obligations under the Agreement with
Canada. GLNPO is located in Chicago and provides
national management for the Great Lakes program.
OMEP's role is one of support and oversight.
Concerns about water quality in the Great Lakes
have evolved over time from disease-causing
organisms to oxygen depletion and eutrophication
and, recently, to toxic substances as the leading
threat to human and ecosystem health.
The program initially tackled control of pollution from
individual, identifiable—or point—sources. Major
municipal treatment plants were required to reduce
phosphorus in effluents, and phosphate detergent
was banned in many of the Great Lakes States. These
efforts successfully reduced nutrients, resulting in
elevated oxygen levels and restoration offish in Lake
Erie and elsewhere.
The first Water Quality Agreement was signed by the
United States and Canada in 1972 and has been
amended three times. During negotiations for the
most recent amendments, in 1987, the principal con-
cern was the control of persistent toxic substances.
These substances have accumulated in sediments in
many urban and industrial centers, known as "Areas
of Concern," in both countries.
The Clean Water Act amendments of 1987 direct
GLNPO to coordinate actions within and external to
EPA that are aimed at improving water quality in the
Great Lakes to ensure U.S. compliance with the
Great Lakes Water Quality Agreement. The Act fur-
ther requires GLNPO to manage Great Lakes surveil-
lance, research, and demonstration projects.
The program then turned to nonpoint sources of pol-
lution. The principal nonpoint source of excess
nutrients was the runoff of surface water from agricul-
tural land. This water carries topsoil laden with
nutrients (including fertilizers) to the Lakes. GLNPO,
working with the Department of Agriculture's Soil
Conservation Service, funded projects with
individual farmers to illustrate how voluntary best
management practices could reduce phosphorus
loadings from agricultural sources. Today the States
have their own phosphorus control programs as part
of the implementation agreement with Canada.
21
-------
NEAR COASTAL WATERS ACTIVITIES
A new five-year strategy for GLNPO has the
following goals:
Support the completion of Lakewide
Management Plans for Lakes Michigan,
Ontario, and Erie to determine the steps
needed to make fish safe to eat.
Support the completion and implementa-
tion of Remedial Action Plans to restore
beneficial uses in all Areas of Concern.
Obtain enough information about sour-
ces, fates, and effects of pollutants to sup-
port a mass balance approach in remedial
programs.
Conduct a demonstration program to as-
sess and address contaminated bottom
sediments.
Evaluate results of point source and non-
point source remedial programs to deter-
mine whether additional controls are
needed to restore oxygen levels in Lake
Erie.
Strengthen partnerships with the Great
Lakes States, other EPA programs, and
other Federal agencies in carrying out all
responsibilities.
Protect the Lakes from human abuse by
improving public understanding of the
Great Lakes system and related issues.
-------
NEAR COASTAL WATERS ACTIVITIES
The Chesapeake Bay Program
ATLANTIC OCEAN
CHESAPEAKE BAY
The Chesapeake Bay is the largest estuary in
the United States; biologically, it is one of the
most productive systems in the world. It is part
of an interconnected system that includes a
portion of the Atlantic Ocean and rivers
draining parts of New York, Pennsylvania, West
Virginia, Maryland, Delaware, and Virginia. The
Bay proper is approximately 200 miles long and
ranges in width from about 4 miles to 30 miles.
The water surface of the Bay proper covers
more than 2,500 square miles. However, the
Bay is relatively shallow, averaging 28 feet in
depth, making it very sensitive to temperature
and wind. The water and related land
resources of Chesapeake Bay serve over 12
million people.
The Chesapeake Bay program is managed by EPA's
Region in Philadelphia (Region III), and day-to-day
operations are handled by the Chesapeake Bay
Liaison Office in Annapolis, Maryland. OMEP's role
is one of support and oversight.
The Chesapeake Bay Program began in 1977 as a
Federal-State partnership. In 1983 the Governors of
Maryland, Virginia, and Pennsylvania, the mayor of
the District of Columbia, the Chesapeake Bay Com-
mission, and EPA signed the Chesapeake Bay
Agreement. This agreement committed the States
and the District of Columbia to prepare plans to im-
prove and protect the Bay's water quality and living
resources. The following actions were imple-
mented:
Institution of land-use controls at or near'
the bay shoreline
Development of nonpoint source control
programs for agricultural and urban sour-
ces
Acceleration of tighter controls on point
sources, particularly municipal treatment
plants
Strengthening of wetlands protection
laws and programs
23
-------
NEAR COASTAL WATERS ACTIVITIES
When the Chesapeake Bay Program began, many
studies had documented the negative effects of pol-
lution. However, scientific data were lacking for two
serious problems that were disturbing leaders and
citizens throughout the Bay region. The Bay's gras-
ses were disappearing in many areas and landings
of certain fish species were declining.
Three critical areas were chosen for intensive
investigation—nutrient enrichment, toxic sub-
stances, and the decline of submerged aquatic
vegetation (SAV). Results of these investigations
have greatly increased the understanding of sources
of pollutants, their transport and fate within the es-
tuary, and their impacts on a major ecosystem com-
ponent, SAV.
These research findings contributed to the second
phase of the program, the characterization effort,
which concentrated on determining trends in the
Bay's water quality and the health of its resources.
The goal of characterization was to provide an infor-
mation base for evaluating human impacts on the
ecosystem and a framework for guiding manage-
ment options. The product of this phase is
Chesapeake Bay: A Profile of Environmental
Change. This report presents the current state of the
bay and trends in its water quality and resources. It
also suggests possible causes of some of the chan-
ges observed and thereby provides a useful manage-
ment tool.
The technical studies and Bay-wide characterization
laid a foundation for determining appropriate
management strategies. The major product from the
third phase is Chesapeake Bay: A Framework for
Action. This report presents a framework for the
actions that users must take to restore and maintain
the ecological integrity of Chesapeake Bay. Addition-
al products of the phase include predictive models
and a comprehensive data management system.
This phase also encouraged a regional management
approach to guide the future of the Bay.
In 1987, the parties signed a new Agreement for con-
tinued cooperative efforts to restore and protect
Chesapeake Bay. It contains goals and priority com-
mitments for living resources; water quality; popula-
tion growth and development; public information,
education and participation; public access; and
governance. A most important provision is a commit-
ment among the Bay States to reduce the levels of
nutrients in the Bay by 40 percent by the year 2000.
Strategies to control toxic materials, manage
fisheries, and minimize the impact of development
on the Bay's drainage basin are being developed.
The Chesapeake Bay Program was also formally
mandated by the 1987 Amendments to the Clean
Water Act.
24
-------
NEAR COASTAL WATERS ACTIVITIES
The National Estuary Program
The lessons learned and the precedents set by
the Great Lakes and Chesapeake Bay
programs helped lay the foundation for the
National Estuary Program. In 1985, the
Congress directed EPA to conduct programs in
four estuaries: Narragansett Bay in Rhode
Island, Buzzards Bay in Massachusetts, Long
Island Sound in New York and Connecticut,
and Puget Sound in Washington. In 1986, EPA
added San Francisco Bay in California and
Albemarle/Pamlico Sounds in North Carolina.
The National Estuary Program was formally estab-
lished by the 1987 amendments to the Clean Water
Act. The program's goals are protection and im-
provement of water quality, and enhancement of
living resources. The types of environmental
problems the national program addresses are com-
plex. They include loss of habitat and living resour-
ces, contamination of sediments by toxic materials,
elevation of nutrient levels, contamination by bac-
teria, and depletion of oxygen. These problems can
affect human health through contact with the water
and by ingestion of contaminated shellfish and fin-
fish. More frequently, pollution problems limit the
estuary's desirable uses, like recreational and com-
mercial finishing and shellfishing, and may even
close beaches to swimming. Environmental
problems may not affect other important uses, such
as shipping, municipal and industrial water use, and
waste disposal. Nevertheless the program assumes
that these conflicting use demands can be met
through collaborative planning.
PUGET SOUND
BUZZARDS BAY
NARRAGANSETT BAY
LONG ISLAND SOUND
SAN FRANCISCO BAY/
SAN JOAQUIN DELTA
ALBEMARLE/PAMLICO
SOUNDS
25
-------
NEAR COASTAL WATERS ACTIVITIES
The Clean Water Act amendments authorize EPA to
convene Management Conferences to develop
Comprehensive Conservation and Management
Plans (CCMP) for estuaries of national significance
that are threatened by pollution, development or
overuse.
Management Conferences may be convened for up
to five years. The Act identifies seven major pur-
poses of a Management Conference:
1. Assess trends in water quality, natural
resources and uses of the estuary.
2. Collect, characterize, and assess data
on toxic materials, nutrients, and natural
resources within the estuary to identify
the causes of environmental problems.
5. Develop plans for the coordinated
implementation of the CCMP by the
States as well as Federal and local
agencies participating in the conference.
6. Monitor the effectiveness of the actions
taken.
7. Review all Federal financial assistance
programs and Federal development
projects for consistency with the plan.
The Act identifies required members of a Manage-
ment Conference to ensure representation by a
broad range of interests. Membership must include
representatives of Federal, State, regional and local
agencies, affected industries, academia, and the
public.
3. Develop the relationship between the
Inplace loads and point and nonpoint
loadings of pollutants to the estuary and
the potential uses of the estuary.
4. Develop a CCMP that recommends
priority corrective actions and
compliance schedules addressing point
and nonpoint sources of pollution to
restore and maintain the chemical,
physical, and biological integrity of the
estuary, and assures that the designated
uses of the estuary are protected.
26
-------
NEAR COASTAL WATERS ACTIVITIES
Each estuary program must establish its own objec-
tives and operating methods, which depend on the
character and problems of that estuary. The interests
and values of its public are also a paramount con-
cern. Although each program is unique, each goes
through the following four phases:
1. The planning initiative during which the
management framework is built
Figure 8 shows the kinds of conflicts and probable
causes faced by the 12 estuaries now in the national
program. Although each estuary is unique, their
programs share some common themes. Two es-
tuaries, one on the East Coast and one on the West,
will be discussed as examples of how the National
Estuary Program works. All of the six original
programs will complete a CCMP during the early
1990s.
"^
.'J
2. Characterization and problem
definition, which examines changes in
water quality and natural resources,
evaluates point and nonpoint pollutant
loadings, and determines their
relationship to pollution problems
3. Creation of a Comprehensive
Conservation and Management Plan
4. Implementation of the plan.
FigureS.
Typical conflicts and probable
causes faced by 12 estuaries in the
national program.
\PROBLEMS-*
Albemarle-Pamlico Sounds
Buzzards Bay
Delaware Bay
Delaware Inland Bays
Galveston Bay
Long Island Sound
Narragansett Bay
NY/NJ Harbor
Pugct Sound
Sarasota Bay
San Francisco Bay
Santa Monica Bay
( TOXIC ^ Ce\ iTRnPWirATin^ ( CHANGES IN ^
CONTAMINATION 1 I EUTROPHICATION) 1 M(Jft Rpftn| |R 1
N — • — / PATHOGEN V— — >/" HABITAT LOSS V- / ( ^\
^CONTAMINATION J ^AND ALTERATION^ [ OTHER J
DPX ®
^xl
or ©
crx ®
crx ®
®=x
o^x @
d=X ®
d=X ©
o=x @
CTX
Gr=x ©
crx ©
crx ®
crx @
crx
crx @
crx ©
crx ©
^x®
®=x
crx ©
cr
crx ©
crx ®
orx
crx @
.crx
s=X
crx -9
crxs
crx <®
X •
x •
crx @
@
«
crx ®
crx ®
crx ©
cr ®
crx ©
crx ©
crx •
crx ®
cr @
crx @
crx •
cr'x
cr x ©
crx ©
crx ®
®
GIT POINT SOURCES X NONPOINT SOURCES <§) OTHER
27
-------
NEAR COASTAL WATERS ACTIVITIES
Puget Sound
PUGET SOUND
PACIFIC OCEAN
Over the past three decades, environmental
programs designed to protect this area have control-
led many conventional pollutants and maintained
Puget Sound in relatively good health. However, con-
tinuing development of the region has imposed
growing demands on the estuary. This growth is
accompanied by increasing evidence of serious
water and sediment quality problems, biological
stresses, and limitations on beneficial water uses.
During the 1980s, significant concentrations of toxic
contaminants have been found in the sediments of a
number of the Sound's urban and industrial embay-
ments. These include highly toxic and very persist-
ent chemicals. Field surveys have identified
abnormalities in bottom-dwelling communities, in-
creased incidence of disease in fish caught in parts
of the Sound where sediments contained high con-
centrations of chemicals, and elevated levels of
polychlorinated biphenyls (PCBs) in the edible tissue
of fish and shellfish.
Puget Sound supports a rich and diverse
commercial and sport fishery for fish and
shellfish. Its 2,200 square miles of bays and
inlets and over 2,000 miles of shoreline
embrace industrial and commercial activity,
shipping, and international commerce. Puget
Sound is a major recreational attraction that
contributes significantly to growing tourism in
the area.
PCBs, or polychlorinated biphenyls, are highly
toxic organic chemicals. Tliese compounds were
manufactured and marketed in the United
States until 1977. Tlie same quality that made
them suitable for a variety of industrial
applications—(heir stability—also makes them
a lingering problem in the environment. PCBs
accumulate in sediments, where they persist for
longperiods, and from there can be taken up by
tlie tissues of marine organisms.
28
-------
NEAR COASTAL WATERS ACTIVITIES
Further, nonpoint source pollution from rural septic
systems and farm practices appears to be a major
source of bacteria. In developing urban areas,
stormwater is contributing additional bacterial and
toxic contamination. As a result of these combined
high levels of bacteria and toxicants, many produc-
tive shellfish areas are being closed.
The Puget Sound Estuary Program (PSEP), started
in 1985, has been jointly managed by EPA's Seattle
Region (Region X), the Puget Sound Water Quality
Authority, and the Washington State Department of
Ecology. PSEP has successfully completed major
steps toward identifying problems, characterizing
the estuary, and planning for and developing action
programs.
A highlight of the Puget Sound work has been the
Urban Bay Toxics Action Program. Concentrating
limited resources first in the areas needing them
most, the Program designed and is implementing
toxics action programs for the urban industrial bays.
Based on existing information, these programs call
for early action to prevent further chemical con-
tamination and environmental degradation. Special
action teams of enforcement and compliance inves-
tigators are assigned to each bay by the Washington
Department of Ecology. These teams investigate
high priority areas to identify and control sources of
contamination.
The Puget Sound Estuary Program has also
produced the Puget Sound Environmental Atlas, a
series of 500 maps with up-to-date information on
pollution sources, resource distribution within the es-
tuary, and current environmental conditions; and the
Protocols Manual, developed with the Army Corps of
Engineers, which recommends techniques for the
sampling and analysis of variables in the Sound.
Since the program began, PSEP has produced about
50 other technical reports and manuals. J
The 1989 Puget Sound Water Quality Management
Plan outlines action plans to protect and enhance
three resources: the Sound's water and sediment
quality; its fish and shellfish; and its wetlands. The
final plan, or CCMP, is scheduled for release in 1991.
29
-------
NEAR COASTAL WATERS ACTIVITIES
Long Island Sound
LONG ISLAND SOUND
The Long Island Sound is a 110-mile-long
estuary with 1,300 square miles of water and
577 miles of coastline. To many, the Sound is a
favorite spot for sportfishing, sailing, and
swimming. To others, it is a vital transportation
route or the home of commercial fisheries.
Approximately 200,000 boats are registered and
operate on Long Island Sound; the commercial
catch of lobsters, finfish and shellfish exceeds
$20 million annually.
Bordered on one end by New York City, the Sound
is surrounded by 14.6 million people. As a result of
the population, 86 sewage treatment plants dis-
charge processed effluent and wastes into waters
entering Long Island Sound, as do many industries.
Nonpoint source runoff from land surrounding the
Sound also contributes to pollution, not all from
local sources. Eighty percent of the fresh water
entering Long Island Sound comes from rivers that
drain States as far north as Massachusetts, New
Hampshire, and Vermont.
This program is unique among the original six es-
tuary programs in that two EPA regions, Region I in
Boston and Region II in New York, and two States,
New York and Connecticut, share leadership respon-
sibility for the management coalition.
In 1985, based on substantial input and review by
diverse interests, the program selected two priority
problems for major study: low dissolved oxygen, or
hypoxia, and the distribution and impacts of toxic
substances. The program is also addressing the
need to protect living marine resources.
Although a variety of causes can deplete oxygen
in water, scientists believe mat eulrophication,
discussed in the introductory sections of this
report, contributes to the problem in Longlsland
Sound. Nutrients that produce eulrophication
are added to the Sound by input from sewage
treatment plants, slonnwater runoff, and die
atmosphere.
30
-------
NEAR COASTAL WATERS ACTIVITIES
The Long Island Sound Study is working to
determine
The scope of the Sound's problems with
toxic contamination and low dissolved
oxygen
The year-to-year trends of toxic pollution
and nutrient input
The specific effects of these toxic con-
taminants on the living resources of the
sound, including fish and shellfish des-
tined for human consumption.
BUZZARDS BAY
NARRAGANSETT BAY
Other Original Estuary Programs
Buzzards Bay
The Buzzards Bay Program began in 1985 as a joint
project of EPA's Boston region and the Mas-
sachusetts Executive Office of Environmental Affairs.
This program is focusing on three priority problems
in the Bay: (1) closure of shellfish beds, (2) con-
tamination of fish and shellfish by toxic metals and
organic compounds, and (3) high nutrient inputs and
their potential pollutant effects.
Narragansett Bay
The Narragansett Bay Project, jointly managed by
EPA's Boston office and the Rhode Island Depart-
ment of Environmental Management, is tackling
seven priority problems: (1) management of
fisheries, (2) nutrients, (3) impacts of toxic con-
taminants, (4) health and abundance of living marine
resources, (5) health risk to consumers of con-
taminated seafood, (6) land use, and (7) recreation-
al uses.
31
-------
NEAR COASTAL WATERS ACTIVITIES
Albemarle/Pamlico Sounds
EPA's Atlanta Region (Region IV) with the coopera-
tion of EPA Region III and the North Carolina Depart-
ment of Natural Resources and Community
Development manage the program in Al-
bemarle/Pamlico Sounds. Current work centers on
10 conflicting uses of the estuary system. Six of these
uses directly or indirectly affect the ecology of the
system: (1) waste disposal, (2) agriculture, (3)
forestry, (4) residential and commercial develop-
ment, (5) mining, and (6) national defense. The four
other uses are primarily affected by the health of the
estuary system: (7) commercial fishing, (8) wildlife,
(9) natural resources, and (10) tourism and recrea-
tion.
San Francisco Bay/San Joaquin
Delta
The San Francisco Estuary Project is managed by
EPA's San Francisco Region (Region IX) at the
Association of Bay Area Governments in Oakland.
Using a survey to identify technical and management
issues, the estuary program reached consensus on
five basic priority problems that affect the beneficial
uses, public health, and living resources of the area:
(1) decline of biological resources, (2) increased
point and nonpoint source pollution, (3) reduced
freshwater inflow and salinity, (4) increased water-
way modification, and (5) intensified land use.
ALBEMARLE/PAMLICO
SOUNDS
SAN FRANCISCO BAY/
SAN JOAQUIN DELTA
32
-------
NEAR COASTAL WATERS ACTIVITIES
1988 Additions to the National
Estuary Program
The 1987 amendments to the Clean Water Act
and 1988 Appropriations Act directed EPA to
give priority to including an additional six
estuaries in the national program. These
estuaries (New York-New Jersey Harbor, New
York and New Jersey; Delaware Bay, Delaware
and New Jersey; Delaware Inland Bays,
Delaware; Sarasota Bay, Florida; Galveston
Bay, Texas; and Santa Monica Bay, California)
were added to the program in 1988.
The Governor's nomination package for each
estuary describes the major environmental
problems, probable causes of the problems, and
preliminary program issues. Specific goals for these
new programs will be refined by the Management
Conference in each area.
SANTA MONICA BAY
NEW YORK/
NEW JERSEY HARBOR
DELAWARE INLAND BAYS
DELAWARE BAY
GALVESTON BAY
SARASOTA BAY
33
-------
NEAR COASTAL WATERS ACTIVITIES
New York - New Jersey Harbor
The New York State Department of Environmental
Conservation and the New Jersey Department of En-
vironmental Protection proposed broad goals and
objectives to maintain and enhance the water quality
of New York-New Jersey Harbor. The nomination ac-
knowledged the need to go beyond secondary treat-
ment and deal with combined sewer overflows to
ensure that a healthy diverse marine community is
maintained, minimize human health risks associated
with consumption of shellfish and finfish, maximize
opportunities for water contact recreation, and en-
sure that citizens of New York and New Jersey real-
ize to the fullest extent possible the social and
economic benefits associated with the New York-
New Jersey Harbor.
The broad problems to be addressed by the
Management Conference are pathogen contamina-
tion, toxic contamination, changes in living resour-
ces, habitat loss and modification, eutrophication,
and floatable debris.
Delaware Bay
The Delaware Department of Natural Resources and
Environmental Control, the Pennsylvania Depart-
ment of Environmental Regulation, and the New
Jersey Department of Environmental Protection
proposed goals for the program. These include
providing for the restoration of the living resources
of the Delaware Estuary, reducing and controlling
point and nonpoint sources of pollution, protecting
public water supplies, managing the economic
growth of the Delaware Estuary, and promoting
greater public understanding about the Delaware
Estuary and participation in decisions and programs
affecting the estuary.
Delaware Inland Bays
Problems affecting the Inland Bays include in-
creased population growth and land development
due to the relatively low cost of land and building
construction, and the accessibility of the beaches to
a large population, as well as nonpoint pollution
problems due to the extensive agricultural interests,
specifically poultry farming. With poor flushing
capabilities and low freshwater input, the geologic
and geographic characteristics of the Inland Bays
contribute to their vulnerability.
Goals set by the State of Delaware's Department of
Natural Resources and Environmental Control
include strategies to develop more complete infor-
mation about the Inland Bays, to build better
cooperation and coordination between different
-------
NEAR COASTAL WATERS ACTIVITIES
Federal, State, and local agencies, to increase public
participation and education, and to build com-
prehensive strategies for regional planning, for was-
tewater and drinking water management, and for
managing fertilizer, herbicide, and sediment con-
trols.
Sarasota Bay
Sarasota Bay is a small, subtropical, relatively pris-
tine bay located in one of the nation's fastest grow-
ing areas and thus is increasingly threatened by
residential and commercial development and over-
use. It has been designated by the State of Florida
as an Outstanding Recreational Water, provides
critical habitat for endangered species such as
manatees and loggerhead sea turtles, and generates
millions of dollars annually through recreational uses
.and tourism.
The State of Florida has established six goals linked
to the environmental problems and causes that it has
identified. These goals are to improve water
transparency in the Sarasota Bay Study Area; reduce
the quantity and improve the quality of stormwater
runoff to Sarasota Bay; prevent further losses of
seagrasses and shoreline habitats and restore lost
habitats; coordinate beach/inlet/channel creation
and maintenance activities to reduce dredging,
eliminate conflict, and enhance the Bay; provide in-
creased levels of managed access to Sarasota Bay
and its resources; and establish a vertically in-
tegrated management system for Sarasota Bay.
Galveston Bay
Many development and water resource enhance-
ment projects are currently in progress or proposed
in the Galveston Bay area. Issues associated with
these projects are potential water quality changes in
the Bay and its tributaries, which transport nutrients
and both treated and untreated wastewater dischar-
ges to the Bay; potential reductions in freshwater
inflow in the Bay system and its associated wetlands,
and potential changes in Bay salinity; possible
increased turbidity, resuspension of toxic or hazard-
ous chemicals, and potential changes in Bay circula-
tion and salinity profiles; possible loss of contiguous
wetlands due to subsidence, erosion, decreased
sediment transport or shoreline development; oil and
gas exploration/ production, including seismic
activities in the Bay environment; and ecosystem
interconnection between the riverine systems, the
Bay system and the Gulf of Mexico.
35
-------
NEAR COASTAL WATERS ACTIVITIES
Goals set by the Texas Water Commission include
the maintenance of water quality and the enhance-
ment of estuary productivity in the shallow bays, the
prevention of water quality deterioration in the Hous-
ton Ship Channel, the examination of current
wastewater treatment programs and dredge spoil
disposal methods, the development and analysis of
baseline toxics data, and the prevention of man-
induced wetlands losses and the control of shoreline
erosion in the four-county area.
Santa Monica Bay
Santa Monica Bay is one of the most heavily utilized
areas in California. Approximately 8 million people
live near the Bay and use it for bathing, boating,
sport fishing, and other forms of recreation. Many
marine species may be impacted by current prac-
tices, including at least five Federally-listed
endangered species. Some of the problems facing
the Bay include the following: two of the largest
treated sewage discharges in the nation are within
the study area; sediments around the Los Angeles
County outfall contain high levels of DDT, other
organic compounds, and trace metals; there have
been several sewage spills to Ballona Creek, a
tributary of the Bay, usually during storms and
power outages; substantial pathogen contamination
has temporarily closed many beaches in the Bay.
The Management Conference will refine the broad
environmental goals proposed by the State, focusing
on problems related to storm drain discharges, sedi-
ment quality, fish tissue body burdens, pathogen
contamination, and others.
36
-------
NEAR COASTAL WATERS ACTIVITIES
t.-.-.v.-.-.wl-X-.-.-.-.'ja
Estuaries Identified by the
Ocean Dumping Ban Act of 1988
In 1988, the Ocean Dumping Ban Act identified
four new areas to receive EPA's priority
consideration for inclusion in the National
Estuary Program. These four areas are
Massachusetts Bay; Barataria-Terrebone Bay,
Louisiana; Indian River Lagoon, Florida; and
Peconic Bay, New York.
Other Near Coastal Waters
Initiatives
OMEP completed a strategic plan for Near
Coastal Waters at the EPA Administrator's
request in 1987. This long-term plan is the
logical extension of experiences and success
achieved through the Great Lakes, Chesapeake
Bay, and National Estuary Programs. It
provides a framework for management
attention to complete coastal ecosystems and
to the thousands of square miles of near
coastal waters that have problems similar to
those found in the current estuary programs.
The goal for the plan is to maintain and, where
possible, enhance near coastal water
environmental quality. A wide range of coastal
experts, including Federal, State and local
managers, EPA regional and headquarters
staff, scientists, environmental groups, and
citizens participated in the development of the
plan.
OMEP's approach for implementing the plan is to
identify coastal areas requiring additional manage-
ment attention, encourage Federal and State
managers to use their existing regulatory tools and
resources to solve problems more efficiently, and
help Federal, State and local officials implement new
management tactics that will achieve measurable
environmental improvements in these coastal areas.
37
-------
NEAR COASTAL WATERS ACTIVITIES
Four priority projects are under way:
1.A national assessment of the
environmental status and trends of all
near coastal waters fo identify those in
need of management attention, using
existing data from Federal, State, local
agencies and academia. With this
assessment, OMEP will assist the EPA
Regions and States in developing specific
regional coastal strategies that focus or
increase management activities at the
regional and State level.
2. The selection of pilot projects fo
demonstrate innovative management
actions, which can then be applied to
environmental problems in other coastal
waters. Projects are currently underway in
Delaware, Perdido Bay, and Oregon.
3. A technology transfer initiative to
continue to develop management
expertise in coastal regions and a national
network of environmental managers in
coastal States, counties, and local
governments through which OMEP can
informally transfer and receive key
information on coastal problems and
strategies. This technology transfer
initiative will encompass all of OMEP's
Near Coastal Waters programs.
4. The examination and expansion of
existing coastal regulatory authorities
through OMEP's coordination with other
EPA offices and EPA Regions.
The Gulf of Mexico Initiative
The Gulf of Mexico initiative is an example of the
near coastal waters approach in practice. It was
launched by the EPA Regional Administrators in
Atlanta and Dallas in 1987 and is jointly managed by
the two EPA regions, with a program office located
at the John C. Stennis Space Center near Bay St.
Louis, Mississippi. The purpose of this initiative is to
develop and implement a comprehensive strategy
that will balance the needs and demands of man-
related activities with the preservation and enhance-
ment of living marine resources in the Gulf. Initial
emphasis of the program will be on six areas that
have been widely accepted as issues of major con-
cern: extensive loss of valuable habitats such as
wetlands and submerged aquatic vegetation,
nutrient over-enrichment, toxics and pesticide
contamination, shellfish bed closures, human altera-
tion of freshwater flow to Gulf estuaries, and public
health.
The environmental problems of the Gulf of Mexico
result from many different, and sometimes conflict-
ing, State and regional activities. Thus EPA's Gulf of
Mexico program must work to improve communica-
tion among all Federal agencies, States, public and
private organizations, and citizens.
38
-------
NEAR-COASTAL WATERS ACTIVITIES
The New York Bight
NEW YORK BIGHT
THE GULF OF MEXICO
The New York Bight Restoration Plan is required by
the Marine Plastic Pollution Research and Control
Act of 1987. This plan is being developed by EPA's
New York region, in cooperation with NOAA and
other Federal and State agencies. The objective of
the plan, which follows the National Estuary Program
model, is to restore the Bight to its prior uses. Due
in FY 1991, the plan will identify and assess the
impact of pollutants to water quality and marine
resources, identify technologies and practices to
control pollutant inputs, identify costs of control
measures and impediments to implementation, and
develop recommendations for funding and for coor-
dinating these projects.
wontinuing Activities
OMEP is developing an index of susceptibility for the
remaining 90 estuaries not designated by the Water
Quality Act. This assessment will identify high-risk,
medium-risk, or low-risk estuaries for three classes
of pollution: (1) point source nutrient loadings, (2)
nonpoint source nutrient and pesticide loadings, and
(3) point source toxicant loadings. An assessment of
the cumulative impact of all three classes of pollution
will also be produced. These assessments will be
used to determine future directions for the national
demonstration program and support regional, State
and local initiatives for estuarine management.
OMEP will also support the development of near
coastal waters strategies in each of EPA's seven
coastal regions.
39
-------
THE COASTAL PARTNERSHIP
U.S. ENVIRONMENTAL PROTECTION AGENCY
DEPARTMENT OF COMMERCE
U.S. NATIONAL OCEANIC AND ATMOSPHERIC
ADMINISTRATION
DEPARTMENT OF DEFENSE
U.S. ARMY CORPS OF ENGINEERS
DEPARTMENT OF AGRICULTURE
AGRICULTURAL STABILIZATION AND
CONSERVATION SERVICE
The governments and people of this Nation
share responsibility for protecting our coastal
and marine waters. OMEP's success in meeting
its objectives and in supporting EPA's coastal
goals will depend on the many regulatory and
management programs of other EPA offices
and other Federal, State, and local
governments, as well as on public participation
in these programs.
DEPARTMENT OF THE INTERIOR
U.S. MINERALS MANAGEMENT SERVICE
DEPARTMENT OF THE
VS. BSD AND WWXJFE SERtflCE
US.COMSTGUATO
OEPARrueHTOFAOftCW.TWE
SCS.CCKSSWATICH SBWX.
40
-------
THE COASTAL PARTNERSHIP
Within EPA's Office of Water, tools for improv-
ing water quality include construction grants,
criteria and standards, NPDES permits, com-
pliance and enforcement actions, water quality
management grants, controls for combined
sewer overflows, groundwater protection
programs, nonpoint source control programs,
water quality monitoring, and wetlands protec-
tion programs.
Other EPA offices are also responsible for control ac-
tivities not based on water quality. These include
Clean Water Act dredge and fill permits, Environmen-
tal Impact Statements for other Federal agencies, Su-
perfund and Resource Conservation and Recovery
Act activities, atmospheric loadings, pesticides and
toxics substances controls, research and develop-
ment activities, and international activities. OMEP
works with these offices to ensure that their regula-
tions and national policies consider the special con-
cerns of the coastal and ocean environment.
A number of other Federal agencies also have
statutory responsibilities related to the coastal and
ocean environment. These agencies administer at
least 21 programs affecting the coastal and ocean
environment. Additionally, the coastal States and
local governments are directly concerned with
water, agriculture, fisheries, land use, and resource
protection programs.
No area of environmental cooperation has received
more sustained attention by the international com-
munity than the prevention and control of marine
pollution. Within EPA, OMEP has a lead role in sup-
porting the London Dumping Convention and MAR-
POL OMEP must assure that U.S. positions are
consistent with U.S. law and policies and coordinate
with other EPA offices and Federal agencies to
assure that international requirements are met on a
government-wide basis.
41
-------
FOR MORE INFORMATION
For general information or questions about national programs or policy, contact
Ms. Darla Letourneau at the following address:
EPA Office of Marine and Estuarine Protection
401 M Street, SW
Washington, DC 20460
202-475-8580
For area-specific questions, contact the closest EPA regional representative:
EPA Region I, Boston, Massachusetts
Mr. Ron Manfredonia
Water Management Division
John F. Kennedy Building
Boston, MA02203
617-835-3531
EPA Region II, New York, New York
Mr. Mario DelVioaro
Water Management Division
26 Federal Plaza
New York, NY 10278
212-264-5170
EPA Region III, Philadelphia, Pennsylvania
Mr. Randy Pomponio
Environmental Management Branch
841 Chestnut Street
Philadelphia, PA 19107
215-597-2541
Chesapeake Bay Program, Annapolis, Maryland
Mr. Charles Spooner
Chesapeake Bay Program
410 Severn Avenue
Annapolis, MD 21403
301-922-2285
EPA Region IV, Atlanta, Georgia
Mr. Robert McGhee
Water Management Division
345 Courtland Street
Atlanta, GA 30365
404-347-212S
Great Lakes National Program Office,
EPA Region V, Chicago, Illinois
Ms. Carol Rnch
GLNPO
230 South Dearborn Street
Chicago, IL 60604
312-353-2117
EPA Region VI, Dallas, Texas
Mr. Bruce Elliott
Water Management Division
1201 Elm Street
Dallas, TX 75270
214-655-7144
EPA Region IX, San Francisco, California
Ms. Loretta Barsamian
Water Management Division
215 Fremont Street
San Francisco, CA 94105
415-974-8283
EPA Region X, Seattle, Washington
Mr. Ron Kreizenbeck
Water Management Division
1200 Sixth Avenue
Seattle, WA 98101
206-442-1265
»uj<»Tzssvi3msjsT:JMwnct iw>».
42
-------
-------
-------
-------
First-Class Mail
Postage and Fees Paid
EPA
Permit No. G-35
United States
Environmental Protection
Agency
Office of Marine and
Estuarine Protection
(WH-556F)
Official Business
Penalty for Private Use $300
-------