BRIEFING
  DOCUMENT
     Prepared by the
.S. ENVIRONMENTAL PROTECTION AGENCY
      REGION II
        for
  THE PRESIDENT'S
  WATER POLLUTION CONTROL
  ADVISORY BOARD
NEW YORK CITY
SEPTEMBER 26-29,1972
                                UJ
                                CD
                                T

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       OCEAN   DUMPING
        A Briefing Document for

            THE PRESIDENT'S
        WATER POLLUTION CONTROL
            ADVISORY BOARD
               Prepared by

         Lawson E.  Whitesides,  Jr.
Environmental  Protection Agency, Region II
          With the Assistance of

Regions I, II, III, IV, VI, IX, and X, E.P.A.
The Office of International Affairs, E.P.A.
The Office of Legislative Affairs, E.P.A.
James Verber, Food and Drug Administration,  H.E.W.
New York District Office, Corps of Engineers
Policy Planning Division, E.P.A.

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                             CONTENTS
                                                               PAGE





SECTION 1 - INTRODUCTION                                         1



SECTION 2 - CURRENT OCEAN DISPOSAL PRACTICES                     3



SECTION 3 - EFFECTS OF OCEAN DISPOSAL                           15



SECTION 4 - ALTERNATIVES TO OCEAN DUMPING                       19



SECTION 5 - CURRENT NATIONAL POLICY                             23



SECTION 6.- FEDERAL OCEAN DUMPING LEGISLATION                   31



SECTION 7 - STATE LEGISLATION AND CONTROL ACTIVITIES            35



SECTION 8 - INTERNATIONAL ACTIVITY                              39



REFERENCES                                                      43

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                    SECTION 1 - INTRODUCTION
     This Briefing Document has been written for the use of the
President's Water Pollution Control Advisory Board in connection
with its meeting in New York City from September 26-29, 1972.
     The topic of Ocean Disposal of Waste was covered authorita-
tively by the Council on Environmental Quality in its 1970 Report
to the President entitled Ocean Dumping:  A National Policy (1).  Much
has happened in this field in the intervening two years and, as
a result, some of the specific information in that report is
now out of date.
     This Briefing Document has been assembled in an attempt to
bring information in the Council's Report up to date.  Although
it has been written to be understandable by itself, it will be
most meaningful if read in connection with the Council's Report.
     Every attempt has been made to include salient information
which the Advisory Board needs.  This document should not,
however, be considered an exhaustive treatment of the subject.

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Particularly in the areas of research on the effects of ocean
dumping and alternatives to ocean dumping, it is impossible to
give complete coverage in a brief report.  Presentations by
experts during the first and second days with attendant
questioning by the Board should plug gaps in the written
information available.
     In the seven sections which follow, the material is
organized in the following way:  Current Practices are reviewed
in Section 2 and followed by the Environmental Effects of these
practices in Section 3 and Alternatives to these practices in
Section 4.  The Present National Policy is outlined in Section 5,
the status of new Federal Ocean Dumping Legislation is discussed
in Section 6, and State Legislation and Activity is reviewed in
Section 7.  Section 8 describes current International Activity
to regulate and control ocean disposal of waste.

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           SECTION 2 - CURRENT OCEAN DISPOSAL PRACTICES
     In its 1970 Report to the President, the Council on Environ-
mental Quality reviewed ocean dumping practices for six materials
(1, p. iv).
     Dredge Spoil - The solid material removed from the bottom
     of water bodies generally for the purpose of improving
     navigation:  sand, silt, clay, rock, and pollutants that
     have been deposited from municipal and industrial discharges.
     Sewage Sludge - The solid material remaining after municipal
     waste water treatment:  residual human wastes and other
     organic and inorganic wastes.
     Solid Waste - More commonly called refuse, garbage, or trash.
     The material generated by residences; commercial, agricultural,
     and other establishments; hospitals and other institutions
     and municipal operations.  Chiefly paper, food wastes,
     garden wastes, steel and glass containers, and other miscel-
     laneous materials.

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     Industrial  Wastes - Acids;  refinery,  pesticide,  and  paper
     mill  waste; and assorted liquid  wastes.
     Construction and Demolition Debris  -  Masonry,  tile,  stone,
     plastic, wiring, piping, shingles,  glass,  cinderblock,  tar,
     tarpaper, plaster, vegetation,  and  excavation  dirt.
     Radioactive Wastes - The liquid  and solid  wastes that result
     from processing of irradiated fuel  elements, nuclear reactor
     operations, medical use of radioactive isotopes, and research
     activities and from equipment and containment  vessels which
     become radioactive by induction.
This section will present more recent data on quantities  of
materials disposed of, disposal  sites, and disposal costs.
     Estimates of the quantities of dumped material were  presented
by the Council in its Report to the President.   These estimates
were based on data supplied by the Dillingham Corporation for
1968 (2) and were later found to be incomplete (3).  Verber's
revisions of these estimates were used in the later Dillingham
report (4) and are used as the 1968 figures here.   Both the 1968
and the 1970 data presented here, like data used in the Council's
Report to the President, do not include waste piped into the ocean
but only that waste delivered by vessel.
Dredge Spoil
     On a tonnage basis, dredge spoil is the largest waste category
being disposed of in the sea.  Because of the large number of
dredge projects carried out all around the country at any one time,

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it is extremely difficult to compile a comprehensive inventory
of quantities disposed of.  Estimates made by the Dillingham
Corporation (2) and used by the Council on Environmental Quality
in its 1970 Report to the President indicated that 38.4 million
tons of dredge spoil were dumped in the ocean in 1968 (1, p. 3).
However, Verber's careful review of the Dillingham data yielded the
following quite different estimates, which have been used in
a later Dillingham report (4).
          Table A:  Amount of Dredge Spoil Disposed of
                    in the Ocean during 1968
                                        Annual Tonnage
          Atlantic Coast                  30,880,000
          Gulf Coast                      13,000,000
          Pacific Coast                    8.320.000
               Total                      52,200,000
No estimates for later years have been as carefully or comprehen-
sively assembled.  However, some data are available for later
periods and can be compared.
     On a national basis, a significant portion of the polluted
dredge spoil is disposed of at the New York Harbor dumping sites.
During the five-year period from 1964 to 1968 (inclusive) an
average of 7.5 million cubic yards of dredged material was dis-
posed of in the Harbor (7).  In the year June 1969 - June 1970
this figure was 6.6 million cubic yards (8) and in the calendar
year 1971 the figure was 9.3 million cubic yards (5).   Of this

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latter 9.3 million cubic yards, however, 3.2 million is accounted
for by two unusually large projects.
Industrial Waste
     Industrial waste is a category which includes a wide variety
of materials.  Table B shows the percentage (by weight) breakdown
of the industrial waste dumped into the ocean in 1968.
          Table B:  Types of Industrial Haste Disposed of
                    in the Ocean in 1968 (4. p. 22]
               Waste Acid                       58%
               Refinery Wastes                  12%
               Pesticide Wastes                  7%
               Paper Mill Wastes                 3%
               Other                            20%
By far the largest single contributor (on a weight basis) was
waste acid.
     Table C presents total amounts of dumped industrial  waste
for 1968.

          Table C:  Amount of Industrial Waste Disposed of
                    in the Ocean during 1968 (4, p. 21)
                                            Annual Tonnage
          Atlantic Coast                      3,013,000
          Gulf Coast                            696,000
          Pacific Coast                         981.000
               Total                          4,690,000
While it was not possible to compile complete data for later
periods, a comparison of certain key source areas is possible.
The New York City area is the single most important source of
this industrial waste, accounting for over 55% of the tonnage in

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1968 (4, pp. 21 and 22).  Between 1968 and 1970 the amount from
this area grew from 2.7 million tons (4, p. 22) to 3.4 million tons (5),
Of this total, in each case approximately 90% was waste acid.
Ocean dumped industrial waste from the Philadelphia area increased
from 290,000 tons in 1968 (4, p. 22) to 733,000 tons in 1971  (5).
Almost all of this material is waste acid.
Sewage Sludge
     The ocean dumping of sewage sludge from barges is carried
out at two Atlantic Coast sites only:  in Lower New York Harbor
and near the southern tip of New Jersey.  As Table D indicates,
the quantity of material being disposed of at these sites has
increased significantly in the last three years, reflecting an
increase in the amount of raw sewage being treated as well as
the higher degree of treatment now occurring in some upgraded
plants.
          Table D:  Amount of Sewage Sludge Disposed of in the
                    Ocean
                                             Annual  Tonnage
                                         1968~[T)      T97T (5)
          Atlantic Coast                4,477,000      5,721,000
          Gulf Coast                            0              0
          Pacific Coast                	0     	0
               Total                    4,477,000      5,721,000
At the New Jersey Clean Water Council hearing on June 29, 1971,
Morris Klegerman explained how much more sewage sludge is produced
when a plant is upgraded by using the following example:

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8
          "A non-industrial community with primary sewage treatment
          now typically produces 4 1/2 to 5 tons of sludge daily on
          a dry solids basis for a population of 100,000 people.  On
          a wet basis, that is, the quantity actually barged to sea
          (after concentration), it is between 45 to 50 tons per day
          per 100,000 of population.  After secondary treatment,
          however, the corresponding figures will become about 9 tons
          per day on a dry solids basis and about 200 tons per day
          on a wet basis (i.e. in the condition barged to sea).
          So that even with zero population growth and zero industrial
          growth, the communities comprising the metropolitan New
          Jersey area, by reason of the increased degree of sewage
          treatment, will double their production of sludge on a dry
          solids basis and quadruple the volume on a wet basis."

     Construction and Demolition Debris

          The ocean disposal of construction and demolition debris is

     carried out almost exclusively at a site 15 miles south of New

     York City.  The quantity of this material dumped at sea depends

     on how much construction and demolition occur in New York during

     the year and how much of this typically "clean" inert material

     is used for fill in projects around New York Harbor.  As Table E

     shows, the quantity of debris was significantly less in 1971

     than three years earlier.


               Table E:  Amount of Construction and Demolition Debris
                         Disposed of in the Ocean

                                                 Annual Tonnage
                                             1968~[4FT97T (5)

               Atlantic Coast                574,000       348,000
               Gulf Coast                          0             0
               Pacific Coast                	0      	0

                    Total                    574,000       348,000

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Solid Waste
     The known ocean disposal sites for solid waste (refuse,
garbage, etc.) are on the Pacific Coast.  Only three sites were
known to be operating in 1968, and by 1971 only two were still
active (one 20 miles offshore of the City of Montara, California
and the other 20 miles off Newport Beach, California).  Table F
shows that there was perhaps a slight reduction in the known
quantity of solid waste disposed of in the sea between 1968
and 1971.

          Table F:  Amount of Solid Haste Disposed of in
                    the Ocean
                                          Annual  Tonnage
                                      196814")Till  (5)
          Atlantic Coast                    0              0
          Gulf Coast                        0              0
          Pacific Coast                26,000         21,000
               Total                   26,000         21,000
Radioactive Haste
     For all  practical purposes, the ocean disposal of radio-
active wastes from the United States was almost nonexistent in
1968 and 1971 (4, p. 23; 6).
Cost of Disposal
     A table of 1968 disposal costs and cost ranges is presented
in the final  Dillingham report (4) and is reprinted here as
Table G.

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10
    Disposal Sites
         The final Dillingham report (4) also contains the latest
    comprehensive mapping of disposal sites available (1968).  This
    set of maps is reprinted here as Figures 1,2, and 3.

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                     Table G
AVERAGE AND REPORTED RANGE OF COSTS PER TON FOR MARINE
        DISPOSAL OF WASTES IN U.S. COASTAL WATERS
                        1968
Type of Waste
Dredging spoils
Industrial wastes
Bulk
Containerized
Refuse and
Garbage
Sewage sludge
Construction and
demolition debris
Explosives
Miscellaneous
Total U.S.
Average
cost/ton
$0 . 40/ton
$l.70/ton
$24/ton
$15/ton
$1 . OO/ton
$0.75/ton'
$l5/ton
$l5/ton
Reported
Range $/ton
$.20 - .55
$0.60*9. 5O
$5-130
$5 - $6O
$.80-1.20
$.70- 1.35
$15 - $90
$5 -. $6OO
Pacific Coast
Average
cost/ton
$0.43/ton
$1 . OO/ton
$53/ton
$l5/ton



$l5/ton
Reported
Range $/ton
None
$O.6O-9.5O
$5O - $130
$5-$60



$5 - $600
Atlantic Coast
Average
cost/ton
$0 . 54/ton
$l.80/ton
$7 . 73/ton

$1. OO/ton
$0.75/ton


Reported
Range $/ton
$.40 - .55
$.60-7.00
$5 - $17

$.80-1.20
$.7O -1.35


Gulf Coast
Average
cost/ton
$0 . 25/ton
$2.30/ton
$28/ton





Reported
Range $/ton
$0.20 -.25
$.75-3.50
$10 - $40






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12
                            Pacific  Coast Disposal Areas
                                                and
                                   Artificial  Reefs
                                N
                                \
                   Ore.
                 LEGEND
 D  Dredging Spoils
 E  Explosives and Toxic Chemical Ammunition
© Explosives and Toxic Chemical. Ammunition, Inactive Site
 G  Refuse
 I  Industrial Waste
 R  Radioactive Waste
R3 Marker includes more than one site
   Artificial Reef
   Marker includes more than one reef
                                See inset mop
                                          I
                              0. "^	»L03 Angelas
         Nautical Miles
     Figure 1. The Pacific Coast was the only U.S. coast where authorized refuse disposal sites were found.

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                                                                                13
 Atlantic Coast Disposal Areas
                       and
          Artificial  Reefs
        LEGEND
 0  Dredging Spoils
©  Dredging Spoils, Inactive Site
 E  Explosives and Toxic Chemical Ammunition
©  Explosives and Toxic Chemical Ammunition,
      Inactive Site
 I  Industrial Waste
 R  Radioactive Waste
 S  Sewage Sludge
D2  Marker includes more than one site
#  Artificial Reef
H&  Marker includes more than one reef
of"'
             Nautical Miles
     Figure 2. Sewage sludge disposal sites were only found on the Atlantic Coast, where most radioactive waste
  disposal sites were also located.

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O £
»
U
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3 O.
If
It
M
il
B 5'
o 5'
e ^
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>•* n
So
- e
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i-> X
   '
  5
  *"
  I
  a
  o
  g.
  I
  I
      6W/ 0/ Mexico Disposal A reas
                          and
               Artificial Reefs
Texas
               LEGEND
 0  Dredging Spoils
© Dredging Spoils, Inactive Site
 E  Explosives and Toxic Chemical Ammunition
© Explosives and Toxic Chemical Ammunition, Inactive Site
 I  Industrial Waste
 R  Radioactive Waste
04 Marker includes more than one site
   Artificial Reef
ifj Marker includes more than one reef
                          GULF   of  MEXICO
                                                     Nautical Miles

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                                                                      15
               SECTION 3 - EFFECTS OF OCEAN DISPOSAL
     In its 1970 Report to the President, the Council on
Environmental Quality reviewed the known effects of ocean pollu-
tion, caused in some cases by ocean dumping (1, Chap. II).   In
this section the material presented by the Council  will  be
reviewed very briefly, and then the results of a few of the more
important recent studies will be presented.
Summary of the Council's Report on Ocean Pollution
     1.  Biological concentration of pollutants may occur in the
marine food chain.  For example, phytoplankton, at the bottom
of this chain, concentrate certain heavy metals, which are
concentrated further within the food chain.
     2.  Effects of ocean pollution on marine life result from
toxicity, oxygen depletion, biostimulation and habitat change.
          A.  Toxicity - Toxic wastes include such materials as
          pesticide waste, oil and refinery wastes, heavy metals,
          and paper mill wastes.  Sublethal effects, of toxic
          wastes on marine life include reduced vitality and
          growth, reproductive failure, and interference with
          sensory functions.

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16
             B.  Oxygen Depletion -
                      "Oxygen supports marine and aquatic life and
                      is necessary to the biological degradation
                      of organic materials.  Organic wastes [including
                      sewage sludge] dumped or discharged into water
                      bodies demand oxygen to decompose.  If waste
                      loads are too heavy, the oxygen levels become
                      depleted and the diversity of marine organisms
                      is altered . . . When all of the oxygen is
                      depleted, organisms die and anaerobic bacteria
                      produce hydrogen sulfide and methane gas which
                      are malodorous" (1, p. 14).

             C.  Biostimulation -

                      "Some wastes, such as sewage sludge, are
                      particularly rich in nutrients, such as
                      phosphates and nitrates.  These nutrients can
                      cause biostimulation--the accelerated fertili-
                      zation of plant life.  When the plants die,
                      oxygen necessary to support marine life is
                      used in their decomposition.  And when dead
                      algae are carried to beaches, they rot and
                      produce unpleasant odors.  By creating excessive
                      blooms of algae, biostimulation indirectly
                      changes the nature of bottom sediments and thus
                      whole communities of bottom organisms" (1, pp. 14
                      and 15).  (It should be noted that nutrient poor
                      areas of the ocean exist, which might benefit
                      from detoxified sewage sludge.)

             D.  Habitat Changes - Changes in the kinds and quantities
             of sediments may change whole ecological systems.

        3.  The effects of ocean pollution on humans include public

   health, recreation, and economic losses.

             A.  Public Health - Toxic agents like mercury and pathogens
             like the hepatitis virus may find their way into the
             human food chain through seafood.

             B.  Recreation - Many beaches have been closed near large
             metropolitan areas.  Floating material, such as solid
             waste and oil, as well as odors from rotting algae and
             anaerobic water, are unpleasant and damage amenity values.

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                                                                      17
          C.  Economic Loss - Ocean pollution has had a substan-
          tial, deleterious effect on the shellfish industry and
          on other seafood industries.  (New methods are being
          developed which may make it possible to clean shellfish
          from contaminated beds.)  Cleaning up and rehabilitating
          polluted beaches is another cost.
Some Important Recent Studies
     In a recently published study of the New York Harbor disposal
areas, the National Marine Fisheries Service has concluded that
the "disposal of dredging spoils and sewage sludges has had a
significant and often deleterious effect on the living resources
of the New York Bight" (9, p. 7-1).  Some of the most important
findings of the study are:
     1.  Heavy metals were found to have accumulated in sediments
directly receiving sludge and spoil, and are spreading out from
the designated points of disposal.
     2.  "Many large crustaceans such as crabs and lobsters
collected inside the disposal areas were diseased."  Also found
in the disposal area were some, but not a large portion, of
diseased finfish (9, p. 7-2).
     3.  "The central portions of the disposal areas contained
almost no normal benthic [i.e. bottom dwelling] macrofauna [like
lobsters]."
     4.  No prolonged effect on the zooplankton or benthic organisms
could be attributed to ocean disposal of industrial acid wastes.
(As Section 2 shows, large quantities of acid waste are disposed
of in the New York disposal areas.)

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18
         In  this  same  report,  other  similar  studies were reviewed.
         1.   A report  by  Grigg and Kiwala  (10)  "indicated a reduction
    in  species diversity  and numbers of  individuals at sewage outfalls
    along, the southern California coastline."  Such reductions indicate
    ecological  stress.
         2.   Shelton  (11),  however,  "was unable to detect a significant
    effect of ocean disposal of sludge on  benthic organisms" of the
    Thames Estuary, perhaps because  of strong currents.
         A significant study by Jannasch e_t  al_. (12) recently reported
    that  they found very  little microbial  degradation of organic
    materials, including  fruit, bread, and meat, over a three-month
    period at a depth  of  1,500 meters.   These results have prompted
    the following statement from the National Marine Fisheries Service:
         "Present disposal  practices have  1) degraded the benthic
         communities of the New York Bight,  2)  produced large amounts
         of  floatable  materials,  and 3)  resulted in generally
         deteriorated .waters and  marine  sediments.  We believe, how-
         ever,  thatxit would be imprudent  to shift ocean dumping
         further  offshore unless  it  is done with considerable caution
         and supervision.   [Jannasch's results  suggest] the possibility
         of  damage to  benthic  nonmicrobial fauna if extensive deep-
         sea dumping were to occur"  (9,  pp.  7-10 and 7-11).

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                                                                       19
             SECTION 4 - ALTERNATIVES TO OCEAN DUMPING
     The 1970 Report to the President by the Council on Environ-
mental Quality discusses various alternatives to ocean dumping (1).
This section will review these alternatives, in some cases with
additional comments based on new studies.
Dredge Spoil - The Council recommended continued ocean disposal
of unpolluted dredge spoil, but conceded that "for polluted
dredge spoils, current disposal practices are not adequate" (1, p. 24)
The National Marine Fisheries Service agrees, concluding recently
that "a high priority should be given to developing new modes of
disposal of contaminated dredging spoils" (9, p. 7-11).  Interim
methods of disposal, suggested by the Council, include disposing
of the polluted material farther from shore or isolating the
material in diked areas.  Jannasch's findings (Section 3) have
led many to oppose disposal of polluted dredge spoil in the deep
sea (Section 6).  On the other hand, the idea of diking has

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20
    recently gained  renewed  attention.  The Army  Corps of Engineers
    has  proposed a diked  disposal  area  south  of Staten Island  (the
    Hoffman-Swinburne  Project).  The  polluted water  from inside this
    specially lined  and diked  basin would  be  decanted through  a
    treatment facility as rain or  new spoil material raised  its
    level.   A feasibility study  for this project  has been endorsed
    by the  Environmental  Protection Agency.
         Longer-range  alternatives include high temperature  incinera-
    tion of polluted spoil and pre-treatment  to remove toxic wastes
    so that the  spoil  can be used  for soil improvement.  Suggestions
    to reduce the quantity of  polluted  spoil  which must be handled
    include better erosion control and  higher levels of waste  treatment.
    Sewage  Sludge -  According  to the  Council, the alternatives for
    disposing of sewage sludge,  both  interim  and  long-term,  are to
    use  it  as a  soil conditioner and  fertilizer,  to  incinerate it,
    or to use it in  landfill and reclamation  projects.  In the New York
    metropolitan area, where 90% of the sewage sludge barged to sea
    originates,  it has been  difficult to implement these alternatives
    quickly.   By almost any  method of returning sludge to the  land,
    the  total quantity of sludge generated in New York would require
    large areas  of disposal  land.  And  incineration  would require large
    capital  expenditures  and might worsen  the area's existing  air
    pollution problems (Section  5).   In a  recent  study it was  found
    that small but measurable  quantities of specific metals  which
    are  known to accumulate  in the human system,  and which are known

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to be toxic at certain levels, were found in the input sludge,
stack emissions, scrubber water, and residue of those incinerators
tested.  Also small, but measurable quantities of specific organic
chemical compounds including various pesticides and polychlorinated
biphenyls, which are known to accumulate in the human system,
were found in all sludge samples analyzed.   It should be expected
that, under conditions of poor combustion,  such compounds could
be emitted from the stacks of sewage sludge incinerators and perhaps
thence to human lungs (13).  Although it is not possible to
establish that health effects are associated with sewage sludge
incineration, these findings are a source of concern nonetheless.
Solid Waste - As was indicated in Section 2, the ocean disposal
of solid waste is not at present practiced  widely.   However, the
Council believes that there will be growing pressure in the future
to dispose of solid waste at sea because of "increasing population;
increasing per capita rates of solid waste  generation; and the
declining capacity, increasing costs, and lack of nearby land
disposal sites" (1).  The Council sees sanitary landfill and
incineration as possible interim alternatives.  In  connection
with landfill, rail haul is mentioned, perhaps to help reclaim
strip mines. Incineration at offshore facilities is a possibility.
Long-term alternatives cited by the Council  include recycling and
generating electric power with fluidized bed reactors fueled by
solid waste.

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22
    Industrial  Waste - A wide variety of materials  are  included  in
    this category and so it is impossible to  give  specific  alterna-
    tives which apply across the board.   However,  in  terms  of  general
    types of interim solutions, the  Council cites  incineration and
    treatment followed by land disposal.  A long-term alternative
    might be to change production processes,  perhaps  by recycling the
    material.  The Council  suggests  that regional  disposal, treatment,
    and'control  facilities  might be  established.
    Construction and Demolition Debris - This material  is usually
    "clean"  and inert, and  the Council,  therefore,  sees no  need  to
    seek alternatives to supervised  ocean disposal.

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                                                                      23
      SECTION 5 - NATIONAL POLICY ON OCEAN DISPOSAL OF WASTE
     In 1970 the Council on Environmental Quality recommended a
comprehensive national policy on ocean disposal of wastes to the
President.  This policy would "ban unregulated ocean dumping of
all materials and strictly limit ocean disposal of any materials
harmful to the marine environment" (1).  The following details
of the Council's policy recommendations are taken from Ocean
Dumping - A National Policy (1, pp. v-viii).
     "The Council recommended new legislation which would:
     (1)  Require a permit from the the Administrator of the
          Environmental Protection Agency for the transportation
          or dumping of all materials in the oceans,, estuaries,
          and the Great Lakes.
     (2)  Authorize the Administrator to ban ocean dumping of
          specific materials and to designate safe sites.
     (3)  Establish penalties for violation of regulations.
     (4)  Provide for enforcement by the Coast Guard.

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24
         "The Administrator of the Environmental Protection Agency
         would   be guided by the following principles in exerting
         his authority:

         (1)  Ocean dumping of materials clearly identified as
             harmful to the marine environment or man should be
             stopped.

         (2)  When existing information on the effects of ocean
             dumping are inconclusive, yet the best indicators are
             that the materials could create adverse conditions if
             dumped, such dumping should be phased out.  When further
             information conclusively proves that such dumping
             does not damage the environment, including cumulative
             and long-term damage, ocean dumping could be conducted
             under regulation.

         (3)  The criteria for setting standards for disposing of
             materials in the ocean and for determining the urgency
             of terminating disposal operations should include:

             (i)    Present and future impact on the marine environ-
                    ment, human health, welfare, and amenities.

             (ii)   Irreversibility of the impact of dumping.

             (iii)  Volume and concentration of materials involved.

             (iv)   Location of disposal, i.e., depth and potential
                    impact of one location relative to others. .

         (4)  High priority should be given to protecting those
             portions of the marine environment which are biologically
             most active, namely the estuaries and the shallow,
             nearshore areas in which many marine organisms breed
             on spawn.  These biologically critical areas should
             be delineated and protected."

         The Council recommended "the following policies relating to
         specific types of wastes currently being dumped . . .

         (1)  Ocean dumping of undigested sewage sludge should be
             stopped as soon as possible and no new sources
             allowed.

         (2)  Ocean dumping of digested or other stabilized sludge
             should be phased out and no new sources allowed.  In

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     cases in which substantial  facilities  and/or significant
     commitments exist,  continued ocean dumping may be
     necessary until  alternatives can  be developed and
     implemented.   But continued dumping should be con-
     sidered an interim measure.

(3)  Ocean dumping of existing sources of solid waste should
     be stopped as soon  as possible.   No new sources should
     be allowed, i.e., dumping by any  municipality that
     currently does not  do so, nor any increase in the
     volume by existing  municipalities.

(4)  Ocean dumping of polluted dredge  spoils should be
     phased out as soon  as alternatives can be  employed.
     In the interim,  dumping should minimize ecological
     damage.  The  current policy of the Corps of Engineers
     on dredging highly  polluted areas only when absolutely
     necessary should be continued, and even then, navigational
     benefits should  be  weighed carefully against damages.

(5)  The current policy  of prohibiting ocean dumping of
     high-level radioactive wastes should be continued.
     Low-level liquid discharges to the ocean from vessels
     and land-based nuclear facilities are, and should
     continue to be,  controlled by Federal  regulations
     and international standards.  The adequacy of such
     standards should be continually reviewed.   Ocean dump-
     ing of other  radioactive wastes should be  prohibited.
     In a very few cases, there may be no alternative offering
     less harm to  man or the environment.  In these cases
     ocean disposal should be allowed  only  when the lack of
     alternatives  has been demonstrated.   Planning of
     activities which will result in production of radio-
     active wastes should include provisions to avoid ocean
     disposal.

(6)  No ocean dumping of chemical warfare materials should
     be permitted.  Biological  warfare materials have not
     been disposed of at sea and should not be  in the future.
     Ocean disposal of explosive munitions  should be terminated
     as soon as possible.

(7)  Ocean dumping of industrial wastes should  b'e stopped
     as soon as possible.  Ocean dumping of toxic industrial
     wastes should be terminated immediately, except in
     those cases in which no alternative offers less harm to
     man or the environment.

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26
         (8)   Ocean  dumping  of  unpolluted dredge spoils, construction
              and  demolition debris,  and similar wastes which are
              inert  and  non-toxic  should be  regulated to prevent
              damage to  estuarine  and coastal areas.
         (9)   Use  of waste materials  to rehabilitate or enhance the
              marine environment,  as  opposed to activities primarily
              aimed  at waste disposal, should be conducted under
              controlled conditions.   Such operations should be
              regulated, requiring proof by  the applicant of no
              adverse effects on the  marine  environment, human health,
              safety, welfare and  amenities."
         On October  7, 1970, President Nixon endorsed the Council's
    recommendations  (14) and shortly  thereafter recommended Federal
    legislation  for  implementing this national policy.  Legislation
    on  this subject  is (as of August  15, 1972) under consideration
    by  Congress.
         Until a new law is  passed the Environmental Protection Agency
    is  using  the Report  of the  Council on Environmental Quality to
    guide its actions and policies as they relate  to ocean dumping
    practices (15, p. 2).  In the  specific case of the Federal Construc-
    tion  Grants  Program  for  the construction of municipal waste
    treatment plants, an interim policy was  established by E.P.A. on
    October 31,  1971  (16).   This interim policy provides that:
         (1)   Federal grant  funds  may not be used  for the construction
    of  new treatment plants  when sludge is to be disposed of in the
    ocean.
         (2)   Federal grant  funds  may not be used  for the expansion or
    improvement  of existing  facilities which dispose of sludge to
    the ocean,unless concurrently  with the expansion or improvement,
    conversion to  other  means of disposal is planned.

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                                                                      27
     (3)  Under certain circumstances, the second requirement
may be waived on an interim basis.  In this case, other require-
ments apply.
     (4)  The cost of facilities and equipment for disposal  of
sludge in ocean waters  is not considered an eligible construc-
tion cost for purposes of a grant.
          The implementation of this policy has created problems
in the New York City area, where approximately 13 million people
depend upon ocean disposal of sludge.   Alternatives to ocean
dumping in the New York metropolitan area would require sub-
stantial investments.  Sludge incineration on the scale necessary
to implement the interim policy might lead to an air pollution
problem less desirable than the results of the current sludge
dumping practice (15).  And land disposal of all sludge produced
by existing plants and those under construction would require
by one estimate 165 square miles per year at a 2 inches  depth (17).
          Because of this situation E.P.A. has under review a revised
interim policy which would permit the continuation of ocean
disposal of sludge from facilities in the New York metropolitan
area.  If adopted, this policy would only apply for those areas
where the environmental alternative to ocean disposal is now
unacceptable and would be an interim solution only (15, p. 3).
          Specifically, this special interim policy for the
New Jersey-New York metropolitan area would include the following

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28
   provisions  (15, pp. 3 and 4):
         (1)  Approval of construction grants with continued ocean
   disposal of sludge provided:
             (a)  Sludge is adequately treated.
             (b)  Industrial waste ordinances regulate the discharge
             of heavy metals or other toxic materials into the
             municipal system.  This industrial waste pre-treatment
             policy must be adopted by E.P.A. and the States
             to assure specific minimum concentrations of objectionable
             materials in the waste treatment plants' influent and
             effluent as well as the resultant sludge.
             (c)  Ocean dumping from the New Jersey-New York metro-
             politan area has to be abandoned when a more effective
             environmental alternative is available through the
             efforts and requirements of the States, E.P.A., and
             regional sludge management authorities.
         (2)  It is recognized that ocean disposal of sludge will
   have  an effect upon the marine environment.  E.P.A. would assume
   its responsibilities in an assessment of these effects by establish-
   ing new dumping sites, controls over dumping practices, and
   evaluating and monitoring the marine environment prior to and
   during the interim ocean disposal of sludge.  This program of
   monitoring and analysis should permit E.P.A. in cooperation with
   the National Oceanic and Atmospheric Administration to expand
   its knowledge of the effects of ocean disposal of treated and
   detoxified municipal sludge.

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                                                                      29
     (3)  E.P.A. would support the formation and operation of
regional intrastate or interstate solid waste disposal  authorities.
It is recommended that this interest be in the form of financial
resources and/or technical assistance.  These authorities would
be responsible for the development of acceptable long-term
alternatives for the management of the sludge problem.   The same
authorities would implement the most effective alternatives to
permit eventual abandonment of ocean disposal.
     No final action has been taken on this proposed revised
interim policy for the New York metropolitan area.

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                                                                       31
           SECTION 6 - FEDERAL OCEAN DUMPING LEGISLATION
     One of the principal recommendations of the Council on
Environmental Quality in its 1970 Report to the President was for
Federal legislation on the ocean disposal of waste (1).  A draft
of such a bill was sent to Congress as part of the President's
1971 Environmental Program.  Although Congress has not yet taken
final action on the ocean disposal bill  (as of August 15, 1972),
passage may come at any time.
     On July 27, 1972, a House-Senate Conference Committee announced
that it had reached agreement on H.R. 9727 (19).  This agreement
cleared the way for House and Senate action on the ocean dumping
law.  As it now stands, the two-year measure provides $39.1 million
for the regulation of dumping, $20 million for the establishment
of marine santuaries, and $12 million for research.  Specific
provisions of the bill include (18):
     1.  an absolute ban on the transportation and dumping of
         radiological, chemical, or biological warfare agents,
         and high level radioactive wastes.

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32
        2.  a prohibition on the transportation and dumping of all
            other waste material unless authorized by permit.
        The following description of the bill  is largely quoted from
   an EPA release (18):
        The Administrator of EPA will  issue a  permit after notice and an
   opportunity for a public hearing when he determines that the proposed
   activity will not degrade or endanger human health, welfare, or the
   marine environment, ecological systems or the economic potentialities.
        When reviewing a permit application, the Administrator must
   consider appropriate alternative locations  and methods of disposal or
   recycling as well as the need and the effects of the proposed dumping.
   A permit may not be issued where the material to be dumped will  violate
   applicable water quality standards.
        In addition, the Administrator is authorized to designate sites
   and/or times within which certain materials may not be dumped.
        The Corps (of Engineers) may issue permits for dumping of
   dredge spoil.  In each case the Corps must  make an independent deter-
   mination based upon the potential effects of a permit denial on
   navigation, economic and industrial development,and foreign and domestic
   commerce in addition to the possible methods of disposal and appropriate
   locations for dumping.
        The Corps cannot issue a permit which  does not comply with the
   criteria relating to the effects or with the sites or times of the
   dumping.  The Administrator will determine  whether the Corps is in
   compliance with such restrictions and the determination of the
   Administrator is final..

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                                                                       33
     If the Corps determines that there is no economically
feasible method or site available, it must so certify and request
a waiver from the Administrator of EPA.  The waiver is automatically
approved thirty days after receipt unless the Administrator finds
the dumping will result in an unacceptably adverse impact on
municipal water supplies, shellfish beds, wildlife, fisheries, or
recreational areas.
     Penalties of up to $50,000 and one year imprisonment are
provided for those who knowingly violate the Act.   As far as citizen
suits are concerned, any person has standing in Federal  courts and
may seek to enjoin violations of the Act or of an  issued permit.
The Coast Guard is given responsibility to enforce the provision
having to do with unlawful transportation of material for dumping.
     The Secretary of Commerce, in conjunction with the  Coast Guard
and EPA, is to develop a comprehensive research and monitoring
program as to the effects of dumping.  The Secretary of  Commerce
is also authorized to initiate a comprehensive and continuing program
of research with respect to the long-range effects of pollution.
In addition, the Secretary of Commerce is directed to conduct research,
investigations, experiments, training demonstrations, surveys and
studies to determine the means of ending all ocean dumping.
     Finally, the Secretary of Commerce is authorized to designate
as marine sanctuaries areas of the oceans, estuaries, and Great Lakes
where he determines that such action is necessary  to preserve them for
their conservation, recreational, ecological or aesthetic values.  No
license or permit can be issued to conduct activity within a designated

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34
   marine  sanctuary.
        The  Environmental  Protection Agency  is now  in the process of
   developing  plans  to  implement  this  law.   If it is passed, the imple-
   mentation plan  would be published shortly thereafter  (20).

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                                                                       35
       SECTION 7 - STATE LEGISLATION AND CONTROL ACTIVITIES
     In 1970 the Council  on Environmental  Quality concluded that
"State regulation has not established a basis for an extensive and
comprehensive method of controlling ocean  dumping.   Besides general
lack of authority and programs, State jurisdiction  would generally
be limited to the 3-mile  territorial  sea"  (1, p.  30).   Since 1970,
activity has varied considerably from State to State.
     In Maryland, a House Joint Resolution was adopted on May 17,  1971,
calling on:
     "The Congress of the United States and the Federal  Department
     of Health, Education, and Welfare [to] take  immediate action
     to halt the pollution of our ocean waters being caused by
     the dumping of untreated wastes  into  the waters of the Atlantic
     Ocean" (21).
     Florida passed a law in 1971 requiring secondary treatment "or
other treatment deemed necessary" on  new ocean outfalls  and by
January 1, 1973 on all industrial waste discharged  through ocean
outfalls (22).  And Maine approved a  law authorizing its Wetlands
Control Board to adopt "orders regulating, restricting,  or prohibiting
dredging, filling, removing or otherwise altering any coastal  wetlands
or draining or depositing sanitary sewage  into or on any coastal

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36
   wetland, or otherwise polluting the same" (23).

        Perhaps the broadest State ocean disposal  control  regulation

   yet proposed is the one currently under consideration  in  New Jersey

   (24).  The New Jersey Department of Environmental  Protection gives

   the following description of the specific provisions of this regulation

   (25):

        Section 1 of the proposed regulations defines the legal
        and technical  terms used in the regulations.

        Section 2 of the regulations prohibits,  outright, the
        handling or loading on vessels for ocean disposal  of
        certain materials whose adverse impact on the marine
        environment is so great that even disposal  far from
        shore would be unwise.  These materials  include pesticides,
        petroleum products, mercury, and radioactive  materials.

        Section 3 of the proposed regulations restricts the  handling
        or loading for ocean disposal of materials  which  are
        generated in such amounts that the onshore  treatment which
        would be required by an outright prohibition  of their
        loading for disposal at sea would not be immediately
        practical.

        These materials are chemical wastes (which  do not contain
        the four materials banned by Section 2 of the proposed
        regulations),  sewage sludge, and polluted dredge  spoil.
        The restriction is that handling or loading on vessels
        of such material shall be in violation of the regulation
        unless the material handled or loaded is disposed of in
        waters deeper than 2,000 meters as shown on the section
        of the U.S. Naval Oceanographic Chart Int.  108, N.O. 131
        reproduced in  the proposed regulation.  Waters of this
        depth occur within 125 miles of the coast line of the
        State.

        The restrictions on loading for ocean disposal of dredge
        spoil apply only to dredge spoil taken from highly polluted
        waterways.  These are the Delaware River south of Camden,'
        New Jersey, Raritan Bay, Raritan River,  Newark Bay,  Arthur
        Kill, Hackensack River, Passaic River, Hudson River, and
        Kill  Van Kull.

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                                                                       37
     Section 4 of the regulations requires that all those persons
     engaged in any phase of the ocean disposal of waste materials
     obtain a permit from the Department within thirty days of
     the effective date of the regulation or prior to the commence-
     ment of their ocean disposal activity, whichever occurs later.
     Section 5 of the regulations requires that every person issued
     a "Permit to Handle or Load Materials for Ocean Disposal"
     shall report monthly  to the Department on the details of
     his loading, handling, and disposal activities.
     A public hearing was held on these proposed regulations on
July 14, 1972.  Testimony included a statement by Mr. Ralph F. Vaccaro
and Dr. Peter H. Wiebe of the Woods Hole Oceanographic Institution,
who cited evidence that biological decomposition of organic matter
is relatively slow in the deep sea and that deep-sea dumping (as
required in Section 3 of the proposed regulations) "is at best a
hazardous pursuit and may be tantamount to storing the wastes
indefinitely."  They suggested "that use of the deep sea for
waste disposal activities should be denied until such time as the
possible dangers are proved invalid" (26).
     The U. S. Environmental Protection Agency supports "the objectives
of the proposed New Jersey ocean disposal control regulations."  EPA
stated, however, that "there has been a recommendation that materials
should be discharged eastward of the 2,000 meter depth line.  This
practice should be avoided and minimized until its environmental
impact can be assessed effectively and be demonstrated to be without
significant harm" (15).  Questions have also been raised about the
geographical extent of New Jersey's jurisdiction.
     As of August 15, 1972, the New Jersey Department of Environmental
Protection was still reviewing testimony on the proposed regulations and
had taken no final action (27).

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                                                                       39
               SECTION 8 - INTERNATIONAL ACTIVITY
     The focal point for recent international activity related to
ocean disposal of waste has been the U.N. Conference on the Human
Environment held in Stockholm, Sweden, from June 5-16, 1972.
     The Preparatory Committee for this Conference recommended in
February 1971 that an Inter-Governmental Working Group on Marine
Pollution be established to prepare some of the action to be taken
in Stockholm.  The first session of this Group was held from June 14-
16, 1971, in London.  During these meetings the United States introduced
draft articles of a convention on the regulation of transportation for
ocean dumping (28).  The Group continued consideration of the draft
articles at its second session in Ottawa from November 8-12, 1971.
As a result of these sessions and subsequent exchanges between the
interested Governments, an  Inter-governmental Meeting on Ocean
Dumping was held at Reykjavik, Iceland from April  10-15, 1972.  At
this meeting, the text of draft articles of a Convention for the
Prevention of Marine Pollution by Dumping was produced.  The meeting
also passed a resolution to forward these draft articles to the
United Nations Conference on the Human Environment for further con-

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40
   sideration and appropriate action (30).

        These draft articles include provisions  for the  following  actions

   by the states parties to the convention  (30):

        1.  Prohibition of dumping of specific materials,  including
            organohalogens (such as DDT), mercury and its  compounds,
            cadmium and its compounds, persistent plastics,  persistent
            synthetic materials which float,  various oils, high  level
            radioactive waste, and agents of  chemical and  biological
            warfare.

        2.  Establishment of a system of permits  for the dumping of
            all  other materials.  Special permits would  be required
            for materials containing significant amounts of arsenic,
            lead, copper, zinc, and their compounds, as  well  as
            organosilicon compounds, cyanides, fluorides,  and pesticides
            not specifically prohibited.  Included also  would be acids
            and alkalies containing significant  amounts  of beryllium,
            chromium, nickel, and vanadium, as well  as bulky wastes
            which might present a serious obstacle to fishing or
            navigation.

        The U.N. Conference on the Human Environment referred this draft

   ocean dumping convention to the U.N.  Seabeds  Committee  for its  comments

   and to a conference to be held in the United  Kingdom  for final

   consideration, if possible, before the end of 1972.  The State  Depart-

   ment says that, "The U.S. strongly supported  . .  . this recommendation

   as offering the best possible opportunity  for prompt  conclusion of

   the work on the ocean dumping convention first proposed by U.S. in

   June 1971" (31, p. 37).

        The U.N. Conference on the Human Environment also  recommended that

   the participating governments (31):

        1.  Accept and implement available  instruments on  the control
            of maritime sources of marine pollution.

        2.  Ensure that the provisions of such instruments are complied
            with by ships flying their flags  and  by ships  operating
            in areas under their jurisdiction.

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                                                                        41


     3.  Control ocean dumping and continue work on ocean dumping
         conventions.

     4.  Participate in the approaching Law of the Sea Conference
         and the 1973 IMCO Marine Pollution Conference with objective
         of bringing all significant sources of pollution in marine
         environment, including radioactive pollution from nuclear
         vessels, under appropriate control and eliminating completely
         by middle of present decade all  intentional  discharge of
         oil from ships.

     5.  Strengthen national controls over land-based sources of marine
         pollution.

     Of these recommendations the U.S. State Department said the

following (31):

     The U.S. supported the entire recommendation as  it urges states
     to take legal measures nationally, regionally, and internationally
     to bring major sources of marine pollution under control.  The
     U.S. has misgivings about carte-blance endorsement of all available
     instruments and believes case-by-case review is  necessary, especially
     of non-binding instruments in form of resolutions, etc., of inter-
     national organizations.  The U.S. does not accept that references
     in paragraphs (2) and (3) constitute endorsement of jurisdiction
     other than that widely accepted in international law.  The
     U.S. interprets the reference to appropriate controls of radio-
     active pollution from nuclear vessels to mean that each government
     will establish and enforce controls  over its own nuclear powered
     naval vessels and that these governments will take into account
     generally recognized international radiation standards.

     Following on the recommendation of the Conference, a meeting has been

tentatively scheduled for October 23 through November 3, 1972, in the

United Kingdom for final consideration of the Convention for the Prevention

of Marine Pollution by Dumping (32).

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                                                                        43
                             REFERENCES
 (1)  Council on Environmental Quality, Ocean Dumping:   A National
      Policy; A Report to the President, Government Printing Office,
      Washington, 1970.

 (2)  Smith, D.D. and Brown, R.P., 1970., An Appraisal  of Oceanic
      Disposal of Barge-Delivered Liquid and Solid Wastes from
      U.S. Coastal Cities.  Prepared by the Dillingham Corporation
      for Department of Health, Education, and Welfare, Bureau of
      Solid Waste Management under Contract No. PH 86-68-203 (mimeograph).

 (3)  Personal communications, James L. Verber, Food and Drug Administra-
      tion, Department of Health, Education, and Welfare, August 14, 1972.

 (4)  Smith, D.D. and Brown, R.P., 1971, Ocean Disposal of Barge-
      Delivered Liquid and Solid Wastes from U.S. Coastal Cities.
      Prepared by the Dillingham Corporation for the Bureau of
      Solid Waste Management, U.S. Environmental Protection Agency
      under Contract No. PH 86-68-203.

,(5)  Data were supplied by Regions I, II, III, IV, VI, IX, and X
      of the Environmental Protection Agency and the District Offices
      of the Corps of Engineers.  They were complied by Region II
      of EPA.

 (6)  Personal communications, Michael Terpilak, Environmental Protection
      Agency, Region II, 1972.

 (7)  Gross, M.G., Analyses of Dredged Wastes, Fly Ash, and Waste
      Chemicals - New York Metropolitan Region, Technical Report
      No. 7, Marine Sciences Research Center, State University of
      New York, Stony Brook, 1970.

 (8)  Corps of Engineers, New York District, Draft Environmental
      Impact Statement, Supervisor of the Harbor Permit Program,
      New York, 1971.

 (9)  U.S. Department of Commerce, NOAA, National Marine Fisheries
      Service, The Effects of Waste Disposal in the New York Bight,
      Sandy Hook Laboratory, Highlands, New Jersey, 1972.

(10)  Grigg, R.W. and Kiwala, R.S., 1970, Some ecological effects of
      discharged waters on marine life, California Fish and Game,
      56:145-55, as described in (9), page 7-6.

(11)  Shelton, R.G., 1970, The effects of the dumping of sewage
      sludge on the fauna of the outer Thames Estuary.  C.M. 1970/E:8,
      International Council for the Exploration of the Sea, as
      described in (9), page 7-7.

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44
  (12)   Jannasch,  H.W.,  Eimijellen,  K., Wirsen, C.O., and Farmanfarmaian,
        A.,  1971,  Microbial  degradation of organic matter in the deep
        sea.   Science  171,672-675, as  described in (9), page 7-11.

  (13)   Environmental  Protection Agency, Task  Force Report on Sludge
        Incineration,  1972.

  (14)   Report on  Ocean  Dumping - Message from the President (H. Doc.
        No.  91-399,  the  White  House, October 7, 1970.

  (15)   Environmental  Protection Agency, Region II, Statement on Proposed
        New  Jersey Ocean Disposal Regulations, submitted to the New Jersey
        Department of  Environmental  Protection August 14, 1972.

  (16)   Environmental  Protection Agency, Interim  Policy on Section 8
        Grants for Treatment Works Which Dispose  of Digested Sludge
        in Ocean Waters, Washington, October 21,  1971.

  (17)   David  Bird,  "U.S.  Relaxes Policy on Dumping Sludge", quoting
        G.M. Hansler,  E.P.A.,  New York Times,  March 11, 1972.

  (18)   Environmental  Protection Agency, Office of Legislation, Special
        Dumping Supplement,  Washington, July 28,  1972.

  (19)   U.S. House of  Representatives, H.R. 9727, 1972.

  (20)   Personal communications with Scott Shotwell, EPA, Washington,
        August 16, 1972.

  (21)   Maryland,  Resolution 68, Laws  1971, House Joint Resolution
        No.  97, Approved May 17, 1971.

  (22)   Florida, Chapter 274,  Laws 1971, Senate Bill No. 745, Approved
        June 24, 1971.

  (23)   Maine, Chapter 541,  Public Laws 1971,  House Bill No. 1299,
        Approved June  28,  1971.

  (24)   New  Jersey Department  of Environmental Protection, Proposed
        New  Jersey Ocean Disposal Control Regulation, Filed with the
        Division of  Administrative Procedures  May 25, 1972.

  (25)   New  Jersey Uepartment  of Environmental Protection, Ocean Disposal
        Control Regulation:  Basis and Background Document, June 1972.

  (26)   Statement  by Mr.  Ralph F. Vaccaro, Associate Scientist, and Dr.
        Peter  H. Wiebe,  Assistant Scientist, Woods Hole Oceanographic
        Institution  at the Public Hearing on Proposed New Jersey Ocean
        Disposal Control  Regulations,  Monmouth College, West Long Branch,
        New  Jersey,  July 14, 1972.

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                                                                       45

(27)  Personal  communications  with  New Jersey  Department  of  Environmental
      Protection,  August 15,  1972.

(28)  United Nations  Conference  on  the Human Environment,  Report of the
      First Session of the  Inter-Governmental  Working  Group  on Marine
      Pollution.  London, June  14-18.  1971.  A/Conf.  48/IWGMP.I/5,
      June 21,  1971.

(29)  United Nations  Conference  on  the Human Environment,  Identification
      and Control  of  Pollutants  of  Broad  International  Significance,
      A/Conf.  48/8, January 7, 1972.

(30)  United National  Conference on the Human  Environment, Identification
      and Control  of  Pollutants  of  Broad  International  Significance,
      Addendum No.  1:  Draft Articles  of a Convention on Ocean Dumping,
      A/Conf.  48/8/Add.  1,  May 2, 1972.

(31)  United States Department of State,  U.N.  Conference  on  the Human
      Environment:  Round-up  of Actions Taken, June 21, 1972.

(32)  Personal  communication  with Mr.  Robert Porter of the Office  of
      International Affairs,  Environmental  Protection  Agency, August 14,
      1972.

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