xvEPA
United States
Environmental Protection
Agency
Office of
(WH-556F)
EPA 503/9-90/002
December 1989
Surveillance And Enforcement
Of Sewage-Sludge Dumping
Report To Congress
BASE STATION
Governors Is., NY
RELAY STATION
Sandy Hook, NJ
Printed on Recycled Paper
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REPORT TO CONGRESS
on
Surveillance and Enforcement of
Sewage Sludge Dumping
July 14,1988, to March 31,1989
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EXECUTIVE
SUMMARY
This Report to Congress presents the progress of the United
States Coast Guard and the United States Environmental Protec-
tion Agency (EPA) in the use of the Ocean Dumping Surveillance
System (ODSS). The ODSS is the electronic surveillance system
used to track barges that transport sewage sludge to the Deep-
water Municipal Sludge Dump Site, commonly known as the 106-
Mile Site. This report was prepared by EPA in consultation with
the United States Coast Guard as required by Section 1004 of the
Ocean Dumping Ban Act (ODBA) of 1988, which amends the
Marine Protection, Research, and Sanctuaries Act of 1972
(MPRSA, PL 92-532).
The ODBA requires EPA, in consultation with the Coast Guard, to
report to Congress on the progress of the electronic surveillance
system and other means to monitor and prevent illegal dumping
of sewage sludge. This report covers the performance of the
ODSS between July 14, 1988, and March 31, 1989. These dates
are the effective date of ODSS operation, when enforcement
began, and a cutoff date selected in order to analyze the ODSS
data and comply with the legislative report requirement. The
report summarizes EPA's related enforcement activities during
this same period, and discusses future needs for installing and
fabricating additional ODSS units and upgrading or modifying the
system.
Historically, surveillance of ocean dumping operations has been
carried out, to a limited extent, by shipriders, who are inde-
pendent observers (usually Coast Guard personnel) that remain
on board the towing vessel or self-propelled vessel for the dura-
tion of the dump mission. Airplane overflights and observations
from nearby vessels were also used on occasion, but were found
to be impractical and of limited value. All of these surveillance
activities created a drain on Coast Guard resources and have
been almost entirely phased out over the years.
In the early 1970s, the Coast Guard conducted research into the
development of an Ocean Dumping Monitoring System. This
system would have utilized a recording device to record vessel
data on tape. However, this system was not adopted because
collecting the tapes from the vessels and processing the data
would have been manpower intensive. In 1984 the Coast Guard
began research and development of the ODSS, using $500,000 in
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funds allocated by Congress for this purpose. The ODSS was
designed to provide full real-time coverage of the entire 12-Mile
Site operational area. Data on each vessel's status would be
almost instantaneously telemetered via radio signals from the
vessel's "black box" to the Coast Guard base station on Gover-
nors Island, New York. If a violation occurred anywhere in the
operational area, the Coast Guard would be almost instantly
alerted and could contact the vessel via VHF-FM radio.
After the 12-Mile Site was closed and all vessels carrying sewage
sludge were required to dump at the 106-Mile Site, the size of the
operational area that the Coast Guard was required to monitor
increased more than 10-fold. The Coast Guard had to decide
whether it should revise the design of the system, or adopt a new
configuration that uses satellite coverage to provide complete
real-time coverage of the greatly expanded operational area. The
Coast Guard decided against satellite coverage because it could
not be certain when a geosynchronous satellite would be suc-
cessfully launched from an Arian rocket. Although the design that
the Coast Guard selected can only provide real-time coverage up
to 60 nautical miles from its relay station at Sandy Hook, New
Jersey, all components of the system are entirely under the
control of the Coast Guard. When the vessel is outside of the
range of the relay station, data on the vessel's status is stored in
the on-board black box computer and is telemetered to the base
station as the vessel returns to port. After the base station re-
ceives the data, a printout of the vessel's trackline and dump
status for the entire mission can be made. If the printout shows a
violation, EPA could use the printout as a basis for an enforce-
ment action.
Sixteen ODSS units have been installed on the 16 oceangoing
vessels authorized by EPA to dump sewage sludge at the 106-
Mile Site. Each time a vessel dumps sludge at the 106-Mile Site it
is considered to be one dump mission. The Coast Guard consid-
ers any dump mission printout that shows the time, date and
coordinates of the vessel during the dumping operation, as well
as draft readings from at least one transducer (or pressure sen-
sor), to be complete. During the period covered by this report,
there were typically 50 to 65 dump missions per month. During
the first five months of its operation, the ODSS averaged almost
42 percent complete printouts. During the next four months of
operation, its perfomance rating averaged only 14 percent, lower-
ing the average ODSS performance rating for the whole reporting
period. Overall, during the first 9 months of operation, the num-"
ber of complete ODSS printouts obtained for each month ranged
from 7 to 46 percent, with an average of 29 percent.
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This performance rating of 29 percent complete printouts fell
short of the Coast Guard's goal of 80 percent complete printouts.
However, even partially complete printouts can provide valuable
information. For example, if only the time, date, and coordinates
of the vessel are obtained from the ODSS printout, EPA can
compare the actual amount of time a vessel remained inside the
106-Mile site with the calculated amount of time it would take the
same vessel to dump its sludge at the permitted rate of discharge.
If the printout shows that the time that the vessel remained in the
site was less than the time required to dump at the permitted rate,
then the vessel must have exceeded its maximum permitted
dumping rate, dumped outside of the 106-Mile Site, or both.
Therefore, even if none of the transducers are functioning, an
enforcement action may be possible.
Even though the ODSS has not attained its performance goals,
the design of the ODSS provides a deterrent effect because the
ocean dumpers do not know when the system is or is not working
properly. Therefore, any ocean dumper that engages in illegal
dumping in the hope that the ODSS may not be working is taking
a risk. However, because the performance of the ODSS has been
inconsistent, EPA is concerned that the deterrent effect of the
ODSS has been diminished.
There are no plans for installing ODSS units on the shallow draft,
or feeder, vessels that transfer sludge to oceangoing vessels or
land-based storage tanks. Navigation to some treatment plants
can only be accomplished by feeder vessels because waters are
too shallow or access is too narrow to permit passage of larger
oceangoing vessels. The ODSS units are designed to provide
surveillance of dumping operations and vessel movements to and
from the designated dump site. Therefore, as now configured,
the units are not practicable for use in monitoring the feeder
vessels, which frequently load and unload sludge at different loca-
tions.
To provide additional surveillance, in February of 1989, EPA
began implementation of a cradle-to-grave manifest and seal
system designed to monitor all sludge transfers. Under this
system all dump valves on each feeder vessel or oceangoing
vessel will be sealed, with EPA-supplied seals, before any sludge
is loaded onto the vessel. Immediately after each sludge transfer,
an inspector approved by EPA will seal all other valves. These
inspectors will also record the volume of sludge transferred and
other pertinent information on sludge manifest forms. The Coast
Guard will conduct spot checks of the feeder vessels and ocean-
III
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going vessels while they are transporting sludge through the
harbor. If any seals are found to be broken or missing, or show
signs of tampering, the vessel may be required to immediately
return to port, where a full investigation can be conducted. The
purpose of this system is to prevent illegal short dumping of
sludge and also to prevent any prohibited or banned substances
from being surreptitiously loaded onto the vessels along with the
sewage sludge. This system has been operating as a pilot
program since February 1989. When the special ocean dumping
permits became effective on August 14, 1989, the manifest and
seal system became a permit condition.
Although the ODSS has fallen short of its goal of obtaining com-
plete printouts for 80 percent of all dump missions, it must be
remembered that the system has been fully operational for about
one year. The Coast Guard has continued to work on difficulties
encountered during this time period. However, some problems
are persistent and have undermined the reliability of the entire
system. EPA has strongly encouraged the Coast Guard to em-
ploy an independent contractor to evaluate and review the entire
system from top to bottom.
Several plans for upgrading the ODSS to provide near real-time
coverage of all or most of the operational area are discussed and
evaluated in this report. EPA is encouraging the Coast Guard to
implement and test one of these plans, as well as to increase
efforts to improve the overall reliability of the system. EPA-
approved shipriders, supplied by the permittee, will be required
on all vessels transporting sludge to the dump site in the interim.
iv
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TABLE OF CONTENTS
Executive Summary i
Acknowledgements vi
Introduction 1
The Regulatory Need for Electronic Surveillance 1
Development of the Ocean Dumping Surveillance System 2
About This Report 3
The ODSS 4
Overview 4
Components of the ODSS 4
Electronics Package 4
Transducers 5
Base Station 6
Operation of the ODSS 7
Interrogation Intervals 7
Dump Determination 7
ODSS Screen Displays 9
Advantages of the ODSS as a Surveillance Tool 12
Accuracy of the ODSS 14
Installation of the ODSS 15
Sludge Manifest and Seal System 16
Effectiveness of the ODSS
Completeness of ODSS Coverage 19
Violations of Ocean Dumping Permits 21
Limitations to the ODSS 22
Need for Installation of Additional ODSS Units 24
Improvements to the ODSS 25
Antenna on the World Trade Center or Loran Tower .... 25
Satellite Link 26
Communications Capability 27
Conclusions and Recommendations 28
Glossary and Acronyms 30
Appendix A 32
Vessels Authorized to Dump Sludge 32
Permittees Authorized to Dump Sludge 33
Appendix B 34
ODSS Printout . . 34
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ACKNOWLEDGEMENTS
This report was prepared by Mr. Albert L. Visconti, U.S. EPA
Region II, Ocean Dumping Task Force, New York, New York. The
work assignment manager was Ms. Karen Klima, U.S. EPA Office
of Marine and Estuarine Protection, Washington, DC.
Technical data and diagrams were supplied by the U.S. Coast
Guard's Office of Research and Development, Groton, Connecti-
cut. Support was also provided by U.S. Coast Guard Technicians
and Officers at U.S. Coast Guard Headquarters, Washington, DC,
and at Governors Island, New York, New York.
vi
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INTRODUCTION
The Regulatory Need for Electronic Surveillance
Ocean dumping of sewage sludge has occurred since 1924. The
practice of ocean dumping developed over the years because it
was a convenient and comparatively inexpensive means of waste
disposal. In 1972, Congress passed the Marine Protection,
Research, and Sanctuaries Act (MPRSA) to regulate the disposal
of wastes in the ocean. As amended, MPRSA is the primary
legislative authority directly related to ocean dumping. Under
MPRSA, EPA is responsible for issuing permits for sewage sludge
disposal and for designating, managing, and monitoring ocean
disposal sites. Surveillance of operational aspects of permitted
disposal and enforcement of permit conditions are joint responsi-
bilities of EPA and the Coast Guard. Under Section 107 of
MPRSA, the Coast Guard is required to conduct surveillance of
ocean dumping activities.
A barge dumps and the 165-foot
EPA Ocean Survey Vessel Peter
W. Anderson enters the plume to
conduct monitoring studies.
In 1984, EPA designated the 106-Mile Site to receive municipal
sewage sludge. The 106-Mile Site is located 120 nautical miles
southeast of Ambrose Light, New York, and 115 nautical miles
from Atlantic City, New Jersey. In 1986, EPA instructed the
sewerage authorities to begin shifting their dumping activities
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from the 12-Mile Site to the 106-Mile Site. In December of 1987,
dumping activities at the 12-Mile Site were phased out entirely,
and all dumping of sewage sludge was conducted solely at the
106-Mile Site.
Several recent marine pollution events focused the attention of
many legislators, the news media, and the public on a potential
relationship between environmental degradation and dumping
activities at the 106-Mile Site. In response to this increased
attention, Congress passed the Ocean Dumping Ban Act of 1988
(ODBA), which makes ocean dumping of sewage sludge and
industrial waste unlawful after December 31, 1991.
ODBA requires, among other activities, that EPA, in consultation
with the Coast Guard, prepare a report to Congress on the prog-
ress made in using electronic surveillance equipment and other
means to monitor and prevent dumping of sewage sludge outside
of the designated 106-Mile Site by vessels carrying sewage
sludge. This report fulfills that requirement.
Development of the Ocean Dumping
Surveillance System
Over the years, the Coast Guard's ocean dumping surveillance
goals have not been met for a variety of reasons. Bad weather
can often force cancellation of aerial surveillance missions, and
aerial surveillance at night is not feasible. Safety considerations
can preclude a Coast Guard vessel from getting close enough to
a barge to observe when it begins or stops dumping. Lack of
personnel only allowed the Coast Guard to place shipriders on a
limited number of vessels that transport sludge to the dump site.
To improve their surveillance capabilities, in the early 1970s, the
Coast Guard conducted research into the development of an
Ocean Dumping Monitoring System. This system would have
used a recording device to record vessel data on tape. However,
this system was not adopted because collecting the tapes from
the vessels and processing the data would have been too man-
power intensive. In 1984, the Coast Guard began development of
a new technology to monitor ocean dumping activities, the Ocean
Dumping Surveillance System (ODSS), using $500,000 in funds
allocated by Congress for this purpose.
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In 1985 and 1986, prototypes of the ODSS units were installed on
New York City's self-propelled sludge vessel, the M/V North
River, and on towed sludge vessels. Tests were conducted by
the Coast Guard. Based on the results of these tests, the Coast
Guard believed that complete coverage of the entire fleet of
authorized sludge vessels could be achieved if ODSS units were
installed on all of the vessels.
In November 1987, EPA instructed all waste transporters to
coordinate the dry docking of their vessels with the Coast Guard
to enable the Coast Guard to install the ODSS units on all EPA-
authorized oceangoing vessels. EPA designated May 15, 1988,
as the date after which only vessels equipped with an ODSS unit
would be permitted to ocean dump sewage sludge. On July 14,
1988, it was announced that the Coast Guard had completed ini-
tial shakedown and testing of each of the installed ODSS units
and the system was considered operational. However, further
system engineering and shakedown testing was required to
resolve various system problems.
About This Report
This report covers the performance of the ODSS between July 14,
1988, and March 31, 1989 and related EPA enforcement activities
during this same period. These dates are the effective date of
ODSS operation, when enforcement began, and a cutoff date
selected in order to analyze the ODSS data and comply with the
legislative report requirement. The report examines the scope
and limitations of the ODSS and describes EPA and Coast Guard
efforts to overcome these limitations. EPA's sludge manifest and
seal system, a system developed to track and monitor barge
operations in the New York and New Jersey Harbor areas, is also
described and discussed. Finally, future needs for installing and
fabricating additional ODSS units and upgrading or modifying the
system are explored.
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THE ODSS
Overview
The ODSS includes three main components:
• The electronics package or "black box," which is installed by
the Coast Guard on all 16 vessels authorized by EPA to dump
sewage sludge.
• The transducers, or pressure sensors, which measure
changes in the vessel's draft and are also installed on all au-
thorized dumping vessels with the exception of two of the
smaller vessels, the Leo Frank and the Sofoco //.
• The base station, located on Governors Island, NY, and the
relay station located at Sandy Hook, NJ.
All of the components of the ODSS and the roles they play in the
operation of the system are discussed in this section.
Components of the ODSS
Electronics Package
An electronics package, or "black box" is installed on each
vessel that is authorized by EPA to dump sewage sludge at the
106-Mile Site. The electronics package consists of a modified
Loran receiver to determine the vessel position, a real-time clock
to establish the date and time when the vessel is at a given
position, circuitry to read the transducers and Loran, a com-
munications package, and battery back-up. The communica-
tions package contains a radio transmitter, a radio receiver, a
linear amplifier, and a packet controller. The entire electronics
package is encased in a tamper-resistant box to which only Coast
Guard personnel have access. Also mounted on the vessel are a
communications antenna and a Loran antenna.
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Cutaway view of the electronics
package or "black box."
Transducers
Transducers, or pressure sensors, are used to measure changes
in the vessel's draft. Typically, there are three transducers
mounted in the hull of the vessel in three locations: fore, aft and
amidships. These are connected through circuitry to the on-
board computer inside the black box. The computer converts the
pressure sensor readings to draft readings. As a vessel dumps
sludge it becomes lighter, consequently its draft decreases as it
rises in the water. The vessel's draft and its position in latitute
and longitude are shown on the ODSS printouts. (Refer to Ap-
pendix B.) This information is used to determine whether a vessel
has dumped within the designated site. ODSS printouts have
only been used to measure average discharge rates, not instanta-
neous dumping rates.
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Base Station
The base station is located on Governors Island, New York. The
heart of the system is the base station's minicomputer. The base
station computer interrogates the vessel's computer, deciphers
the vessel's replies, puts the information in the data base, and
backs up the data base.
Instructions to the computer are entered through the system
manager's console, a desktop computer with a standard CRT
display and keyboard. Another desktop computer with a touch-
sensitive screen serves as the watchstander's console, where the
operator can interrogate any vessel in the system. A printer is
available to print out copies of the video display. A major factor ir
the selection of the computers used as the watchstander's con-
soles was the touch-sensitive video display. This feature allows
the user to interact directly with the screen without the need for a
keyboard, and is important for a user interface that non-technical
watchstanders can use with confidence.
Other base station equipment includes a communications pack-
age, a Loran receiver, two antennas, and a battery backup. The
VHF-FM radio communication system uses a commercial-grade
transmitter and receiver with a multi-tone, time-diversity modem.
Base station equipment.
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Operation of the ODSS
The ODSS monitors all vessels that are authorized by EPA to
dump sewage sludge at the 106-Mile Site. Basically, the ODSS
operates as follows: The base station interrogates each vessel in
its data base at least once each hour, and the vessel's black box
replies, giving the vessel's status and providing information on the
location, draft, and back-up battery status from each unit. Each
vessel is assigned a three-digit identification number so that the
base station can identify which ODSS remote unit it is interrogat-
ing.
Interrogation Intervals
The base station computer conducts interrogations of the vessel's
black box computer at various intervals. The interrogation interval
and number of updates depend on the last known location and
status of the vessel. When the vessel is docked in port, the
vessel is interrogated once each hour, and when the vessel is
underway in port or at sea, it is interrogated once every 20 min-
utes. When the vessel is outside of communications range, its
black box computer will store data on the vessel's status every 20
minutes, and upon entering the buffer, or near zone, around the
106-Mile Site, it will store data every 2 minutes. After the reduced
dumping rates became effective on August 14,1989, this interval
was increased to 6 minutes to accomodate the longer dumping
times.
Dump Determination
The ODSS keeps track of a maximum draft for each vessel. The
transducers provide information on draft measurements to the
vessel's black box computer. When the vessel is in port, the draft
is measured when the base station conducts its hourly interroga-
tion. When the vessel leaves port, the maximum draft can be
increased (the vessel is allowed to take on seawater as ballast)
but not decreased. Once the draft decreases by a specified
amount below the maximum draft, the system is triggered and
considers the vessel to be dumping.
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Power
Amp
XMTR
Receiver
Relay Station
Base Station
Vessel Installation
ODSS Operations Diagram. A schematic representation of the ODSS, showing how the components are related to
each other during operation.
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ODSS Screen Displays
The ODSS screen displays allow the watchstander to view infor-
mation about the ocean dumping operations being monitored by
the ODSS. The screens display information on each of the 16
vessels authorized by EPA to dump sludge at the 106-Mile Site.
Some examples of the screens that are frequently used are
shown below:
Julian
Date
Time
Vessel List and
Compliance Screen.
The Vessel List and Compliance Screen displays all 16 vessels
in the database and the current vessel status and black box
status of each. If a vessel status changes, it shows brighter than
normal until the watchstander acknowledges it by touching the
vessel square. If the new status is a violation or a fault (BAD
DUMP, NO AC POWER, TAMPERING), the whole square shows
brighter and blinks. Touching the blinking violation square will
call the Vessel Status screen, which contains additional informa-
tion, for that particular vessel. The watchstander is able to have a
copy of the Vessel Status screen printed by touching PRINT
SCREEN.
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I ..... VESSEL
ID* NflflE
144 KIMBERLY ANN
1* LISA
1* LISfl
U5 NORTH RIVER
144 KIMBERLY ANN
145 NORTH RIVER
145 NORTH RIVER
144 KIMBERLY ANN
146 LISA
145 NORTH RIVER
145 NORTH RIVER
145 NORTH RIVER
145 NORTH RIVER
146 LISA
145 NORTH RIVER
H7 MARIA
146 LISA
146 LISA
146 LISA
MISSION .................. | | ......... |
.... ...I END I R£F»
8 MAR 86 STILL'ftCfivf"
23 JAN 86 12:00 6 MAR 86 567
8 DEC 85 12:00 23 JAN 86 CMC
8 DEC 85 12:00 6 MAR 86 LCDR
8 DEC 85 01:00 8 MAR 86 HINTON
8 NOV 85 07:00 5 DEC 85
8 NOV 85 12:00 8 NOV 85
7 NOV 85 23:50 7 NOV 85 00714
7 NOV 85 12:00 6 MAR 86
7 NOV 85 12:00 6 MAR 86
6 NOV 85 23:59 6 NOV 85 COTP-123
5 NOV 85 23:59 5 NOV 85 HI THERE
5 NOV 85 10:31 5 NOV 85
22 OCT 85 23:C9 22 OCT 85 UVU
17 OCT 85 23:59 17 OCT 85 STORK
11 OCT 85 00:00 12 JAN 85
11 OCT 85 22:00 10 OCT 85 CG1234
10 OCT 85 22:00 10 OCT 85
9 OCT 85 15:00 10 OCT 85
Mission Master File Screen.
The Mission Master File Screen lists the mission numbers in
order, most recent at the top, along with the vessel name and I.D.
number, the date and time that each mission started and ended,
and the Captain of the Port (COTP) Reference Number for each
mission. The COTP Reference Number is assigned to each
vessel by the Coast Guard contact person at the start of each
dump mission and is unique for each dump mission. The mission
numbers are assigned chronologically by the computer (1-99) but
are not unique for each dump mission-after counting to 99, the
mission numbers are repeated. Each of the 16 vessels in the fleel
has a unique, three-digit vessel identification number. A copy of
the mission master file can be printed by touching PRINT
MASTER.
10
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Vessel: LISA
Box * 146
MISSION i 24
COTP « die
23 9:05:00
VESSEL OWNER: MODERN TRftNS.
PHONE: 201-589-0277
DESTINATION: 106-I1ILE SITE
HISSION START: 12:34 8 DEC 85
ETA DUMP SITE: 00:00 8 DEC 85
QTY TO DUMP: 900 cu.ft.
TOW FIRM: (NONE)
DRAFTS: MISSION FULL.
NORHAL FULL .
NORMAL EMPTY.
CURRENT READINGS
13:35 20 DEC 85
DOCKED
40 35.05N / 73 55.60U
10.0 13.4 11.2
11.5 . . .
ok ...
TIME OF READINGS
. VESSEL STATUS .
. . LOCATION . .
DRAFTS
. (fud.iid.aft)
. . . BATTERY . .
. . . LORAN . .
. . AC POWER .
. . INTRUSION .
PREVIOUS READINGS
13:31 20 DEC 85
. . . DOCKED
40 35.05N / 73 55.60W
. 10.0 13.4 11.2
. . . 11.5
ok
Vessel Status Screen.
The Vessel Status Screen displays the current status information
for a specific vessel. If the vessel is outside of the range of the
ODSS (60 nautical miles from Sandy Hook, NJ) the screen will
show the status of the vessel at the time of the last communica-
tion.
Vessel Specification Screen.
VESSEL: NORTH RIVER
OHNER: NEW YORK CITY
LENGTH
BEAfl
CAPACITY
DISPLACEMENT' inAxiiiiin i'.'.'.!'.'.!!
NORMAL DRAFT (FULL)
(EMPTY)
DUMP INDICATOR (BEGIN)
(END)
SENSOR LONGITUDINAL DISTANCE..
VERTICAL DISTANCE (even keel')'.
Vessel ID: 145
(212-860-93424
79 11:26:25
325 feet
49 feet
107000 cubic feet
6549 long tons
15.0 feet
4.9 feet
1.7 feet less than max. calculated draft
7.9 feet calculated draft
0 feet (FWO to HID)
0 feet (HID to AFT)
0 feet (FIC sensor LOWER than HID)
0 feet (AFT sensor LOWER than MID)
SLUDGE
LAST KNOWN POSITION: 41 18.SON 72 3.51U
AS OF 07:25 19 IK* 86
The Vessel Specification Screen displays information describing
the vessel. This information (e.g., length, beam, capacity,
11
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displacement etc.) generally does not change. It is entered into
the system through the System Manager's Program and can only
be modified by using this program.
Vessel name
Vessel ID number \^Period covered by track
Mission
number
Vessel Position Screen.
106-mile dump site
12
The Vessel Position Screen displays a representation of the New
Jersey coast and offshore area. This display shows the vessel
path to and from the 106-Mile Site and the vessel position when
dumping inside the site. A copy of the screen can be printed by
touching PRINT SCREEN.
Advantages of the ODSS as a Surveillance Tool
The ODSS was designed to be easy to learn and easy to use, and
to minimize the workload of the personnel necessary to operate
the system. The watchstanders and the system manager have
multi-mission responsibilities and can not devote their full time to
operation of the system. Therefore, the Coast Guard developed a
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simple touch-screen interface for the watchstanders and a soft-
ware program that automatically generates information on dump-
ing activity.
The Coast Guard initially estimated that between the watch-
standers and system manager, operation of the ODSS will require
about one resource-year to operate the system for an entire year.
More recent estimates by the Coast Guard indicate that about five
resource-years will be required. In comparison, it would require
approximately 26 resource-years to maintain shipriders on the
vessels going to and from the dump site during the same time
period.
The "black box", opened to show
its components.
13
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Accuracy of the ODSS
The key piece of equipment in each vessel's black box is the
Loran receiver. This component receives signals from the Coast
Guard's land-based Loran-C Navigation System to determine its
precise location. The Loran receiver inside the black box is
similar to the Loran receiver that the master of the vessel uses to
navigate to the 106-Mile Site. Both Loran receivers will display the
same coordinates at the same time. Therefore, the question of
ODSS accuracy really has to do with how efficient the rest of the
ODSS system is at accurately relaying the information contained
in the Loran receiver to the base station. In an attempt to answer
this question, EPA compared two independent sources of infor-
mation; the ODSS printouts and the Ocean Dumping Notification
Forms (ODNF) that EPA, through a permit condition, requires
vessel masters to submit after each dump mission. The critical
points and times (i.e., enter and exit dump site, start and end
dump) from the two sources were shown to match. Because a
vessel is permitted to enter and exit the dump site at any coordi-
nates it chooses, the chances of a match being mere coincidence
are almost nonexistent. Additionally, the coordinates of the
sludge generator's docking facilities were checked against the
coordinates shown on the ODSS printouts when the vessels were
at the docking facilities. The two sets of coordinates were found
to be the same, confirming that complete ODSS printouts accu-
rately identify the location of the vessel.
The transducers, which measure changes in water pressure, are
connected through circuitry to the computer inside the black box.
This computer, after discounting for the effects of wave action,
uses the pressure readings from the transducers to determine the
draft of the vessel. Although the transducers measure the draft of
the vessel accurately when they are functioning, the number of
incidents when the transducers are not working properly is unac-
ceptably high. The Coast Guard is working on a way to improve
the durability of the transducers.
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INSTALLATION OF
THE ODSS
All barges authorized to dump
sewage sludge now have ODSS
units installed on board.
On November 24, 1987, at a meeting of the ocean dumpers, the
Coast Guard, and EPA, held at Coast Guard headquarters on
Governors Island, New York, the Coast Guard requested that the
waste transporters furnish them with the mechanical, electrical,
and structural drawings for each of the vessels authorized by EPA
to dump sewage sludge at the 106-Mile Site. The Coast Guard
supplied and installed the black box, hull transducers, hull inserts,
antennas, and all necessary cables and connections, at an
estimated cost of $25,000 per unit. The waste transporter was
responsible for supplying and mounting brackets for cables and
antennas, making all necessary waterproof bulkhead holes for the
cables, mounting the hull inserts into which the transducers are
installed, routing the cable from the transducers and antenna to
the black box, and providing the black box with an AC power
source.
In May 1988, the Coast Guard completed installation of 11 ODSS
units on oceangoing vessels that dump sludge at the 106-Mile
Site. Since then, five of the smaller oceangoing vessels have also
been equipped with the ODSS units. This provides position
coverage of the entire fleet of 16 vessels and the dump status of
14 of the vessels that are authorized by EPA to dump sewage
sludge at the 106-Mile Site.
15
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SLUDGE MANIFEST
AND SEAL SYSTEM
There are at least 10 feeder vessels that are used to transport
sludge from the sludge storage tanks on land to the larger,
oceangoing vessels. Navigation to some treatment plants is
restricted because of shallow waters or narrow access and the
feeder or shallow draft vessels are used to service these treat-
ment plants.
ODSS units have not been installed on the feeder vessels and
there are no plans to do so in the future. The ODSS was de-
signed to provide surveillance of dumping operations and vessel
movements to and from a specific designated site. Therefore, the
ODSS units as now configured are not practicable for monitoring
the feeder vessels, which are frequently loading and unloading
sludge at different locations.
EPA has closed this surveillance and enforcement gap in the
ODSS through its sludge manifest and seal system. Implementa-
tion of the plan began in February 1989. The purpose of this
system is to prevent illegal short dumping of sludge and to pre-
vent any prohibited or banned substances from being surrepti-
tiously loaded onto the dump vessels along with the sewage
sludge. This system has been operating as a pilot program;
however, now that the special ocean dumping permits have
become effective as of August 14, 1989, the manifest and seal
system is a permit condition.
The sludge manifest and seal system was designed to provide
cradle-to-grave tracking of all sludge transfers, from their point of
origin to ultimate disposal at the 106-Mile Site. Under this system
all dump valves on each vessel will be sealed, with EPA-supplied
seals, before any sludge is loaded onto the vessel. Immediately
after each sludge transfer, an inspector approved by EPA will seal
all other valves. These inspectors will also record pertinent
information about each sludge transfer on sludge manifest forms.
Two distinct types of seals are used. One type of seal is required
on valves that are frequently used to load or unload sludge, or to
dump sludge at the 106-Mile Site. Another type of seal is required
on valves that must be permanently sealed. Ten-inch plastic
Poly-Lok Seals have been selected for use on valves that do not
require a permanent seal. Each of these seals has the words "US
EPA Region II" and a seven-digit serial number embossed in
white for easy identification. These seals will show whitish blush
marks if any attempt is made to tamper with them.
16
-------
Poly-Lok seals used to seal the
barge's dump valves.
Fiber optic seals have been selected to permanently seal the
dump valves on the feeder vessels. Many of these vessels were
previously used to dump sludge at the 12-Mile Site and thus have
discharge pipes that can dump sludge out of the bottom of the
vessel. Any illegal dumping through these pipes would occur 4 to
12 feet below the water surface and would be extremely difficult to
detect, especially at night. A paramount concern in the design of
the sludge manifest and seal system was the integrity of the
permanent seals for the valves that operate these discharge
pipes.
The fiber optic seal was selected because it uses state-of-the-art
seal technology. Each fiber optic seal consists of a durable
protective polyethylene jacket that covers randomly positioned
acrylic optical fibers. Once the seal is fastened, the optical fibers
form a unique fiber optic "fingerprint." A special camera is used
to photograph the fingerprint. Fiber optic seals have been used
to seal diplomatic pouches, secure various components inside of
missile silos, and for other purposes that require a high degree of
seal integrity. There are no known cases of fiber optic seals
having been circumvented, through either seal substitution or
tampering.
17
-------
A liber optic seal (left)
and its "fingerprint" (right).
No transfer of sludge is permitted if any seal is broken or missing,
unless broken by the approved inspector. EPA and the Coast
Guard will conduct spot checks at the loading facilities. The
Coast Guard will also spot check the vessels in the process of
transporting sludge. If any of the seals are found to be broken or
missing, or show signs of tampering, the vessel may be required
to immediately return to port, where a full investigation can be
conducted.
18
-------
EFFECTIVENESS OF
THE ODSS
Completeness of ODSS Coverage
The Coast Guard defines a "complete" printout as any printout
that shows the time, date, and coordinates of the vessel during
the dumping operation and shows draft readings from at least
one transducer. This information is sufficient to indicate position
during dumping and dumping rate. Between July 14, 1988, and
March 31 , 1 989, 475 dump missions were conducted to the 1 06-
Mile Site. The table below shows the number of dump missions
conducted during each month of the reporting period, and the
complete printouts obtained, and the percentage of complete
ODSS printouts.
NUMBER OF COMPLETE ODSS PRINTOUTS
vs. DUMP MISSIONS
MONTH
July 14-31. 1988
August 1988
September 1988
October 1988
November 1988
December 1988
January 1989
February 1989
March 1989
TOTAL
DUMP
MISSIONS
31
55
52
63
63
52
55
50
54
475
COMPLETE
PRINTOUTS
13
23
24
27
22
7
4
4
14
138
PERCENT
42
42
46
43
35
13
7
8
26
29
During this reporting period, 138 ODSS printouts were complete,
an average value of 29 percent completeness. Because of com-
ponent failures and other system engineering problems, there
were several weeks during the months of January and February
when no data were collected, resulting in a very low performance
rating for these months. The figure below shows a graphic
representation of complete printouts vs. dump missions.
-------
Number of complete ODSS
printouts vs. number of dump
missions.
Number of Dump Missions
70 ^
Dump Missions
Complete ODSS Printouts
Dec
Feb
Mar
1988
1989
EPA can also glean valuable information from some ODSS print-
outs even though the printouts are not complete. For example,
EPA can compare the amount of time a vessel remains inside the
106-Mile Site with the amount of time it would take the same
vessel to dump its sludge at the permitted discharge rate. If the
printout shows that the amount of time the vessel remained inside
the 106-Mile Site is less than the time required to dump at the
permitted rate, then the vessel must have exceeded its maximum
permitted dumping rate, dumped outside the 106-Mile Site, or
both. Therefore, even if none of the transducers are functioning,
an enforcement action may be possible.
20
-------
Violations of Ocean Dumping Permits
Violations detected by the ODSS between July 14,1988, and
March 31,1989, have been tabulated and are shown in the table
below. One dump, suspected to have occurred more than 20
nautical miles outside the site in January 1989, is currently under
investigation. Instances in which vessels strayed outside of the
site during dumping operations are also under investigation.
VIOLATIONS SHOWN ON COMPLETE PRINTOUTS
MONTH
July 1988
August 1988
September 1988
November 1988
December 1988
January 1989
February 1989
March 1989
TOTAL
SHORT
DUMPS
0
0
0
0
0
1
0
0
1
STRAYED
OUTSIDE
SITE
1
2
1
0
0
0
0
0
4
EXCEEDED
DUMPING
RATE
0
0
0
0
0
0
0
0
0
In July of 1988, EPA issued Administrative Complaints against all
three waste transporters and all nine sewerage agencies for per-
mit violations. Most of the complaints contained penalties for
exceeding the maximum allowable discharge rate prior to July
1988. The complaints were a result of EPA's examination of
Ocean Dumping Notification Forms (ODNFs). An ODNF contains
information on a vessel's start and end dump times and the
quantity of sludge dumped. Permit conditions require the master
of each vessel to submit an ODNF after each dump mission.
Since the July complaints were issued, no discharge rate viola-
tions have been detected, during the time period covered by this
report, either by an examination of the ODNFs or by examination
of complete ODSS printouts.
-------
Limitations to the ODSS
The ODSS is not effective in detecting illegal discharges of sludge
in the harbor areas or during vessel transfer (loading and unload-
ing) operations. Tall structures or bridges in the harbor area
interfere with or block line-of-sight radio transmissions, creating
"dead zones". Even when transmissions are not blocked, the
effectiveness of the system is limited during transfer operations.
The ODSS determines vessel dump status by measuring changes
in vessel draft. Before the system can accomplish this, it must
determine a maximum draft for the vessel. A maximum draft for
any given vessel can only be determined after the vessel has
been loaded and has departed port. If a vessel were to illegally
dump sludge out of its bottom discharge pipes at the same time
that it was being loaded with sludge, the ODSS would not be able
to detect a violation. In addition, vessels can hit bottom during
loading, which further impedes the determination of vessel draft
by the ODSS. Therefore, EPA will monitor all sludge transfers
through its sludge manifest and seal system, as described in this
report.
As designed, the ODSS communications link does not provide
continuous contact between the base station and the vessels.
Therefore, real-time detection of violations cannot be made.
When vessels are more than 20 nautical miles from the Coast
Guard base station located on Governors Island, New York, or 60
nautical miles from the relay station at Sandy Hook, New Jersey,
communication is lost. Data on the trackline and dump in-
formation must be stored in the vessel's black box computer until
the vessel again enters communications range on its return to
port.
To detect ocean dumping violations, EPA and the Coast Guard
use printouts that are generated after the dumping has occurred.
Initially, it was expected that the ODSS would be able to obtain
complete printouts on 80 percent of all dump missions. During
the first five months of its operation, the performance of the ODSS
averaged almost 42 percent. Overall, during the first 9 months of
operation, the ODSS obtained complete printouts on only 29
percent of the dump missions. The Coast Guard is reevaluating
the ODSS to determine possible measures to improve its perform-
ance while considering other surveillance techniques.
22
-------
77'
BASE STATION
Governors Is., NY
s
RELAY STATION
Sandy Hook, NJ
\.-'' 106-Mile Site
Area presently outside the
range of real-time coverage
ATLANTIC OCEAN
Chesapeake
Bay
71'
70°
ODSS Coverage Area. Line-of site radio transmission is possible for 20 nautical miles from the base station and for
60 nautical miles from the relay station. The communications range would have to extend to the 106-Mile Site to
provide near real-time detection.
23
-------
Shipriders
Shipriders are independent observers that remain on board the
tugboat or self-propelled vessel for the duration of the dump
mission. Until the ODSS improves, EPA will need to supplement
the system by requiring that Shipriders accompany the ocean-
going vessels. The shiprider's job is to ensure that the vessel
operators dump the sludge in the designated dump site and at
the permitted discharge rates. However, Shipriders also have
limitations. Because most barges are towed at a distance of up
to one-quarter mile behind the tugboat and some of the barges
are unmanned, the Shipriders will not be able to observe when
dumping actually starts and ends. Also the average dump time at
the 106-Mile Site at the reduced rates is 18 hours. Some vessels
will require 38 hours or more to discharge their sludge. The ship-
riders cannot be expected to remain awake for the entire dis-
charge operation. Shipriders do not replace the ODSS, they can
only complement operation of the ODSS. Cost estimates for the
services of a qualified shiprider range from $700 a day to $1200 a
day. A new permit condition requires that an EPA-approved
shiprider, supplied by the permittee, accompany each vessel that
transports sludge to the dump site.
Need for Installation of Additional ODSS Units
The two most likely reasons for requiring the installation and
fabrication of additional ODSS units are the reduced dumping
rates required under the special ocean dumping permits and the
need for surveillance of the feeder vessels. Currently, data indi-
cate that the 16 oceangoing vessels that are equipped with the
ODSS are sufficient to transport all of the sludge at the reduced
discharge rates in the special ocean dumping permits. At pre-
sent, no ODSS units are installed on the feeder vessels, nor are
there any plans to install ODSS units on these vessels, because
the ODSS is not an effective surveillance tool on feeder vessels.
EPA will monitor the feeder vessels through its sludge manifest
and seal system.
In conclusion, the installation of additional ODSS units at this time
is unnecessary. However, should unforeseen exigencies require
that additional vessels be equipped with ODSS units, the Coast
Guard could install two units on short notice if the need arises,
provided that the waste transporter arranges for expeditious dry
docking of the vessel. If there is an emergency that requires an
immediate response, EPA may, upon receipt of a written request
24
-------
from a waste transporter, authorize a vessel not equipped with an
ODSS unit to dump sewage sludge at the 106-Mile Site. EPA will
require the vessel to be accompanied by an EPA-approved
shiprider each time the vessel departs for the 106-Mile Site.
Improvements to the ODSS
Some of the problems associated with the ODSS during this re-
porting period can be attributed to normal start-up and initial
operation of the system. However, there are other problems that
are persistent and have undermined the consistency of the entire
system. In October 1989, the Coast Guard hired an independent
contractor to troubleshoot the ODSS Software. After problems in
the software are resolved, the Coast Guard will complete con-
tracting for another independent maintenance contractor who will
service the ODSS units on each of the vessels. It is anticipated
that the ODSS performance should improve once the contractor
becomes a dedicated resource not tasked with other duties, and
assumes responsibility for troubleshooting the system and devel-
oping a strict maintenance schedule.
To improve the coverage of the ODSS to include near real-time
surveillance of all or most of the operational area, two possible
options are being discussed: (1) increase the range of real-time
coverage by placing an antenna on top of the World Trade Cen-
ter, on top of the Loran Tower at Wildwood, New Jersey, or on
any structure that is substantially higher than the 180-foot com-
munications tower at the relay station; and (2) establish a satellite
link for communicating with the base station. EPA also recom-
mends improvement of the communications capability between
the Coast Guard on Governors Island and the vessel operators in
the operational area.
Antenna on the World Trade Center or Loran Tower
Because the ODSS is a line-of-site system, the quickest, most
direct, and least expensive approach for upgrading the ODSS is
to place an antenna on top of a structure that is substantially
higher than the communications tower at the relay station, such
as the World Trade Center. An antenna on top of the World Trade
Center may allow for almost complete real-time coverage of the
entire operational area. No changes to any of the ODSS remote
units would be required. The antenna, at a height of 1,130 feet,
25
-------
would take the place of the 180-foot line-of-sight (LOS) communi-
cations tower located at Sandy Hook, New Jersey. The Coast
Guard would be almost instantly alerted of a violation almost
anywhere in the operational area.
Another possible option for improving the range of the ODSS's
real-time coverage is to place an antenna on top of an existing
Loran tower. There is a 720-foot Loran tower in Wildwood, New
Jersey. Although this tower is not as tall as the World Trade
Center, it is located parallel to the 106-Mile Site and is completely
under the control of the Coast Guard.
The costs to place these antennas is estimated to be about
$16,000 for the World Trade Center and about $800 for the Loran
tower in Wildwood.
Recently, EPA was informed by the Coast Guard that revised
calculations indicate that an antenna on the World Trade Center
or on the Loran tower at Wildwood, New Jersey, might not be
effective because of background and other atmospheric inter-
ference problems. EPA is encouraging the Coast Guard to go
beyond theoretical calculations and actually install and test one
or both antennas, and also to examine other innovative ap-
proaches to increasing real-time coverage when they conduct
their reevaluation of the ODSS.
Satellite Link
The Coast Guard has been investigating the feasibility and cost of
retrofitting the present ODSS to accommodate the satellite link
GEOSTAR. A rough estimate of the cost to complete this retrofit-
ting is about $1 million. Adopting GEOSTAR would provide a
near real-time data link to the barges by eliminating the electronic
telemetry between the base station and the remote units. GEO-
STAR was selected because of its reliability and its ability to meet
data capture criteria without delays in transmission.
A satellite link would require that the Ray Nav Loran recievers that
are incorporated into the ODSS remote unit on each of the au-
thorized vessels be replaced with a satellite transceiver, which
uses an ANI 7000 Loran-C receiver. The satellite transceiver
would be able to continuously transmit to a geosynchronous sa-
tellite. Therefore, complete real-time coverage of the operational
area could be achieved. The satellite transceivers are commer-
cially available from several manufacturers. The satellite tran-
sceiver uses a spread spectrum-type transmission, which would
26
-------
minimize any possible interference. Frequencies in the 1610-
1626.5 MH band have been allocated by the FCC for these new
Radio Determination Satellite Services.
Communications Capability
Another aspect of the ODSS that needs improvement is the
communications capability of the Coast Guard base station on
Governors Island, New York. The base station is now using VHF-
FM radio communications, which only allow the Coast Guard to
communicate with the vessel operators approximately 35 nautical
miles from shore. Although theCoast Guard can communicate
with the vessel operators indirectly through their land-based
dispatchers, EPA believes that the Coast Guard should have the
ability to talk directly with the vessel operators anywhere within
the operational area. At present, the vessel operators can com-
municate with their land-based dispatchers anywhere in the
operational area via single-side band radio or by satellite commu-
nications. However, direct communications between the vessel
operators and the Coast Guard on Governors Island are limited to
those via VHF-FM radio.
27
-------
CONCLUSIONS AND
RECOMMENDATIONS
Both EPA and the Coast Guard expected the ODSS to perform
better than it has during its first 9 months of operation. Perform-
ance has been sporadic-some weeks it generated a high per-
centage of complete printouts, other weeks the percentage was
low or zero. Although the ODSS provides some deterrent effect in
that the dumpers cannot be certain whether or not it is functioning
properly, EPA is concerned that the deterrent effect of the ODSS
has been diminished by its inconsistent performance record.
Therefore, until the consistency of the ODSS improves, EPA will
require shipriders on board the vessels that are authorized to
dump sewage sludge at the 106-Mile Site. As consistency im-
proves, the shiprider requirement may be partially or completely
waived. EPA will monitor the progress of the overall system as
well as the individual performance of units on each of the 16
vessels authorized to dump sewage sludge at the 106-Mile Site.
To improve the coverage of the ODSS, EPA encourages the
Coast Guard to install and test antennas on the World Trade
Center or on the Loran tower at Wildwood, New Jersey, or on any
structure that is substantially higher than the 180-foot communi-
cations tower at the relay station. Although satellite coverage
may appear to be an attractive option, EPA is concerned that by
the time extensive modifications are completed on each of the
ODSS units and the system is thoroughly tested and debugged,
ocean dumping of sewage sludge will have ended. On the other
hand, the antenna approach can be quickly implemented and
should greatly enhance coverage.
Anyone who has watched the performance of the ODSS during
the past months will be impressed by the fact that the ODSS unit
on the Sea Trader I, the largest vessel in the fleet, is capable of
communicating with the base station up to 80 nautical miles from
the relay station. The other 15 vessels in the fleet are only ca-
pable of communicating with the base station up to 60 nautical
miles from the relay station at Sandy Hook, New Jersey. The
reason for this difference is that the communications antenna on
the Sea Trader I is approximately 10 to 20 feet higher than the
antennas on the other vessels. The ODSS is a line-of-sight
system. Therefore, increasing the height of the land-based
antenna and/or the antenna on board the vessel could increase
the range of coverage.
28
-------
The Sea Trader I
Now that the sludge manifest and seal system is a permit con-
dition of the special ocean dumping permits, EPA and the Coast
Guard will work together to ensure that this system protects the
harbor, estuarine, and shore areas in New York and New Jersey
from any potential illegal dumping by the feeder or oceangoing
vessels. This system, backed by Coast Guard spot checks of the
vessels while they are transporting sludge and by EPA and Coast
Guard spot checks at the loading facilities, is expected to deter
any violators.
EPA and the Coast Guard are confident that by employing the
ODSS, the sludge manifest and seal system, and shipriders to
complement operation of the ODSS, cradle-to-grave monitoring of
sewage sludge from its point of origin to its ultimate disposal at
the 106-Mile Site will be achieved.
2:-
-------
GLOSSARY AND
ACRONYMS
106-Mile Site
At Sea
Bad Dump
Black Box
Complete ODSS Printout
Docked
DMSDS
Dumping
Feeder Vessel/Shallow
Draft Vessel
FCC
(Also known as DMSDS) 106-Mile Deepwater Municipal Sludge
Dump Site.
A vessel is considered at sea when it is not in port, but in the area
of the outer New York Harbor, Long Island Sound or the Atlantic
Ocean.
(Also known as Short Dump) Any dump that is outside the
designated dumpsite.
(Also known as the electronics package or remote unit) The
ODSS (see below) component installed on each dumping vessel
that houses a Loran-C receiver, clock, circuitry, and communica-
tions package in a tamper-resistant box.
A printout that shows the time, date, and coordinates of the
vessel, and draft readings from at least one transducer during a
dumping operation.
A vessel is considered docked if it is in port and has not moved
for three polling periods. When in port, each polling period is
20 minutes.
(Also known as the 106-Mile Site) 106-Mile Deepwater Municipal
Sludge Dump Site.
A vessel is considered dumping when its draft decreases by a
specified amount below the maximum draft and triggers the
ODSS.
Any vessel used to transfer sludge from one location (or vessel)
to another, primarily within the New York/New Jersey Harbors.
Federal Communications Commission.
Geosynchronous Satellite A satellite that travels at an altitude of at least 35,000 kilometers,
and at a speed matching that of the earth's rotation, thereby
maintaining a constant relation to points on the earth.
In Port
A vessel is considered to be in port when it is within the area
roughly encompassing the New York Harbor north of the Ver-
razano Narrows Bridge plus the west side of Staten Island and
Rockaway inlet.
30
-------
Line-of-Sight
Transmissions
Long-Range Hyperbolic
Radio Navigation System
(Loran C)
Loran Receiver
MPRSA
Nautical Mile
NOAA
Oceangoing Vessel
ODBA
ODNF
ODSS
ODSS Unit
Real-Time Detection
Resource-Year
Shipriders
Short Ton
Single Side Band Radio
Vessel Draft
VHF-FM Radio
Radio transmissions that can only be made if the transmitting
and the receiving antennas are within sight of each other.
A land-based navigation system, operated by the Coast Guard,
which transmits radio signals to vessels. Any vessels equipped
with a Loran receiver can determine its location within 50 meters.
A receiver that receives signals from the Loran-C, interprets the
signals, and visually displays the latitude and longitude of the
vessel.
Marine Protection, Research, and Sanctuaries Act of 1972.
One nautical mile equals 6,076 feet or 1.15 statute miles.
National Oceanic and Atmospheric Administration.
Any vessel that is authorized to dispose of sludge at the 106-Mile
Site.
Ocean Dumping Ban Act.
Ocean Dumping Notification Form.
Ocean Dumping Surveillance System. The entire ODSS includes
the base station, the relay station, and the vessel installation.
All ODSS equipment installed on a vessel-the "black box,"
transducers, connecting circuitry, communications equipment,
and Loran antenna.
The ability to detect dumping violations as they occur.
The amount of work a person can be expected to perform in one
year. One resource year equals 48 weeks x 40 hours/week or
1,920 hours/year.
Independent observers who remain on board the towing vessel or
the oceangoing vessel for the duration of the dump mission.
2000 pounds, as opposed to a long ton, which is 2240 pounds.
High frequency radio transmissions that are not limited to line-of-
site range, but can be sent and received over great distances.
Depth of a vessel between the water line and the deepest point of
the hull.
Radio transmissions that are limited to line-of-sight range.
31
-------
APPENDIX A
Vessels Authorized to Dump Sludge
Authorized Vessels
Sea Trader 1
Eileen
Weeks 702
Lemon Creek
Spring Creek
Tibbets Brook
Udalls Cove
Morris J. Berman
Princess B1
Kimberly Ann
Lisa
Maria
Weeks 701
Leo Frank
OBI IV 2
Sotoco // 2
TOTAL
Capacity (Wet Tons)
38,000
1 8,000
1 7,800
1 5,000
1 5,000
1 5,000
1 5,000
12,000
12,000
8,000
8,000
7,900
6,400
5,500
1,000
1,000
196,100
1 Princess B sank on or about October 6, 1989, inside or near the 106-Mile
Site.
2 Authorization for these vessels to dump sewage sludge at the DMSDS was
abrogated on August 14, 1989, at the request of the waste transporter.
32
-------
Permittees Authorized to Dump Sludge
Permittees
Wet Tons per Month *
New York City Dept. of
Environmental Protection
Passaic Valley Sewerage
Commissioners
Middlesex County Utilities
Authority
Nassau County Dept. of
Public Works
Westchester County Dept. of
Environmental Facilities
Bergen County Utilities
Authority
Joint Meeting of Essex and
Union Authority
Rahway Valley Sewerage
Authority
Linden Roselle Sewerage
Authority
TOTAL
379,891
116,667
83,417
76,650
42,803
35,833
33,367
14,097
8,342
791,067
* Projected sewage sludge quantities for 1991.
33
-------
APPENDIX B
ODSS Printout
OCLAN DUMPING SURVL1LLANCE SYSftM VE5!iLL HISTORY
VESSEL NORTH RIVER
VESSEL ID 145
Ktr UK 1 tl/-'
1 DATE
20 DEC
20 DEC
20 DEC
20 DEC
20 DEC
20 DEC
20 DEC
20 DEC
20 DEC
20 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
19 DEC
8S
3 j
85
BS
BS
BS
8"
BS
85
BS
Hr.
85
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B!
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B -
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85
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BS
85
85
85
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BS
85
BS
8S
BS
B\
BS
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85
85
BS
BOX
TIME
1340
: 1338
1240
1140
1040
0940
0920
0900
0840
0834
2241
2141
2121
2059
2019
1939
1919
1859
1839
1819
1759
1739
1719
1659
16S7
1655
1653
1651
: 1651
1649
1647
1645
1643
1641
1627
.1625
1607
1545
1525
1505
1445
1345
1245
1145
' 1131
1043
0943
0843
0823
0803
STATUS
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LATITUDE
40
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40
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41
40
40
40
40
40
40
..• D
40
* -
0
so
40
4g
40
•>•
^i-
41
40
40
41
40
41
40
40
40
40
40
At,
4n
<0
40
40
4C
40
40
40
« ]
* )
40
40
* }
40
40
40
40
t
31
.5!
30
38
38
39
38
38
42
47
47
47
47
47
0
45
41
37
34
31
29
27
24
23
23
23
23
23
23
23
24
24
24
24
26
26
28
30
34
38
38
38
38
38
38
38
38
38
38
38
61N
.87N
72N
.71N
.72N
72N
.72N
71N
31N
33N
3SN
37N
35N
34N
DON
12N
84N
28N
05N
06N
39N
21N
78N
39N
52N
63N
74N
85N
B5N
97N
17N
82N
87N
97N
24N
52N
95N
08N
S7N
23N
32N
30N
30N
30N
30N
30N
30N
30N
30N
30N
«LORAN
LONGITUDE
74 0
74 0
74 1
74 1
74 1
74 1
74 1
74 1
73 59
73 54
73 54
73 54
73 54
73 54
0 0
73 57
74 0
74 2
74 1
73 58
73 54
73 49
73 44
73 42
73 42
73 42
73 42
73 43
73 43
73 43
73 43
73 44
73 44
73 44
73 46
73 47
73 51
73 53
73 52
73 51
73 51
73 51
73 51
73 51
73 51
73 Si
73 51
73 51
73 51
73 51
DOWN
. 26U
69U
88U
87W
B8W
88W
BBU
92U
67U
99U
99U
97U
98U
99W
OOU
56U
03U
54U
43W
70U
13U
47W
78U
59U
57U
71U
90U
09U
09U
27W
82U
12U
27U
87U
68U
16U
34U
24U
62U
97U
89U
77U
77W
77W
77U
77U
77U
77U
77W
77U
— l»K<
FUD
13 7
13 7
137
12.8
12 8
88
66
66
6 6
6.9
15.8
15.4
13 3
11 8
64
6.2
6.4
64
66
6 6
66
66
69
6 9
6.9
6.9
6.9
6.9
69
8.7
10.6
14.7
15.9
16.3
16 3
16 1
15 2
15 0
15 0
15.0
15.2
14.3
11 1
10 9
92
84
8. 1
6.4
6.4
6 4
MID
14 6
146
14 1
13 3
13 1
9. 0
8.1
8 1
8 6
B 1
15 2
14.8
13.3
11 3
7.9
8.
8.
8.
8
8
8
8
B 1
79
7.9
7.9
79
79
7.9
89
98
11.3
13 9
15 6
15 6
156
15.2
152
15.0
15.0
15. 0
13 V
11 1
10.9
9.9
9.2
9.0
7.9
79
7.9
- <
AFT
14 8
14 8
148
13 7
13 3
9 0
90
9 0
88
88
15.4
14 8
13 7
11 3
B 8
86
86
86
86
8 8
86
86
86
86
86
86
8.6
86
86
92
9.6
10 1
12 6
15 2
15 2
15.2
15 2
15 0
15 0
15 2
15 2
14 1
11. 1
10 9
10 1
V.6
96
86
86
86
B« 1 1
VOLT
12 1
12 1
12 1
12.2
12 1
12. 0
12.0
12 0
12. 0
12 0
12. 1
12. 0
12.0
12 0
12 0
12. 0
12 0
12.0
12 0
12. 0
12. 0
12 0
12 0
12 0
12. 0
12.0
12 0
12. 0
12.0
12. 0
12 0
12. 0
12 0
12.0
12.0
12. 0
12.0
12 0
12 0
12 0
12.0
12 0
12 0
12. 0
120
12.0
12.0
12.0
12 1
12 1
•WRONG DOCK XINTRUSION
•-b 1 « IUb
— 1
VESSEL HOX
AT SEA
AT SEA
DOCKED
DOCKED
DOCKED
DOCKED
INPORT
INPORT
INPORT
INPORT
INACTIVE
DOCKED
INPORT
INPORT
NO LORAN
INPORT
INPORT
INPORT
AT SEA
AT SEA
AT SEA
AT SEA
AT StA
AT SEA
AT SEA
»>T SEA
AT SLA
AT SEA
AT SEA
DUMPING
DUMPING
DUMPING
DUMPING
AT SEA
AT SEA
AT SEA
AT SEA
AT SEA
INPORT
INPORT
INPORT
DOCKED
DOCKED
DOCKED
DOCKED
DOCKED
DOCKED
DOCKED
INPORT
INPORT
8AC POWER
c k
III
at
Ok
g i
Ok
Ok
Ik
ok
ok
1
ok
Ok
*
0.
r .
0 »
c k
a •-
ok
1.
Ok
Bk
ok
• If
ok
ik
ok
• k
0.
ok
ok
ok
»t
0.
»l
r> .
ok
ok
ok
ok
ok
X
Ok
Ok
ok
ok
ok
LOST
MSN
1 1
25
2S
2!
-23
-23
-23
-23
-23
-23
-23
-23
-23
-23
23
-23
-23
-23
-23
23
Z l
23
Z '•
23
Z i
Z '
22
23
23
23
23
23
23
23
23
23
23
23
-22
-22
-22
-22
-22
-22
-22
-22
-22
-22
34
------- |