The Marine Environment
-------
Coming up empty. Lobstermen on the East Coast are reporting slimmer harvests this year. Fritz Hansen, who traps between the Statue of
Liberty and the Verrazano-Narrows Bridge in New York Harbor, reports "the worst season in 15 years." It is another puzzle in the growing
concern about how seriously marine waters are polluted. Keith Meyers photo. NYT Pictures.
The Marine
Environment
Arc the oceans poll uled?
Or .in1 American (.oasis
receiving warning signs that
they could become so'.' This
issue oi I'll'A journal focuses
on those very current
concerns.
In an interview. KPA's
Deputy Administrator. A.
lames Barnes, leads oft the
issue, answering questions
tin! public is asking. Then a
point/counterpoint tea lure;
addresses the intense debate
about dumping municipal
sewage sludge at sea. \Ve
hear from Mayor Kdwanl I.
Koch ol X'ew York Citv,
Governor Thomas Kean ol
New Jersey, and Mike
Brinker of (lie Joint Meeting,
a group of northern New
Jersey agencies.
Christopher Daggett,
Administrator of EPA Region
2. explains the Agency's
detective work last summer
to pinpoint the origin ol
mysterious wastes washing
up on the beaches in the
New York Harbor area and
the New Jersey coast. U.S.
Senator John 11. Chalee (K-Kl)
reports on what Congress is
learning in its inquiries into
ocean pollution and the
legislators' thoughts about
solutions.
In a journal Forum, six
close observers of the marine
environment present dherse
views on the question.
"Should the oceans receive
special protection?"
Then, an article reviews
the action and upcoming
challenges on the global
marine protection front, in
the United States again,
Michael R. Iceland, HP A
Region 1 Administrator,
focuses on one ot the oast
coast's most significant and
hard-fought water quality
situations, the cleanup of
Boston Harbor. Shifting to
the west const, a piece
describes the choices and
tradeoffs that northwestern
Orange County, California,
faces as it grapples with
ocean protection questions.
Next, we present a tale
about disappearing coho
salmon in a Washington state
river system, probe the
underwater feats of EPA
divers, and explain a
controversial marine
opportunity—converting old
offshore rigs to reels for
ocean life. An additional
water-oriented article tells
about the problem of air
pollutants tainting the Great
Lakes.
On another subject, an
article ponders a dilemma oi
modern-day environmental
health.
This issue concludes with
a regular feature—
Appointments, c.
-------
United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 14
Number 5
June 1988
&EPA JOURNAL
Lee M. Thomas, Administrator
Jennifer Joy Wilson, Assistant Administrator for External Affairs
R. Augustus (Gus) Edwards, Acting Director, Office of Public Affairs
John Heritage, Editor
Karen Flagstad, Assistant Editor
Jack Lewis, Assistant Editor
Ruth Barker, Assistant Editor
Marilyn Rogers, Circulation Manager
EPA is charged by Congress to
protect the nation's land, air, and
water systems. Under a mandate of
national environmental laws, the
agency strives to formulate and
implement actions which lead to a
compatible balance between
human activities and the ability of
natural systems to support and
nurture life.
The EPA journal is published by
the U.S. Environmental Protection
Agency. The Administrator of EPA
has determined that the
publication of this periodical is
necessary in the transaction of the
public business required by law of
this agency. Use of funds for
printing this periodical has been
approved by the Director of the
Office of Management and Budget.
Views expressed by authors do not
necessarily reflect EPA policy.
Contributions and inquiries should
be addressed to the Editor (A-107),
Waterside Mall, 401 M St., S.W..
Washington, DC 20460. No
permission necessary to reproduce
contents except copyrighted photos
and other materials.
The Offshore Environment:
What People Are Asking
An Interview with
A. James Barnes 3
Should Sewage Sludge
Be Dumped at Sea?
A Point/Counterpoint 8
Whodunit?
by Christopher Daggett
11
What Congress
Is Learning
by John H. Chafee
14
Special Protection for the
Oceans? A Forum 17
Steps Toward
a Global Oceans View
by Alan Sielen 21
Boston Harbor:
No Party After the Tea Party
by Michael R. Deland 24
Tough Choices Ahead
for a West Coast Discharger
by Corinne Clawson 27
Where Did
Those Salmon Go?
by Matthew Coco 29
EPA Divers:
Getting Down to the Nitty
Gritty
by Roy Popkin 32
What to Do
With Those Old Oil Rigs
by Clay Fulghum 35
Air Toxics:
A Headache for the Great
Lakes
by Jane Elder 37
On Another Subject:
To Eat or Not to Eat
by Carole Sugarnian
Appointments 40
39
Correction: In an article fifJed
"Problems on (he Urban Frontier"
in (he las! issue of EPA Journal,
the author re/erred lo a favorable
oulcome of a groivlh management
referendum in Orange County, CA.
In fact, the referendum was
narrowly defeated.
Correction: In (he last issue of the
Journal, joint authors Ann Breen
and Dick Rigby ivere incompletely
identified. They are the
co-directors of The Waterfront
Center, a non-pro/it membership
group based in Washington, D.C.
Editor's note: The next issue of
EPA Journal will be on
Environmental Elhics and
Education.
The annual rate for subscribers in
the U.S. for the EPA Journal is
$11.00. The charge to subscribers
in foreign countries is Si 3.75 a
year. The price of a single copy of
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handled only by the U.S.
Government Printing Office.
Anyone wishing to subscribe to the
EPA Journal should fill in the form
at right and enclose a check or
money order payable to the
Superintendent of Documents. The
requests should be mailed to:
Superintendent of Documents,
GPO, Washington, DC 20402.
Front Cover: Why we came'. Surf
fishing at Cape May, New jersey.
Photo by Bill Weems. Wood/in '
Camp, Inc.
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It is the sea that holds the groat
mysteries. There is still much to be
learned in the land, to be sure, but it is
the third dimension of the oceans that
hides the answers to broad elemental
problems of natural history. Somewhere
out there young salmon lose themselves,
and the Pribilof seals go there when
they leave the rocks where they were
born. Through chance concordance of
cryptic forces, the Red Tide brews up
and sporadically drifts in to the rich
littoral of Florida, killing thousands of
fish, sending the tourists scurrying to
flee the stink, and then sweeping away
again, unchecked and uncomprehended.
As long as man has had the wit to
wonder, he must have puzzle-id over the
new eels in his pasture pond; and being
told they come from the sea where their
parents went to spawn them is as
preposterous as some theory of
astrophysics. When J.L.B. Smith found a
coelacanth fish... it was a living fossil.
as stirring a discovery to a biologist, and
quite as great a probing of the past, as
finding a dinosaur would be. Who can
trace the way of the great blue marlin or
of Rhineodon, the whale shark, or tell
anything worth hearing about the
oarfish or the giant squid, or even say
for sure where the homely mullet
spawns its million or where the
gleaming hordes of tarpon come
from? D
(Excerpted from Archie Carr, "The
RiddJe of the RidJey." From John
Kieran's Treasury of Great Nature
Writing (New York: DoubJeday 6- Co.,
1957.) Copyright 1955 by the author in
Windward Road; reprinted by
permission of Alfred A. Knopf, Inc..
New York.)
••
Steve Delaney photo.
EPA JOURNAL
-------
The Offshore Environment:
What People Are Asking
An Interview with
A. James Barnes
Marine pollution is one of the mast
hotly debated environmental issues. To
get answers to questions the public is
asking about this problem, EPA Journal
interviewed A. James Barnes. Deputy
Administrator of EPA. The text of the
interview follows:
\J. Recently, we've seen a number of
disturbing news reports about pollution
of our coastal waters. Are our oceans
truly becoming polluted?
A Yes. Over the last few years we've
seen indications that our near-coastal
waters, in particular, are under a great
deal of stress from the waste products
that result from population and
economic growth.
vJ What are the stress factors? What
is putting pressure on coastal waters?
r\ Some of the .stresses being felt in
estuaries and near-coastal waters
originate far inland. Run-off from our
farms and cities makes its way
downriver and ends up in the estuaries
and near-coastal waters, which act as
sinks for nutrients and toxic materials.
There is also pressure from
population growth and related economic
activity. Because, more, and more of our
people are moving into coastal areas, we
are filling in wetlands for housing and
roads. We're building sewage treatment
plants, the nutrients from which build
up in local estuaries. Even if we do a
good job treating sewage and waste
streams, the total loadings of nutrients
and toxics are going to increase because
of growth.
Q
A question that might come
naturally to a person sitting on the
beach and looking at this massive body
of ocean water: could human pollution
ever have any impact on this
tremendous resource?
r\ I think the answer is yes. Most of
uur globe is covered with water, that's
true. It would seem to have a very
substantial capacity to assimilate human
waste.
But 1 think that view is very-
short-sighted. We're increasingly
concerned about the ocean's
micro-layer, where the small organisms
at the start of the food chain exist. We
should be cautious about doing
anything that would interfere with the
vital role of that micro-layer in the food
chain.
Rather than looking at the ocean as a
gigantic new receptacle for our waste, I
believe we'd be much better advised to
significantly reduce the amount of waste
we produce in our everyday lives. We
need to minimize the waste burden,
whether it's in the air. on the land, or in
ocean waters.
Li What would you rank as the most
serious threat to the ocean
environment now? Would it be debris,
sewage, radioactive material, industrial
waste, or what?
r\ That is going to vary from area to
area. In some places it's the nutrients
that deprive a body of water of oxygen.
In other plac.es. toxics are probably the
more significant problem.
The issue of debris—such as showed
up on the New Jersey beaches last
summer, and on Long Island this
summer—is more an aesthetic problem.
It is of concern—great concern—because
it interferes with our enjoyment of the
beach. But I'm not sure that debris is
really the most serious threat to the
viability of that sensitive ecosystem that
exists along the coast.
I'm more concerned about the toxics
and nutrients that are finding their way
into these waters. And the loss of
habitat that results from filling wetlands
JUNE 1988
-------
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EPA JOURNAL
-------
Summer, 1940: Coney Island,
an example of a cherished
American tradition—spending
the ctay at the beach. AP Wide
World photo.
Summer, 1988: Gregory Garre, a
lifeguard for the town of Babylon
on Long Island, spends a lonely
day cleaning up Cedar Beach.
Medical-type wastes and
garbage slicks have closed some
New York and northern New
Jersey beaches off and on this
summer and last. APWide World
photo.
and diverting waterflows in those
sensitive areas. After all, the wetlands
and estuaries are the breeding grounds
for all kinds of fish and wildlife that
ultimately make their way to the ocean
or farther inland.
C-l You're talking about the dredging
and filling of habitat. As a result of
that — together with pollution — an: we
seeing a decline in fish reproductivity?
r\ Apparently yes. Look at the
number of shellfish beds that have been
closed for public health reasons. Look at
the areas where commercial fishing is
decreasing — changing a way of
life — because species that once wore
abundant no longer can support
commercial fishing.
L2 Should we also be concerned
about dumping waste at sea, say 100
miles out?
r\ Studies have indicated effects of
dumping at the previous site 12 miles
off-shore. FFA is investigating potential
impacts at the. interim. 1 (Hi-mile site.
Our goal is an end to ail dumping of
sewage sludge off-shore as soon as
possible.
(._) An environmental group recently
reported that acid rain is speeding the
growth of marine algae, which can be a
water pollutant. What's EPA's reaction
to that?
f\ While air deposition may indeed
be a source of some nutrients, there are
other, even more significant sources of
nutrients in many water
bodies— specifically, sewage treatment
effluent and run-off from cities and
farms. Fven so, we do want to lake a
look at the data in that study and see to
what extent acid deposition contributes
to algae bloom.
Q
Is the greenhouse effect—climate
warming—having an effect on sea
level? How concerned is EPA about the
possibility of a rising sea level?
r\ Certainly this is a problem that
warrants serious attention in this
country and around the world. It's a
particular locus of concern tor KPA.
At this point there an; still a number
of questions we have to answer. How
much of a rise in the sea level can be
attributed to she so-called greenhouse
effect? How much is part ol what seems
to be a natural cycle of warming and
cooling that's taken place on the earth
many times over millions of years.
U. How concerned should people be
about off-shore oil drilling? Is that a
threat to the ocean environment?
f\ Off-shore oil drilling, like a
number of other human activities that
might take place in that environment.
warrants our close attention. We need to
determine in advance of drilling what
the potential effects might be, then look
at ways we might minimize or mitigate
those effects. Finally we need to balance
those effects against what we stand to
gain from drilling.
We've learned a lot over the last few
years about ways to minimi/e the
adverse impacts of off-shore oil drilling
on the environment. Some coastal areas
are more sensitive environmentally
and ecologically — to drilling than
others. Often it is possible to drill in a
less sensitive area and achieve the same
economic result.
Q
Does EPA have adequate authority
to address the problems we are talking
about, or do you believe we need
additional authority?
A
Fur most of tin- problems we've
been discussing, there's adequate
authority UM the books. At the same
time. I believe the American people are
going to have to think about making
some adjustments in their lifestyles, For
example, do \ve really need to generate
all the waste that ends up burdening the
environment?
Also, we must be careful that, in our
eagerness to live near the sea, we do not
destroy some of the very values th.it
attract us there in the first place. For
example, wo need to refrain Irom
building in ecologically sensitive areas
along the roast.
\Ve have laws that control the release
ol toxic materials into surlace waters, or
emissions into the air. which mav
ultimately fall to earth and pose a
problem in the marine environment.
When the Agency was looking at the
question of incineration off-shore, the
potential impact of incinerator
emissions on the micro-layer was one ol
our concerns. So the laws on the books
that are aimed at protecting a number (it
different media could ultimately be
used to protect tin; oceans.
At this point. I don't have a sense that
we need a lot more legal authority. We
JUNE 1988
-------
need to have a better scientific
understanding of what's happening in
the environment. We also need to do a
better job, perhaps, of targeting and
using the legal authorities we do have.
At the same time we need to induce
changes in people's behavior-
encourage self-restraint — so that we
minimize the adverse impacts that
population growth and economic
activity have' on coastal and other
ecologically sensitive areas.
v-t
You are calling for reducing waste
at the source, and recycling?
A\ Yes. That is a theme that I'd really
like to emphasize. There was a point
several hundred years ago when there
were so few people and such limited
economic activity that the air, water,
and land around us could assimilate our
waste.
But as our population has grown, as
our economic activity has grown, we're
finding that even if we do a relatively
good job of controlling our pollutants in
the traditional sense, the total loadings
of different pollutants from all sources
are placing a heavy burden on the
environment.
So, as a nation, we really have to
work to minimize waste products, and
then see whether some of those waste
products we do produce can be recycled
or reused. We must stop thinking about
waste disposal as a linear process where
we make something, use it, and then
throw it away. Instead, we need to view
waste disposal as part of a more circular
process where we make something, use
it, then look for a way to reuse it and
minimize how much of either that
product, or the packaging, or associated
waste materials ultimately have to
become a burden on the environment.
And that's central to our concern
about the oceans. It is also important
when we're talking about trying to
improve air quality in this country, or
the quality of our surface waters, or our
ground waters.
\JL
Of course EPA faces a wide range
of problems — from pesticide residues
on land, to contaminated ground water,
to toxic air pollutants. Where would
you rank marine pollution on the scale
of comparative risk from environmental
problems?
/A Well. I certainly would rank
estuarine and near-coastal waters
pollution up near the top of the list. It
may not be number one. but it's in the
top three or four. In part, that's because
these areas are really the base of the
whole ecological system that we depend
upon for much of our .sustenance.
Many of the problems facing marine
areas are related to the ecological
well-being of the country as a whole.
Some other environmental problems
may rank higher in terms of risk to
human health, because people are being
exposed to them by breathing the air, or
drinking water, or being exposed, say, to
pesticides.
But when we are talking about the
ecological dimension, which is very
important, then marine issues have to
be ranked very high.
\-L In this issue of the magazine, we
include a forum in which we have
asked a variety of ocean observers and
specialists whether the oceans should
receive special environmental
protection as compared to the air or the
land. How would you answer that
question?
r\ We are going to protect the ocean.
We're going to generate some waste, but
I'd like to see us confine it to limited
areas of the land, and not put the ocean
resource at risk.
Q
What do you sense about the pace
of the nation's efforts to protect the
marine environment? Are we moving
fast enough now? Do we need to move
faster?
r\ Well, I'm torn on that question. On
the one hand, we've been very pleased
at the response we've seen in a number
of areas around the country—the Great
Lakes, the Chesapeake Bay program, and
some of the other estuary programs, in
which local and state concerns are
unified and groups are pulling together
to protect these resources.
At the same time, one can't help
being conscious, again, of the massive
movement of the population in this
country to the coastal areas, to the
increased construction and economic
activity that's taking place all along our
coasts and is just bound to accelerate
the stresses we're placing on these very
significant and special areas.
We're not yet near the point where we
can feel comfortable about the success
of our efforts to protect coastal lands.
Q
r\ I think there's an essential role for
individuals, whether they live far inland
or closer to the oceans. Basically, all of
us must try to be more conscious of
what happens to the waste products of
our everyday activity as they leave our
property.
Even if you're living 50 or 500 miles
from an estuary or coastal waters, the
pesticides you spray on your lawn or
the fertilizers you spread on your farm
can be washed off and find their way
into a river—or into a sewer system and
then into a river—and can then have a
significant impact on coastal areas far
downstream.
Then, when you go to the shore for
summer vacation, you find there aren't
any lobsters because the oxygen has
been depleted by nutrients and other
waste that flows into the coastal waters,
you have to realize that you are part of
the problem.
So there are a number of things for
individuals to think about, and a
number of ways to act. We all are going
to have to do a little more, individually
and collectively, to protect the oceans.
Q
Do you think people really
understand that their actions can have
a significant impact?
r\ Some people, yes. Do the bulk of
the people reach that conclusion'.1* I
doubt it.
Q
What role can individuals play in
protecting the coastal and marine
environment?
How does the world
community—international action—fit
into this picture?
r\ Well, the world community is
going to be increasingly significant
when it comes to a global commons like
the ocean, in which all people have an
interest.
At a number of international
meetings, I've been struck by just how
intense the feelings are of many
government leaders—particularly those
of island nations—about the overall
health of the oceans. They see the
oceans as belonging to all the people on
this earth, and not the province of those
who happen to be living in highly
industrialized or developed countries,
and who may be eyeing the ocean as an
easy way to get rid of their waste.
I think we're going to see increased
pressure and concern from a variety of
international organizations to try to
protect the oceans. They believe that
EPA JOURNAL
-------
people who create waste and benefit
economically from actions that create
waste should be the ones that carry the
burden.
U. Over the long run, do you think
any waste can be safely disposed of at
sea, near shore, or even in deep water?
r\ Yes, some waste probably could be
safely disposed of at sea, particularly in
the deep sea. But that shouldn't be too
unqualified a "yes" because the
ramifications of using the sea as a
significant depository of waste are really
not well understood vet. They must be
understood before we act, or we could
find ourselves in trouble, discovering
after the fact we've created problems
that are working their way up through
the food chain. A problem of that sort
could be very difficult to reverse.
\J. How would you describe the slate
of our knowledge about the ocean
environment and the severity of the
threat to it?
r\ We don't have perfect knowledge
about any area of the environment or
EPA's ship. Peter W. Anderson,
currently located in the
Chesapeake Bay, does marine
research and monitoring.
From a dinghy, crew member
Robert Orme checks a buoy
which radios data on water
temperature, salinity, and
dissolved oxygen back to the
EPA liaison office in Annapolis,
Maryland. Steve Delaney photo.
the ecological chain, but the amount of
information we have about the ocean
environment is less than our knowledge.
say, of inland waterways and lakes.
That should make us cautious about
moving into the ocean environment for
waste disposal until we gain a better
sense of the possible effects of what
we're doing there.
Q
Would you single out any
particular areas as needing EPA
research attention?
r\ The Administrator has asked our
scientists to focus hard on wetland and
estuarine areas because we have seen so
much incremental damage there. We
need a better scientific understanding of
the limits—the tolerance—these regions
possess. We also need to learn whether
we can restore some of the areas
previously damaged or endangered.
LJ. There is a lot of coverage of
marine environmental problems in the
media. Do you believe the public is
well-informed?
r\ I think public sensitivity to marine
problems has increased lately. As 1
travel around the country and speak to
different groups, I find that the level of
concern is significantly higher than it
was, say, a few years ago.
Note: As EPA journal went to press, Mr.
Barnes announced (hat he luis at.rcpdul
a position as Dean of the School of
Public (iiuJ Environmental Affairs a<
Indiana University. Dr. John A. Moon:
will serve us Acting Deputy
Administrator (see Appointments in (bis
issue).
JUNE 1988
-------
Should Sewage Sludge Be
Dumped at Sea?
A Point/Counterpoint
Sewage .sludge is treated human waste
and other sewage produced in the form
of a semi-solid residue from waste
treatment processes. Despite a
widespread public perception (hut
ocean dumping of sludge pollutes the
sea and damages marine resources,
there is still an active debate on
whether such ocean disposal is in fact
detrimental to the marine environment
and whether other sludge disposal
methods are generally more ru:ceptubJr:.
In J977, Congress voted to end all
ocean dumping by If)81 through
amendments to the Marine Protection.
Research, and Sanctuaries Act
(commonly known as the Ocean
Dumping ActJ. That Jaw was, however,
successfully challenged in court by New
York City in 1981. The court ruled that
ocean dumping of sewage sludge might
continue beyond 1981 unless EPA
determined, on a case-by-case basis,
that dumping would unreasonably
degrade the marine environment. As a
result, a total of nine sewer agencies in
New York City, Westchester and Nassau
Counties in New York State, and New-
Jersey are still dumping their sewage
sludge in the ocean at a dump site 106
miles east of Cape May, New Jersey.
Some politicians and
environmentalists have demanded a
total ban on using the ocean as a sludge
dumping ground. Others believe that
ocean disposal is both safe and
environmentally sound. They further
argue that disposal of sludge in the
ocean is the best method available to
places like New York City, given the
volume it has to handle and the lack of
landfill spaces and other alternatives.
Recently, New Jersey ordered an end
to all ocean dumping of sludge by 1991,
and the formulation of alternative
land-based sludge management plans is
now a high priority. Meanwhile, EPA is
considering ocean dumping permit
applications from the nine sewer
agencies and is negotiating phase-out
schedules with these authorities. Also.
Congress is considering further legislation.
In light of the controversy, EPA
Journal asked Mayor Koch of New York
City, Governor Kean of New Jersey, and
Mike Brinker. Executive Director of Joint
Meeting, a group of northern New Jersey
agencies, to respond to the question:
Should sewage sludge be dumped in the
ocean? Their comments follow:
Mayor Edward I. Koch
Sewage sludge is a normal product of
daily life. Government does not
create sludge, but government has been
given responsibility for ensuring its safe
disposal. On a strictly scientific: basis.
sludge disposal in the ocean is the best.
most environmentally sound method
now available to New York City. Over
time, it has been proven safe and
reliable. Yet, despite this, arguments are
repeatedly put forward in opposition to
the discharge of sludge in the ocean.
Then; are only three ways to dispose
of sludge. It can be burned, spread on
land, or placed in the ocean. The first
two options are particularly difficult for
New York City. The city's air quality
already falls short of federal standards,
and we are working to meet those
standards as soon as humanly possible.
Emissions from burning sludge would
lead to the further deterioration of the
city's air quality, which is unacceptable.
Placing our sludge on land would cause
enormous problems because there is
practically no land available on which
to spread it.
Contrary to a widely held view, ocean
disposal (if sludge plays no role in the
fouling of coastal areas. Sewage sludge
contains neither garbage nor other
materials that could float onto a beach.
Sludge and garbage arc. two completely
separate products of modern life. Sludge
is 97 percent water. The remaining three
percent consists of tiny particles of
solids in suspension. As sludge is
released into the sea, it disperses
quickly, becoming invisible to the eye
and undetectable by laboratory analysis
Ocean disposal does not harm aquatic
life. New York's sludge has been singled
out by special interests—including the
fishing lobby—as being toxic. This is
just not true. In fact, the solids in our
sludge consist primarily of organic:
materials, with a lower proportion of
industrial pollutants than the sludge
produced by many other cities. Under
the city's pretreatment program,
increased amounts of industrial
pollutants have been removed from
sludge over the past two years.
For 50 years, the city has disposed of
sludge in the Atlantic ocean without
incident. Ocean disposal does not
deplete oxygen levels that are needed to
sustain marine life. Neither does it
introduce toxic concentration of heavy
metals or other pollutants into the
ocean. Laboratory tests have established
that the city's sludge is harmless when
diluted by seawater.
Yet accusations against the city
persist, especially when there is some
need to explain an environmental
mishap, and Now York looms as a big
target. Just recently a respected national
newspaper erroneously reported that the
city's sludge had harmed lobster beds
on the Continental shelf. The article had
no byline, and the source for this
allegation was unsubstantiated. 11 turns
out that those lobster beds are 70 miles
up-current from the city's disposal site,
so ocean currents actually carry sludge
cnvcjy from them.
New York City has never claimed
financial hardship as an excuse to
continue ocean disposal. The city has
been required to prove—and we did
prove through a scientific study—that
ocean disposal is the most
environmentally sound method now
available.
Smaller cities can farm out their
sludge for outside disposal. New York's
Mayor Edward I. Koch
EPA JOURNAL
-------
sludge operation, which generates 2.5
million gallons every day. is too
massive to be entrusted to a patchwork
of private contractors. Last year's
spectacle of the Mobro garbage barge
wandering helplessly on the high seas
clearly warns against this sort of waste
management.
Several years ago, the city assessed
the relative environmental impacts of
ocean disposal and incineration. U'e
concluded that ocean disposal was a
safe option. For all the claims made on
its behalf, incineration could open a
Pandora's box of environmental
problems. Few modern incinerators arc;
currently in use anywhere, and none of
these are as large as the city would
need. Our previous commitment to
garbage incineration and our
compliance with the federal Clean Air
Act could force the city to locate sludge
incinerators outside of the city.
Wherever they are located, sludge
incinerators would have the addition,il
burden of being operated so as not to
produce any acid rain effect on the
environment.
Ocean dumping may not be the
ultimate method of sludge! disposal. At
EPA's request, we are again examining
the relative environmental benefits of all
known methods. By studying the
alternatives anew and working with
state and federal legislators, we may
some day devise a process that is even
safer than ocean disposal.
Unfortunately, we won't find it next
year or the year after. It will take time,
patience, and cooperation to develop a
method that won't replace our 50-year
safety record in the ocean with a new
threat to the: environment.
New York City is firmly committed to
pursuing the most environmentally
sound method of sludge management
that is legally and technologically
within our grasp. Given time, we will
find such an alternative to ocean
disposal.
(Copyright H)88, h'divurd I. Koch; used
by permission)
Governor Thomas H. Kean
The Atlantic Ocean and the New
Jersey shore are something special:
no one disagrees with that. How many
families look forward to those la/.y
summer weekends when they can live
the good life in cottages in Belmar or
Mantoloking? How many romances have
been hatched as young couples stroll in
the moonlit surf? How many generations
have earned a living by fishing our
ocean's waters?
Sadly, despite its mysterious beauty
and its practical significance, we have
often treated the ocean no better than a
junkyard or a garbage can. U'e have
viewed it as a convenient dumping
ground for those awful substances we
do not want on land. In no area is this
shortsighted philosophy more apparent
than in our reliance on ocean dumping
ot sewage sludge.
Forty-eight states, along with most of
New York state and the southern part of
New Jersey, dispose of their sewage
sludge without resorting to ocean
dumping. Only nine agencies in
northern New Jersey and the New York
City area send sewage sludge in barges
out over the hori/.on to be dumped into
increasingly murky waters.
Since the Ocean Dumping Act was
passed in 1973. the amount of sewage
sludge dumped by New Jersey towns
and cities has increased from 442.000
pounds per day to almost 930.000
pounds per day. Fifty-eight percent ol
the sewage sludge we produce is now
dumped in the ocean.
Why has this increase occurred?
Because we have done a good job of
upgrading w.tstewater treatment
facilities. In fact, we expect a 50-percent
increase in the volume of sludge
produced over the next few years as we
continue to provide cleaner water.
Given rny state's increased
dependence on sludge dumping, it
would be convenient simply to argue
that the practice should continue. But
we must not do what is easy: we must
do what is right, both for the
environment and for our long-term
economic health. We must end all
dumping of sewage sludge in the ocean
by 1991.
Mayor Koch and others argue that no
evidence exists proving that dumping
sewage sludge damages the ocean. The
truth is, the scientific evidence is too
uncertain to answer that question. By
choosing ocean disposal over land
disposal, we are gambling on the
unknown.
If we lose that gamble, the price is
incredibly high: tourism is a $7 billion
industry on the New Jersey shore; the
regional fishing industry earns more
than $100 million a year. What's more,
these numbers don't begin to
approximate the cost of lost jobs, ruined
vacations, and the degradation of a
natural resource we have a moral
responsibility to bequeath to the next
generation.
No one can argue any longer that the
ocean is the only viable disposal option
for sewage sludge. U'e have made
dramatic advances in pretreatment to
remove toxic: metals from sludge, in air
pollution control technology to allow us
to burn sludge safely, and in source
reduction technologies to cut the
volume of sludge produced. These
technologies are safe and practical.
Other states are using them. They are
working.
Knding sludge dumping isn't going to
be cheap. In northern New Jersey, we
estimate we may have to site six new
incinerators at a cost of hundreds of
millions of dollars. New Jerseyans will
see these costs in their sewage bills.
Still, this is a price we are willing to
pay as one very important step to
protect our precious ocean from
destruction.
[kit New Jersey cannot do it alone.
New York and New Jersey are as
dependent upon each other as a figure
skating pair in the Olympic Games.
Imagine if only one skater spent long
hours training while the other never
Governor Thomas H. Kean
JUNE 1988
-------
practiced? The result would be failure.
The same result will occur if New Jersey
ends its sludge dumping while New
York continues.
Some have said a five-year deadline is
unrealistic;. I disagree. New Jersey's
experience has proved that this is
enough time to permit and site these
facilities, and to begin construction. If
New Jersey can do it. why can't New
York?
Ending sludge dumping has to be a
high priority. When that last sludge
barge leaves the harbor, it will signify
thai the years of neglect and callous
disregard for the ocean are finally
behind us. It will show that we
appreciate the ocean's value and fragile
nature.
It will signal, in short, that we accept
the responsibility of passing on a
healthier planet to those who come after
us. o
Mike Brinker
Should sewage sludge he dumped in
the ocean? This question raises three
others:
• Qm we afford, environmentally, to
discontinue disposing of treated sewage
sludge in the ocean without accurately
evaluating all of the options available
(ocean, air, and land) to determine
which would lie impacted the least?
• Is the timetable that has recently been
decided upon attainable':'
• Is the decision to cease ocean
disposal politic. al or scientific:?
In 1 i)76, when the issue of
discontinuing ocean dumping was
initially raised, it was determined thai
sewage sludge disposed in the ocean
was detrimental and, therefore, the
practice should cease. Nobody,
however, has determined that land
disposal would be less detrimental than
ocean dumping. In fact, it may create
more problems.
Tilt; decisions being made
today- involving fines and fees and the
establishment of an unattainable
timetable in an effort to force the
discontinuance of ocean dumping by
March 1!)<)1 are political, not
scientific. They are based principally
upon the public perception that treated
sewage sludge deposited in the
ocean—even 106 miles offshore—is
environmentally damaging. The treated
sludge is confused with raw, untreated
sewage or with garbage and its attendant
floatables that find their way to the
ocean through combined sewer
overflows and garbage landfills.
Arguments on both sides point to
"irrefutable proof" to support their
contentions. The fact of the matter is
that EVA is required to de-designate or
redesignate the 106-mile site, but only
after their complete evaluation has been
made. Should EPA decide to redesignate
the site, there is no doubt that the
decision will be challenged. If the
challenge succeeds, whatever timetable
is set thereafter would be in the form of
a compliance schedule, since cessation
of ocean dumping would be a foregone
conclusion.
From a practical standpoint, the
presently proposed !!)!)] deadline
cannot be met. Therefore, consideration
should be given to extending this date
with the understanding that those
agencies that show good faith efforts in
preparing to get out of the ocean shall
be exempt from fees, fines, and
penalties while their preparations
proceed.
The six New Jersey agencies that use
the 100-mile site have recently had their
effluent discharge permits modified to
include a mandated compliance
timetable, under which we must submit
to the state Department of
Environmental Protection, by April 30.
1989, an update of our previously
submitted land-based sludge
management plans. At that time we
must define the plan (probably
incineration) which will be utili/.ed: we
must also acquire the site, conduct a
Public Hearing and offer responses to
same, and submit an application for
said plan for review and approval.
The permitting process for sludge
incineration air permits will take
approximately 12 months, or until April
30. 1 <)<)(). This leaves only 11 months to
fund, design, review, bid, award,
construe:!, and start up (following
shakedown) an incineration facility.
This just cannot be done within the
time frame proposed by the regulatory
agencies and the legislature.
And what of the risks to air quality?
The northern New Jersey area is one of
the most densely populated and
industrialized areas in the country.
Added to six proposed solid waste
incinerators and a hazardous waste
incinerator in this area, the five sludge
incinerators that have been proposed
would only compound the already
existing air-quality problem.
The legacy that would be left by those
who regulate and legislate might be a
cleaner ocean, but at what expense to
the air quality, and at what cost to the
millions of people who inhabit this
densely populated area?
The issues at hand should be resolved
by conducting a "multi-media
evaluation." A recent article in the
nationally circulated U'ciler Pollution
Control Federation /ounuil noted that
the ocean should be considered a
multi-media disposal environment.
Before we remove 55 percent of the total
sludge quantity generated in New Jersey
from the ocean and bring it onto the
land, perhaps we should reconsider and
not commit ourselves to a decision that
may have land- or air-related
repercussions in the future, after the
present-day legislators are gone from
office.
We are not against the cessation of
sewage sludge disposal in the ocean. We
do and will support what promises to
be scientifically and environmentally
proper for the users of our facilities so
long as timing and factual data are
considered in the decision-making
process. Hut until a proper decision is
made, we can only continue to dispose
of our treated sewage sludge in the
ocean, 106 miles offshore. LJ
Mike Brinker
10
EPA JOURNAL
-------
Syringes picked up from the
shoreline of Staten Island's
Midland Beach, on July 11,
1988, are displayed in a child's
beach toy. Hundreds of such
items have been found this
summer on New York-northern
New Jersey area beaches
along with blood vials,
prescription bottles, and
medical tubing. William C. Franz
photo. Staten Island Register.
Whodunit?
by Christopher Daggett
II IVIothing ever really goes away."
I \l That's what scientist and writer
Barry Commoner warned several years
ago regarding the environment.
Garbage, one of the less savory fruits
of our technological progress, is no
exception to that rule: plastic toys,
appliances, and packaging; rubber tires
and dacron shirts; styrofoam cups. We
use them and throw them away. Out of
sight, they are out of mind ... for a time,
until these "disposable" goods resurface
as decomposing ghosts of their former
JUNE 1988
1 1
-------
selves. And they can do it in the
unlikeliest of places.
This point was brought home to New
York and New Jersey by a mysterious
development last summer. Garbage of
unknown origin began washing up on
shores in the New York Harbor area and
along the New Jersey coast. So much
garbage was washing up, some of it in
giant, floating slicks of coagulated
waste, that local health officials had to
close beaches on several occasions.
In the most publicized case—in
August 1987—a 50-mile garbage slick
washed up on New Jersey beaches from
Belmar to Beach Haven. The slick
contained all types of floatable garbage
(often referred to as floatables),
including plastics, paper, cans, bottles,
wood, and, most alarming to the
beachgoers, used hypodermic syringes
and other medical-type waste.
The problem quickly became a hot
topic to the local news media.
Environmental groups and politicians
raised public health issues, and the
business community voiced concern
about the effects of floatables pollution
on the beach-dependent summer
tourism industry.
Jarring TV footage and newspaper
photos of syringes and other garbage
blanketing sections of coastline fueled
public concern throughout the region.
The clamor grew to find the source and
stop the pollution.
EPA began its own investigation to
help state and local efforts to unravel
the mystery. For three months, from
November 1987 through the following
January, the Agency conducted
helicopter surveillance and on-site
investigations, photographing and
videotaping shorelines and waterways,
and tracing possible sources.
The first goal of the investigation was
to assess the real extent of the floatables
problem and to see which areas were
most heavily affected.
In general, the greatest accumulation
was found along natural, undeveloped
shorelines, near the New York City
metropolitan area, which retain
floatables more readily than do heavily
developed shore areas. In fact, floatables
accumulation was minimal along the
developed shorelines, where man-made
seawalls and piers that prevent them
from washing ashore have replaced
beaches and wetlands.
While assessing^the extent of the
problem was a necessary first step, the
overriding goal of EPA's study was to
isolate the sources of the floatables.
Agency investigators used a number of
tools, including special tide-monitoring
and surveying equipment, to track
possible sources. They turned up
several likely sources. They also found
that the dynamics of floatables pollution
are much more complex than was first
suspected.
They found, for example, that
floatables pollution takes two distinct
forms. First, there is everyday
accumulation—dispersed quantities of
floating garbage and wood that have
been familiar sights in the New York
Harbor area for many years. And, there
are the large concentrated slicks of
waste. Though they appear only
periodically, it is these slicks which
most alarm people and have forced the
widely reported beach closings.
The investigators' most important
discovery was that each form of
floatables is produced in a distinct way.
Extensive helicopter surveillance and
tracking found a wide variety of sources
There is no single villain in
this story. As EPA discovered,
there are many factors, from
garbage handling to the pull
of the moon.
for daily accumulations of dispersed
floatables:
• Litter from pleasure boaters and
beachgoers.
• Foreign and American commercial
ships and military vessels that dump
on-board garbage at sea in order to
avoid the requirements of in-port waste
disposal.
• Spillage, from garbage landfills on the
shores of New York Harbor.
• Spillage from garbage barges at
marine transfer stations.
• Free-floating wooden beams and
planks from decaying piers, rotting
wooden vessels, and pier demolition
work.
The daily accumulation of medical
waste that has so alarmed people has
less apparent origins. City and state
regulations in New York and New Jersey
mandate special handling and, in some
cases, incineration of medical refuse.
Obviously, some of it has been slipping
through the regulatory checks. It
remains unclear, though, whether it
comes mainly from hospitals and
clinics, private practitioners, home
IV-users, drug addicts, or some
combination of all of these.
If finding all the sources of the
dispersed, everyday floatables has been
difficult, determining the sources of the
floating slicks has proven no less so.
In fact, because the slicks appear only
periodically, it has been even harder to
pin down the dynamics behind their
formation. Certainly, dispersed
floatables provide some of the raw
material, but slick formation requires
some other, more unusual
12
EPA JOURNAL
-------
circumstances, as well. It appears that
they can form in a couple of ways.
EPA investigators found one way
slicks formed while studying Pralls
Island, an uninhabitated piece of land
in the waters off Staten Island that was
literally covered with garbage.
The investigators had come to suspect
that, when heavy rains worked together
with the lunar pull of a new or full
moon to produce abnormally high tides,
Something else unusual was happening:
floatable garbage previously deposited
along the island's shores was
resuspended in the harbor waters by the
high tide and flushed back offshore. The
resuspended garbage, apparently, then
gathered in the water with other
floatables to form large floating slicks.
To test that theory, and to document
it on film, EPA undertook a special
study of the island. Monitoring was
initiated with the occurrence of a new
moon and one day prior to a forecasted
rainstorm. Investigators marked off the
island's high tide line and painted
onshore floatables fluorescent orange in
order to track any resuspension.
Tide-monitoring bottles were also
dropped along the shoreline.
Two days later, after the rainstorm
and the gravitational pull of the new
moon had produced tides two feet
above normal, the investigators found
that virtually all the specially painted
floatables, as well as the tide-monitoring
bottles, had either been resuspended
and carried off the island or redeposited
elsewhere along its shore. New floatable
objects had been deposited in their
place. At the same time, floating garbage
slicks began to appear in the waters off
the islanid.
EPA also found a second way slicks
can be formed when the investigators
examined a process called combined
sewer overflow. In many older cities of
the Northeast, such as New York City
and Newark, New Jersey, storm drainage
systems and sewer systems are
combined in one underground network.
During big rainstorms, these municipal
systems are often overloaded and have
to divert some stormwater run-off
directly into the waterways of the New
York Harbor complex. The run-off
carries with it a good deal of sewage, as
well as leaves and street litter that have
been swept into storm drains. When this
run-off combines with dispersed
floatables already in the water,
concentrated slicks can be formed.
And when combined sewer overflow
and resuspension in the water occur
together, the largest slicks appear to be
formed.
In fact, a look back by EPA revealed
that such a combination occurred only
days before the infamous 50-mile slick
appeared off the New Jersey coast in
August 1987. EPA believes that,
together, these events helped to produce
the giant slick.
Another suspected factor in the
formation of the big slick is garbage that
is believed to have been illegally
dumped into the New York Harbor
some days before the slick appeared. As
of now, however, that is still under
investigation.
Now that most of the sources of
floatables pollution in the New
York-New Jersey area have been
identified, EPA is trying to focus
With the major parts of the
puzzle now identified,
policy-makers should find it
less of an exercise in the dark
to piece together solutions.
attention on possible solutions. But
getting rid of floatables, whether in
dispersed or slick form, will be no mean
feat.
Writer H.L. Mencken easily could
have been talking about floatables
pollution when he said: "For every
problem there is one solution that is
simple, neat, and wrong." The floatables
problem is so visible, so obvious, that it
is tempting to look for equally obvious
solutions. But there is no single villain
in this story. As EPA discovered, there
are many factors, from garbage handling
to the pull of the moon.
Efforts to minimize floatables
pollution will have to take all of the
contributing sources into account. And
they will have to address the dynamics
of the floatables problem in all its
complexity. But with the major parts of
the puzzle now identified,
policy-makers should find it less of an
exercise in the dark to piece together
solutions, a
(Daggett, Administrator of EPA''s Region
2 since 1984, will become
Commissioner of New Jersey's
Department of Environmental Protection
flu's month.)
Editor's note: Similar incidents of beach
washups of floatable garbage, most
notably including medical-type waste,
are occurring this summer in the ocean
waters of the New York-New Jersey
area. Local, state, and federal
authorities are working to address the
problem through a variety of legislative,
regulatory, and public education
measures. Investigations continue into
the sources of the waste, particularly
the medical-type material, o
JUNE 1988
13
-------
What Congress
Is Learning
by Senator John H. Chafee
The 100th Congress has heard a
disturbing message regarding the
condition of our coastal waters, bays,
and estuaries. This message has not
been carried solely by environmental
groups but is echoed by fishermen
alarmed by declining catches of fish, by
average citizens who are disgusted by
the tide of coastal pollution and trash
that appears with regularity on our
beaches, and by objective researchers at
universities and at the Congressional
Office of Technology Assessment.
Essentially the message is the same:
America's coastal waters are dying. The
implicit conclusion is that the panoply
of policies and programs at the federal,
state, and local levels has not been
effective in adequately protecting our
marine environment. At a time when
the stresses on our coastal waters have
never been greater, we are experiencing
a decrease in funding for critical marine
research and enforcement programs and
are witnessing a lack of political will
needed at all levels of society to protect
our resources at sea.
Perhaps most sobering is the dire
warning delivered in a congressionally
mandated report by the Office of
Technology Assessment (OTA). This
report, Wastes in the Marine
Environment, notes that an enormous
amount of pollution ultimately makes
its way to coastal waters. Many of these
waters, the report notes, have exhibited
a variety of adverse impacts, and their
overall health is declining or threatened.
Without stern additional measures, new
or continued degradation will occur in
our coastal waters.
This message is unequivocal and
poses a serious challenge to lawmakers.
Not only do existing laws need to be
more stringently enforced, but there is
clearly a need for new, forward-looking
legislation that offers innovative
approaches to the problem. This is
happening at a time when budget
deficits are forcing Congress to
scrutinize every new dollar that goes
out the door.
The Senate Environment and Public
Works Committee, in a series of
oversight hearings this past year, has
heard testimony chronicling individual
success stories. For example, EPA's
Near-Coastal Program holds promise of
providing us with accurate
measurements of the total loadings of
pollutants in our near-coastal waters. In
this effort, EPA is being assisted by the
National Oceanic and Atmospheric
Administration's national status and
trends programs. Despite Administration
efforts to cut the data-gathering
capabilities of these programs, they have
been a useful tool in monitoring the
health of coastal waters.
Another major effort under way at
EPA is the National Estuary Program,
which fosters inter-agency.
inter-governmental, and public/private
sector cooperation in addressing the
total pollution problems of selected
estuaries. Under the auspices of this
program, a comprehensive master
environmental plan is being developed
for Narragansett Bay in Rhode Island.
Ideally, this plan will address the
control of point and nonpoint sources of
pollution, and the implementation of
environmentally sound land-use
practices near the Bay.
Although we are winning some of the
battles, it is apparent from the OTA
report that we are losing the war. The
two major statutes that govern waste
disposal in the marine
environment—the Marine Protection,
Research, and Sanctuaries Act (MPRSA)
and the Clean Water Act—in theory
provide adequate authority to protect all
marine waters and the rivers that flow
into them. MPRSA generally regulates
the transportation and clumping of
wastes on the high seas, and the Clean
Water Act covers all discharges into the
navigable waters of the United States.
The broad authorities of these
overlapping bills give government the
ability to assess and regulate the total
loading of pollutants into the marine
environment.
Why, then, are we finding that almost
a third of the shellfish beds in the
United States are closed due to
pollution? Why are half of our nation's
coastal wetlands destroyed? Why are
beaches from Florida to Maine often
closed to swimmers for periods during
the summer? Why are some New
England lobstermen reporting that their
catch is down 75 percent? And why are
14
EPA JOURNAL
-------
;
•• *.
UL~$m
Y V*^-
.j • ' r-T. J"«*
..
.
Above. New Jersey's Department of Environmental Protection set thousands of bottles free
from various locations to determine where they would land. Hundreds washed up on the
eastern shore of Staten Island like these in Princes Bay. William C. Franz photo. Staten Is/and
Register.
Far right. A scenic shoreline as people like to think of it. Steve Delaney photo.
we still dumping more than a billion
pounds of toxic pollutants directly into
our waters each year?
The solution to these problems is
complex. It involves a significant
increase in congressional oversight of
the agencies charged with enforcing
these statutes, new legislation to bring
new approaches to conducting research
on the marine environment, and a
public education campaign aimed at
heightening awareness of coastal zone
management issues. Oversight must
focus not on issues in isolation, such as
successes in regulating point-source
pollution, but on a comprehensive
picture of why coastal waters are
declining in health. The site-specific
waterbody management programs
initiated by the Water Quality Act of
1987, such as the Chesapeake Bay and
National Estuary Programs, must be
viewed as part of an integrated national
strategy to clean up coastal waters.
The need for comprehensive
management of coastal waters will grow
more urgent as we approach the next
century. Population shifts are placing an
increasingly heavy burden on the east
and west coasts of the United States. By
1990, a mere two years from now, an
astounding 75 percent of America's
population—over 180 million
people—will live within 50 miles of our
JUNE 1988
15
-------
sea or Great Lakes coasts. The intense
pressure on the marine ecosystem
created by this migration will require
government at all levels, as well as the
private sector, steadfastly to^esist the
urge to overdevelop our coastal areas.
For example, municipalities that already
experience wastewater overflows during
rainstorms must tightly restrict
development until additional treatment
capacity exists to deal with such
emergencies. Policies at the federal level
should reinforce this kind of approach.
During oversight hearings, lawmakers,
including myself, have been frustrated
by the lack of definitive answers to
seemingly basic questions. Is the shell
disease seen in many New England
lobsters caused by the ocean disposal of
sludge? No one seems to know for sure.
Why have oyster harvests in Chesapeake
Bay declined by almost two-thirds?
What is causing the disorder that results
in the beaching of hundreds of
dolphins? What is the relationship
between the introduction of pollutants
to the marine environment and the
contamination of marine organisms?
What is the impact of extensive new
sewage treatment plant capacity on the
water quality of Narragansett Bay?
In testimony before the Senate
Environmental Protection
Subcommittee, Robert Duce, Dean of the
University of Rhode Island's Graduate
School of Oceanography, lamented that
in many coastal areas we simply do not
know with any scientific accuracy
whether there has been'improvement or
degradation. He also noted that the
necessary measurements and long-term
monitoring programs that can give us a
standard against which we can gauge
water quality, and by which we can
measure water quality changes, simply
have no! been available for most coastal
regions.
Before government can act
intelligently, it is essential that we
develop a thorough scientific
understanding of our marine resource
and identify threats to its quality. This
knowledge is vital if we are to protect
the marine environment and act to
prevent problems before they become
unmanageable. OTA's report on wastes
in the marine environment concluded
that—monitoring, research, and
enforcement are currently
inadequate. . . . Information gaps still
constrain analyses of marine wastes
disposal, partly because of a lack of
information gathering in some areas of
the country, lack of systematic analyses
of gathered data, and ineffective
dissemination of results.
In response to this critical lack of
information, Senator George Mitchell
(D-ME) and 1 have developed legislation
to expand and strengthen our marine
and estuarine research program: the
Marine Research Act of 1988. The key
provision of the bill authorizes the
establishment of 10 multi-state regional
marine research centers. The centers
would coordinate and support the
activities of organizations and agencies
in the region, including state agencies,
The need for comprehensive
management of coastal waters
will grow more urgent as we
approach the next century.
universities, and other laboratories. The
regional research centers would be
designed to complement existing
research efforts, such as those being
undertaken by the Sea Grant Program.
The bill would authorize $29.5 million
annually for each of the next five years.
The regional approach adopted by
this legislation will encourage
researchers to study specific marine
ecosystems, rather than stop at the
artificial borders of a particular state.
Passage of this bill, which now has
close to 20 co-sponsors, will allow us to
answer some basic questions about
status and trends and help us keep pace
with the growing threats to marine
environmental quality.
In addition to a critical lack of
research, Congress has recently heard
about other problems afflicting our
oceans. There has been growing concern
over discarded plastics in our nation's
waters: six-pack holders, packing bands,
lost or discarded fishing nets, etc.
Entrapment in this plastic debris is
known to kill thousands of birds, seals,
turtles, sea lions, and fish every year.
The plastic pollution problem has
grown to such a point that the average
citizen cannot go to a beach or park
without encountering plastic litter.
Beach clean-up efforts, which have now
become routine in many states, result in
the collection of tons of plastic debris.
Congress took definitive action to
address this problem last year when it
approved legislation to implement the
international convention for the
prevention of pollution from ships,
commonly known as MARPOL Annex
V. This treaty, when it goes into effect
later this year, will make it illegal for
ships to dispose of plastic waste
overboard. The Senate also has recently
approved a bill 1 authored to require
six-pack holders to be made from
degradable materials, a requirement that
12 states have already adopted.
Congress recently held hearings on
reports that the nitrates in acid rain may
effect the quality of our coastal marine
waters. As with many reports of this
kind, it raises significantly more
questions than it answers. A related
issue concerns the potential for global
warming to raise sea levels and the
catastrophic consequences this could
have for our planet.
The combined effect of these issues
has been to increase the awareness level
of legislators regarding the impending
crisis in our marine environment. It is
my hope that we are setting the stage for
a comprehensive re-examination of
marine environmental policy in the next
Congress. Such an examination must
include a critical look at existing
statutes such as the Coastal Zone
Management Act, the Clean Water Act,
and the Marine Pollution, Research, and
Sanctuaries Act, as well as the agencies
charged with their implementation.
Where gaps are discovered, new
legislation must be crafted. Research is
clearly an area where more funding and
legislation are needed to fill critical
gaps.
Finally, if this re-examination is to
occur, environmental and citizen groups
will have to continue to turn up the
heat. Recently, Representative Mike
Lowry and I sponsored a breakfast to
bring a coalition of environmental
groups to Washington to present the
findings of a landmark conference
entitled "Saving Our Bays, Sounds, and
the Great Lakes." The environmental
groups attending this conference, which
represent more than eight million
people, were brought together to help
solve the problems that are killing
America's coastal waters. Groups such
as these will have to use all the political
clout they can muster to convince
Congress that action must be taken to
preserve our coastal environment.
We are very shortsighted if we do not
heed the warnings of the Office of
Technology Assessment and take steps
now to avert what is becoming an
environmental crisis. Polluting our
coastal waters to the point where
marine life cannot exist is not the legacy
we should leave to future generations. Q
(Cha/ee (R-Rhode JsJandJ serves on the
Senate Environment and Public Works
Committee.]
16
EPA JOURNAL
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Raymond Muzika photo.
Special
Protection
for the
Oceans?
A Forum
Should (he ocean receive
special protection? EPA
Journal asked six respected
observers from different
vantage points their views on
this question. Here are their
answers:
Sally Ann Lentz
As noted marine biologist
Dr. Sylvia Earle observes,
"We know more about outer
space than we know about
life in the deep ocean."
Lacking hard scientific facts
about deep ocean ecosystems,
it's difficult to quantify the
damage done by pollution.
Nonetheless, the vital link
between healthy oceans and
the ability to sustain life on
our planet is well known,
and that link alone is ample
reason for special protection
of fragile ocean and coastal
ecosystems.
Last year, the World
Commission on Environment
and Development published
the results of a compelling
four-year study, Our
Common Future. As a part of
its report, the Commission
found that living resources of
the ocean "are under threat
from over-exploitation,
pollution, and land-based
development," and that
"sustainable development, if
not survival itself, depends
on significant advances in
the management of the
oceans."
Given the importance of
the oceans in sustaining life,
special protection is needed
to safeguard their unique
vulnerability—both
ecological and political. The
oceans' function as a natural
sink for wastes from land and
air was part of a grand design
that functioned extremely
well for hundreds of millions
of years—before the creation
of synthetic products like
pesticides, chemicals,
plastics, and other toxic
wastes. Today, though, the
persistence and toxicity of
these materials present an
untenable challenge to the
natural function of the ocean.
At the same time, existing
political systems contribute
JUNE 1988
17
-------
to the vulnerability of the
ocean. The oceans know no
boundaries. Yet national and
international law sets up
artificial boundaries, leaving
the oceans at risk at the
hands of those individuals,
and governments, for whom
protection and wise use are
not guiding considerations.
So yes, the oceans should
have special protection — they
must have special
protection — to preserve them
as the life-givers of our
plant;! and to shield them
from abuse by short-sighted
special interests. Through
education, research, and
action, this challenge must be
met — individually and
collectively. Other challenges
may seem more immediate,
but few are as pervasive in
their implications, n
l/ is a Skiff Attorney af
the Oceanic Society.)
Charles Osterberg
Should the oceans receive
more protection than a
babbling brook, Walden
Pond, a copse of trees alight
with redbud, a host of golden
daffodils? More protection
than the rich black loam of
Iowa, the Big Skies of
Montana, the mighty
Columbia, or a Saguaro
cactus forest in Arizona? This
oceanographer votes "no."
No matter. The Marine
Protection, Research, and
Sanctuaries Act (1972) did
just that. The Navy's old
nuclear submarines must be
buried on land despite the
recommendations of the
Environmental Impact
Statement and ALARA (keep
radiation levels As Low As
Reasonably Attainable)
because of the Act and the
prohibition against ocean
disposal specifically
provided in the Anderson
Amendment. This
amendment sprouted
overnight like a toadstool in
the barnyard in the rain
when the Navy included the
ocean in its disposal options.
Special protection from a
vigilant Congress to make
doubly sure!
Now proud, patient old
submarines smolder
ignominiously in
incongruous terrestrial
graves, awaiting the slow but
tireless geologic forces of
wind, sun, water, and gravity
to return them inevitably to a
just burial in the distant sea.
Yes, the fringes of the
ocean are polluted and need
protection. But this is
because of misguided laws
protecting the ocean, which
as a consequence of their
implementation, leave the
land and air vulnerable to
misuse. Rain and ground
water perc through waste
disposal dumps, septic fields,
and landfills, pouring filth
into coastal waters. Fumes
from fuels, autos, and waste
burning climb to the skies,
returning as acid rain and
chemical crud. All natural
distributive processes carry
these downhill to coastal
waters, polluting the 2
percent of our oceans that
provide 85 percent of our
seafood. Meanwhile 98
percent of the planet's water.
that in the deepest ocean,
contains less man-made
pollutants than fresh spring
water. Other than remoteness
and barrenness, the only
thing that the ocean has too
much of is Congressional
protection, c:
(Osterberg. now retired, is n
former professor of
Oceanography at Oregon
State [/niversiiy, director of
the International Laboratory
of Marine Radioactivity in
Monaco, radiation specialist
with the Department of
Energy, and independent
businessman.)
Representative
Mike Lowry
For centuries, the vastness,
the beauty, and the many
potential uses of the oceans
have captured the
imagination. Human
innovation has brought us
far. creating technology that
has allowed us to adapt to
some of the sea's perils, and
to shorten the distance
between continents.
Modern-day vessels now
process as well catch much
of the seafood that comes to
our markets and into our
homes. Millions enjoy the
coastal regions for their
recreational activities. Given
the amount of dependency
on and enjoyment of ocean
waters, special attention must
be given to their protection.
Recently, the coastal areas
of the United States and their
inhabitants have been subject
to various forms of pollution.
A most prevalent problem for
our nation's waterboclies,
especially in coastal areas, is
the amount of land-based
pollution that in various
forms continues to invade
them, resulting in increased
levels of contamination of
water-column sediments and
living marine resources.
The basic factor underlying
the need for special ocean
protection is that ocean and
coastal waters are a common
property resource. Since they
are available for public use,
many people will take
advantage of this availability,
risking overuse of this
valuable resource. In the case
of ocean waste disposal, for
example, regulatory policies
and limits must be applied
that recognize the fact that
the ocean is a common
property resource and that
unless the government
specifically intervenes to
protect them, the ocean and
coastal areas could become
the repository of last resort
for much of our nation's
waste. This is a particular
EPA JOURNAL
-------
concern as we continue to
limit disposal of waste in
landfills and by incineration.
Congress has established
policies to protect our HUMUS
and keep them available for
the benefits and activities we
all enjoy. The Clean Water
Act and, to a great extent, the
Marine Protection, Research.
anil Sanctuaries Act
(MI'RSA) are two such major
legislative initiatives. Both
are designed to provide
special protection of ocean
disposal of harmful materials.
The MPRSA is presently up
for amendment to Establish
additional research centers to
aid in the long-term
monitoring and research
necessary to clean up our
nation's important water
bodies.
The ocean is a unique
resource in that no other part
of our world today offers its
public availability for
enjoyment and plays such a
vital role in energy and life
cycles. It is imperative that
this resource receive the
special protection necessary
for its survival. '-
(Congressman Loivry
(D-WashingtonJ is Chairman
of the House Oceanography
Subcommittee.)
Charles D. Matthews
The answer to this question
is a resounding YKS!
Speaking from the
perspective of the National
Ocean Industries Association
(X'OIA) and our members'
activities, the ocean waters
surrounding the United
States are receiving the
protection and the attention
they deserve.
Many people are concerned
that offshore oil and gas
development might harm the
ocean environment. However.
history has shown that these
operations can he carried out
in an environmentally sate
manner. The record of the
domestic: offshore industry
speaks for itself.
More than :12.00U wells
have been drilled in state and
federal waters off the U.S.
const with only one spill in
which significant amounts of
oil reached shore, and that
was almost 20 years ago.
NO1A does not know of any
conclusive scientific: data
which indicate that
permanent damage resulted
from that spill. Kach day, in
fact, some 1.2 million barrels
of oil and 13.7 billion cubic
leet ol natural gas are being
produced from offshore wells
in an environmentally safe
manner.
According to a study by
the Xational Academy of
Sciences a few years ago.
only a small fraction of the
oil in the world's
ocean—about 5 lOOths ol 1
percent of the total --can be
attributed to offshore
operations under federal
supervision. The same study
reported that river run-off is
the principal source ol oil
pollution in the seas.
accounting for 41 percent ot
the total, 'rankers and other
forms of transportation
account for approximately 20
percent, \atural oil
seeps—such as those off the
coast of California—account
for 15 percent of the
worldwide total. In fact,
during the past 15 years.
natural oil seeps off
California have contributed
2.4 million barrels of oil to
the ocean's waters.
By comparison to these
sources, oil and other
pollutants from Outer
Continental Shelf (OCS)
operations simply fall off the
low end of the statistical
scale. Since 1970. when new
regulations and technologies
were implemented in the
wake of the Santa Barbara
incident, the I'nited States
has produced over 5 billion
barrels of oil from the OCS.
while losing a total of fewer
than 850 barrels from
blowouts.
Exploratory wells must be
drilled to find and delineate
oil reserves, but most
exploratory wells do not find
commercially producible oil
reserves. Obviously, if oil is
not found, there is no risk of
a spill. The discovery of
commercial quantities of oil.
however, does not mean that
a spill will occur. Production
of natural gas obviously
cannot cause a spill. Industry
has developed equipment
and procedures to prevent
spills, and clean-up
procedures to mitigate
potential damage if a spill
did occur. Fortunately.
industry safety practices are
such that then! has been little
need for this equipment.
Concern has also been
expressed about the effects of
offshore drilling mud
discharges on marine life.
Drilling fluids ("muds"), drill
cuttings, and produced water
are either used in or are
by-products of the drilling
process. Offshore disposal of
these materials requires
permits under the National
Pollution Discharge
Elimination System (NTI)KS)
from EPA. Generally.
water-based drilling muds
and produced water, which
have a low toxicity. are
discharged into the
environment. And waste
waters can only be disposed
into the sea if the oil content
averages less than 50 parts
per million.
A l
-------
J.R. Schubel
Society produces enormous
amounts of wastes of all
kinds. We must strive to
reduce these amounts, to
increase the amounts we
recycle and reuse, and to
render those wastes that
require ultimate disposal as
innocuous as is appropriate
and practical. We must then
select disposal strategies
which will minimize the
risks of adverse impacts on
the environment, on living
resources, and on human
health—or which at least will
reduce any risks to
acceptable levels.
Should the ocean receive
special protection? No. The
key word in the question is
"special." My dictionary
defines special as "unusual
or unique, particularly
favored, set aside for a
particular use." As an
oceanographer, I would like
to he able to argue
persuasively for special
protection for the ocean—for
favored status—but I cannot.
To do so would imply that
other segments of our
environment should receive
less protection.
Selection of disposal
methods and sites lor each
kind of waste should result
from a comprehensive
analysis of the advantages
and disadvantages of the lull
range of plausible
alternatives and of the risks
associated with each. The
analysis should lie across
environmental media: air,
land, and water. Before a
disposal strategy is selected,
the best information should
be used to forecast tin;
probable consequences of
each alternative. The most
desirable strategy may vary
with class of waste, with
location, with time, and with
a variety of other factors, all
of which need to be
considered before making a
decision.
All segments of our
environment—land, air. and
water—should receive far
greater protection than they
now do. To favor one
segment of the environment
over others by providing
favored status is not the
answer, especially if it
simply shifts a problem from
one part of our environment
to another. This has been the
situation for far too long, and
neither the environment nor
society has been well served.
Instead of providing special
protection to the ocean, or
any other segment of our
environment, we shoidd use
the knowledge we already
have to make decisions, and
we should be more diligent
and imaginative in searching
for solutions.
The World Ocean should
continue to be a potential
disposal site for certain kinds
of society's wastes. Perhaps it
should be off limits for
others. Within the World
Ocean, we should ensure that
certain segments of the ocean
do receive special protection;
that certain segments do
receive favored status; that
certain segments are set aside
for particular uses which
society considers to be
important. D
(Schubd is Provost of the;
S'fafe (/Diversity of New York
at Stony Brook, and Dean
and Director of Stony Brook's
Marine Science Research
Center.)
Donald F. Boesch
The oceans merit special
consideration for
environmental protection
because they transcend
national boundaries, are fluid
and uncontrollable, and
constitute long-term
repositories for many of
society's wastes—whether
these wastes are directly
discarded into the oceans or
enter by way of rivers or the
atmosphere. On the other
hand, I do not believe that
the oceans should receive
"special protection" if that
means exclusion of activities
and practices, the alternatives
to which would have
deleterious effects on the
land or the atmosphere.
We continue to uncover
pervasive and surprising
interconnections among the
earth's environmental media:
the land, air, and fresh and
ocean waters. The effects of
increased heat retention
resulting from the buildup of
greenhouse gases on ocean
temperature, currents, and
sea level is an obvious
example. Less obvious is the
atmospheric; deposition from
fossil fuel combustion which
has contributed to the
increase in nitrate levels in
the Ohio River, which in turn
may be contributing to
oxygen depletion in the Culf
of Mexico. Atmospheric:
deposition is also apparently
contributing to excessive
nutrient loading of the
Chesapeake Bay.
Clearly our environmental
protection strategies need to
move beyond the current
medium-by-medium
management approach to
allow comprehensive
consideration of the
environmental impacts of
various alternatives. Does
this mean that ocean disposal
of wastes should be allowed
when other options are more
costly or less convenient? No.
Certain types of persistent,
toxic materials should simply
not be released to the ocean,
and rigorous comparisons of
the effects of different
disposal alternatives, even for
non-toxic wastes, should be
required. Does this mean that
dispersion in the vast oceans
is an acceptable alternative to
the more costly control of the
sources of persistent organic
toxicants? Certainly not.
Much of the debate
concerning whether the
ocean should receive special
protection has focused on the
permitting of offshore
disposal of wastes, including
sewage sludge, oil and gas
drilling discharges, industrial
wastes, and incineration of
toxic organics. While these
issues of ocean disposal
merit our concern and
attention, we must be careful
not to ignore the more
pressing problems of •
deteriorating quality of
coastal environments and the
more insidious ramifications
of riverine and atmospheric
inputs of contaminants on
regional and global scales.
These latter problems
overshadow ocean disposal
as serious risks to the health
of the oceans. Q
(Dr. Boesch is Executive
Director of the Louisiana
Universities Marine
Consortium and a member of
the Marine Board of the
National Research Council.)
EPA JOURNAL
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Steps Toward
a Global
Oceans View
by Alan Sielen
A few years ago, 1 was looking around
an old bookstore in London when I
overheard the only other customer—an
elderly American woman—inquire
about books on Hugo Grotius, the 17th
century Dutch international jurist. She
was disturbed about being unable to
find such works in the United States:
her frustration escalated into a tirade on
the philistinism of Americans in
general.
I approached her: "Ah, so you're
interested in the great jurist and
statesman." She looked at me
quizzically, equal parts loathing and
disbelief, "How do you know about
Grotius?"
I couldn't resist, and. in my very best
American accent, said, "\Yhy, madam.
every American schoolchild knows that
Hugo Grotius was the lather of the law
of the sea."
Both of us laughed, and a pleasant
conversation ensued, as 1 explained that
many years ago 1 had worked tin the law
of the sea negotiations. Finally 1 left.
suffused with the glow of a true patriot.
In few areas has Hugo Grotius' legacy
been more fully reaii/ed than in the
development of international law for the
A famed oil spill that helped
raise international
consciousness about the ocean
environment. Crew members
from the Amoco Cadiz help
clean up the Portsall, France,
coastline after an April 1978
accident. American Petroleum
Institute photo.
JUNE 1988
21
-------
One or two countries
prohibiting oily discharges
from tank cleaning operations
won't make much of a dent in
the problem if the rest of the
world's tanker fleet doesn 't
follow suit.
protection of the marine environment.
Faced with the fact that ocean pollution
does not honor national boundaries, and
with highly visible manifestations of
such pollution—oil spills, plastics
washed up on beaches, fish and dolphin
kills—national governments have given
marine protection a great deal of
attention. Since the historic 1972
Stockholm Conference on the Human
Environment, no area of environmental
cooperation has received more sustained
attention by the international
community than the prevention and
control of marine pollution.
In the past two decades major global
and regional agreements have been
concluded for such problems as:
• Ocean dumping (1972 London
Dumping Convention) and marine
pollution (MARPOL 1973/1978
Conventions on the prevention of
pollution from discharges by vessels).
• The special problems encountered in
regional areas (United Nations
Environment Program (UNEP)
Regional Seas Program, which includes
action plans for the Mediterranean,
Persian Gulf, West and Central Africa,
Wider Caribbean, East Asian seas,
Southeast Pacific, South Pacific, Red
Sea, and Gulf of Aden; with plans being
developed for East African and South
Asian seas, and the Southwest Atlantic).
• Other concerns such as liability for
damage from oil spills; control of
land-based sources of marine pollution;
offshore oil and gas development; and
tanker safety.
Some of these activities, such as
dumping and vessel pollution, are
subject to binding international rules.
Others, for the most part, involve
voluntary international guidelines.
Implementing these agreements has
required the cooperation of individual
governments and a network of
international organizations ranging from
specialized agencies like the
22
International Maritime Organization
(IMO) and International Atomic Energy
Agency (IAEA), to UNEP.
Despite this record of negotiation and
agreement on difficult issues, it must be
remembered that the existence of
international environmental law does
not guarantee better protection for the
oceans. None of the aforementioned
agreements establishes a supra-national
police force to patrol the seas and
ensure that rules are enforced; nor does
any provide the resources necessary to
mount an effective pollution-prevention
campaign. Implementation of
international rules is left to the
capability and good will of member
countries, whose responsible national
authorities have different levels of
scientific and administrative expertise
and varying degrees of commitment to
environmental protection.
As the United States has learned in
carrying out domestic environmental
laws, there are no final solutions;
effective environmental protection is a
dynamic process involving individual
citizens, business, academia, state, local,
federal government, and the
professional disciplines of politics,
science, economics, and law. At the
international level, this process becomes
even more complex as individual
nations compete to advance their own
national interests.
If international treaties and other
arrangements for marine protection are
only a stepping stone to real action,
why are they necessary in the first
place? This is a valid question, and,
indeed, much good work has been done
unilaterly by individual governments
combating particular pollution
problems. History shows, however, that
relying on individual governments to
act on their own to fight pollution
problems with global ramifications
usually produces poor results.
Some problems require concerted
action for an effective solution. One or
two countries prohibiting oily
discharges from tank cleaning
operations won't make much of a dent
in the problem if the rest of the world's
tanker fleet doesn't follow suit.
Preventing damage to the marine
environment by the ocean dumping of
toxic wastes will remain elusive unless
all countries agree to follow the same
rules. Effective spill response in a given
region, say the Caribbean, requires that
all nations in the area be prepared to do
their part in responding to an accident.
Also, there are costs associated with the
implementation of effective, pollution
prevention measures, such as
segregating ballast tanks on new tankers,
or carrying out effective monitoring
activities in support of a national ocean
disposal program. If all countries accept
and carry out needed measures, none
will be put at a competitive economic
disadvantage. Also, common
understanding of the scientific and
technical aspects of marine pollution is
enhanced by sharing research and
technological advances. The free flow of
information among countries can
prevent wasteful duplication and enable
individual countries to target limited
resources on those areas most in need of
attention.
In the months ahead, the international
community's commitment to marine
protection will be tested by a number of
important efforts:
• Early efforts in implementing
MARPOL Convention provisions on
tanker design, construction, and ship
operation centered on pollution by oil
and chemicals. Current work focuses
more on the implementation of
"optional" annexes governing harmful
substances in containerized or packaged
form; vessel sewage; and garbage.
MARPOL Annex V, which bans the
disposal of plastics in the world's
oceans and regulates the discharge of
other types of garbage, is particularly
EPA JOURNAL
-------
Oceans, anyone? Seventy
percent of our planet's surface
area is water, most of it in the
seas. Photographed from the
Apollo 17 spacecraft, this view
extends from the Mediterranean
Sea area to Antarctica's south
polar ice cap. NASA photo.
important, and will enter into force at
the end of 1988. Entanglement of
marine animals in plastic debris is a
growing concern, as is the ingestion of
plastics by marine organisms. Such
debris can also threaten humans by
creating hazards to navigation and
diving. Fouling beaches and other
recreational areas can have serious
economic consequences.
• Contracting parties to the London
Dumping Convention face issues that
will have a significant bearing on the
agreement's future effectiveness. These
countries are now evaluating the
environmental acceptability of the sea
disposal of low-level radioactive wastes
and the ocean incineration of hazardous
chemicals. Reaching consensus on an
approach to either of these disposal
options will not be easy. Perhaps most
importantly, the London Convention
Scientific Croup is now evaluating
alternatives to the agreement's present
black list/grey list system of regulation.
Whether a new system will
emerge—based, for example, on the
ocean's capacity to safely assimilate
wastes—remains to be seen. There is
also the question whether an alternative
formulation would uphold the
Convention's basic purpose of
preventing pollution of tin: marine
environment or would invite more
permissive national policies toward sea
disposal.
• Most efforts to control sea pollution
from land-based sources (e.g.. rivers,
pipelines, and run-off) has taken place
at the national or regional level.
Voluntary guidelines were developed by
UNEP a few years ago, but they do not
have the same force of law that the rules
governing ocean dumping and vessel
pollution have. The international
community must consider whether
some International Convention on the
prevention of marine pollution from
land is in order, at least with respect to
the regulation of some of the most
potentially harmful substances (e.g.,
transuranics, synthetic organic
chemicals, oil, and heavy metals).
• Regional conventions, such as those
concluded under the UNEP Regional
Seas Program, can be one of the most
important ways to fight ocean pollution.
For the United States, the recent entry
into force of the 1983 Convention on the
Development and Protection of the
Marine Environment in the Wider
Caribbean will provide an important
opportunity to work with neighboring
countries to protect a common and
increasingly vulnerable resource.
Similarly, activities relating to the 1986
Convention for the Protection and
Development of the Natural Resources
and Environment of the South Pacific
will test the U.S. commitment to a part
of the world that is experiencing
environmental problems associated with
new development and which is of
growing political and strategic
significance to the United States.
• The recent conclusion of a
Convention on Antarctic Mineral
Resources should force nations to
consider seriously the potential
environmental and scientific
consequences of mineral exploration
and development on the Antarctic
continent and Southern Ocean and
whether, under the new Convention,
serious thought should be given to
putting the continent off limits to
development before it is too late and its
critical global monitoring assets have
been destroyed.
• If intelligent decisions on tin; use of
the oceans are to be made, greater
emphasis must be placed on the
scientific: aspects of marine pollution.
Finding effective ways to mobilize the
international marine scientific
community into an effective force for
studying the behavior, late, and effects
of pollutants in the marine environment
is a major institutional challenge.
especially at a time when many
countries are looking at the oceans for
increased use as a waste depository. It is
especially important to ensure that there
are adequate scientific bases for such
decisions. Specific scientific problems
meriting closer attention include:
eutrophiccifion—the effects of nutrient
loading in different geographical areas;
bioaccumulation—foodchain transfer to
marine organisms and to man:
pathogens in the marine
environment—from sewage discharges.
rivers, and agricultural runoff: grnrml
ecosystem effects—resulting from, e.g.,
the disposal of participate matter; future
problems—e.g.. the introduction of new.
often toxic, chemicals into the marine
environment.
This is a full agenda, hut one that
should be taken seriously it future
environmental leaders are to uphold
their public: trust for a part of the world
that affects all our lives-- the oceans.
Finally, our successes and failures in
grappling with the international
dimensions of marine protection can
assist governments in addressing
"non-marine" global environmental
issues, such as stratospheric o/nne
depletion and climate change. Much of
the same dynamics of negotiation.
compromise, and steadfastness
encountered with various marine
negotiations over the years are now
being relived in other environmental
deliberations. Whether governments can
learn from the lessons of the past,
including the work Crotius began three
centuries ago, will have a large bearing
on the outcome of future environmental
negotiations affecting this small
planet, n
(Sieien is Director, Multilateral Staff.
EPA Office of International Activities.)
JUNE 1988
-------
Boston Harbor:
No Party After
the Tea Party
by Michael R. Deland
There is no honor in the distinction of
having the most polluted harbor in
the United States. There is only a
driving imperative to clean it up. It has
taken Boston and other metropolitan
area communities involved 10 years of
indecision and negotiation to reach an
agreement to rebuild the sewerage
system that still grossly pollutes the
Harbor, but Boston has at long last
begun the job.
During the same decade, many other
major U.S. metropolitan areas with
similar problems have made far greater
The old days: Fit? Hugh Lane's oil painting, Boston Harbor, Sunset, which he did between
1850 and 1855. Lane's show, currently in Washington, D.C., will open at Boston's Museum of
Fine Arts September 28. Collection of Jo Ann and Julian Ganz, Jr.
progress in curbing water pollution by
constructing new wastewater treatment
plants. Why did Boston fall so far
behind? Hindsight shows that a key
factor was that Boston's cleanup was
left to "voluntary" efforts, while
cleanups in other cities were spurred by
successful federal legal actions which
put continuing pressure on local
administrative and political obstacles.
Only today, under a federal court order
to meet a clean-up schedule, is Boston
moving ahead. Legal enforcement has
been a difficult lesson for Boston, but
one that, it is hoped, other American
cities will readily accept in the future to
avoid Boston's pitfalls.
Boston looks environmentally clean. It
is not a heavily industrialized city of
the kind generally associated with
serious environmental problems. Boston
is a beautiful urban area, steeped in
history and revolutionary landmarks. It
is home to some of the most prestigious
colleges, medical and research centers,
and computer and biotechnology
companies in the world. It is the city in
which Frederick Law Olmsted, the
father of landscape architecture, left a
permanent imprint with his "Emerald
Necklace" park system. It is a place of
culture, the arts, and music.
Yet Boston has a harbor—abou! 50
square miles, with some 30 islands and
about 180 miles of irregular tidal
shoreline—that is a cesspool, the most
polluted harbor in the nation. The
harbor is Boston's Achilles heel.
How could the citizens of the Boston
area have allowed this pollution to
occur?
There is plenty of blame to pass
around at all levels—local, state, and
federal. To many people, the harbor's
pollution was an "unseen" problem, not
readily detectable with one quick look
at the water. For others, cleaning it up
was too expensive; they feared
dramatically increased sewer rates.
Some did not want a wastewater
treatment plant in their neighborhood.
Also, concerned citizens and political
leaders simply did not fight hard
enough for a harbor cleanup, and so the
projec'.t lay dormant.
But of all the reasons for the failure to
do something about harbor pollution,
the one that stands out as the principal
culprit was the use of a "voluntary"
approach rather than seeking a
"court-mandated" cleanup.
In the late 1970s KPA launched a
national effort to stop water-pollution
violations in major metropolitan areas.
This effort involved major federal
lawsuits in New York, Los Angeles,
EPA JOURNAL
-------
Philadelphia, and elsewhere. Many of
these areas had pollution problems
comparable to Boston's during the
1970s, but have since made greater
progress in mitigating them.
In Boston, on the other hand, local,
state, and federal officials decided to
defer seeking federal legal intervention.
They maintained that progress would
occur more quickly and be more
productive if the courts and lawyers
were kept out of the matter. Instead
their staff and resources concentrated on
a more "cooperative" effort. This did
not work. Boston's sewer system became
one of the nation's worst violators of the
federal Clean Water Act. It fell behind
its schedules and deadlines for
designing and constructing treatment
plants, sludge management facilities,
and combined sewer overflow facilities,
and the submission of a pretreatment
program.
Today, Boston is the only major city
on the east coast that has not
constructed an advanced (secondary)
sewage treatment plant, and it is the
only major city in the United States
which continues to discharge sludge
through a pipe into a waterway. Boston
has two outmoded and ineffective
sewage treatment plants, serving 43
metropolitan communities.
Each day, those plants discharge
approximately a half billion gallons of
partly treated sewage and approximately
70 tons of sludge into the harbor. The
plants are so limited that their capacity
is exceeded every time a good rain falls;
as a result, millions of gallons of
untreated sewage never make it to the
plants. Instead they exit the system
through some 100 combined sewer
overflows, pipes that act as safety valves
by releasing the excess sewage directly
into the harbor.
A recent preliminary report by the
National Oceanic and Atmospheric
Administration (NOAA), based on 1984
data, shows that of all U.S. ocean sites
the agency tested, the sediment in
Boston Harbor near the Deer Island
treatment plant contains the nation's
highest levels of bacteria from sewage,
toxic PCBs, and pollutants from
incomplete fuel combustion.
The report also shows that winter
flounder caught near the Deer Island
site have the highest concentration of
PCBs and the toxic pesticide DDT in the
livers of any fish tested from North
Carolina to Maine. Half of Boston
Harbor is closed to shellfishing, and
shellfish taken from the other half must
JUNE 1988
be run through a special purification
plant.
Swimming is prohibited at all of the
inner harbor beaches (northwest of
Castle Island). During the summer
season, other beaches within the harbor
For too long, Boston Harbor
has been the backyard in
which nearly half the people
of Massachusetts dump their
waste.
are regularly posted with signs saying
that the water is polluted and
swimming may be hazardous to one's
health. The aesthetic value of the harbor
to fishermen, sailors, picnickers, and
sightseers is significantly impaired by
unsightly floating objects such as grease,
fat, and tampon applicators.
For too long, Boston Harbor has been
the backyard in which nearly half the
people of Massachusetts dump their
waste. But the harbor is, in fact,
Boston's front yard. It is the harbor of
the Bay State's capital city. It deserves
to be a glistening, unsoiled
centerpiece—clean, alive, and accessible
to all. It is unconscionable that city
children cannot enjoy the harbor as an
unpolluted swimming area.
Just prior to this writer's 1983
appointment as EPA's Region 1
Administrator, the Conservation Law
Foundation (CLF), a leading New
England environmental group, filed suit
for violations of the Clean Water Act
against the Metropolitan District
Commission (MDC), the Massachusetts
state agency then responsible for the
Boston-area sewage system, and against
EPA for failing to take enforcement
action against the MDC. It was
dismaying to find EPA a defendant in
this suit; CLF was informed that the
Agency would prepare a major federal
court action to clean up Boston Harbor.
Subsequently, the foundation said it
wanted to go forward in federal court
with EPA as an ally, and would wait a
reasonable time for EPA to prepare the
federal case; the case would be pursued
when EPA filed its own parallel federal
court civil action.
In the meantime, a controversy
erupted concerning what role, if any,
the MDC should play in the harbor
cleanup.
It seemed clear that the MDC had to
be replaced by a new independent,
professional, and adequately financed
sewerage authority with the ability to
generate its own capital and operating
revenue. The Commission had long
been underfunded by the Massachusetts
Legislature. EPA promoted the concept
of an independent authority and
testified in support of state legislation to
create a Metropolitan Water Resources
Authority.
However, the legislation became
stalled in the Legislature. It was
opposed by the 43 MDC member
municipalities because they accurately
foresaw the need for authority to
increase sewer-user charges to pay for
the harbor cleanup.
To prod the Legislature, state Superior
Court Judge Paul Garrity, who had
previously presided over a civil suit by
the city of Quincy against the
Commission for Boston Harbor
violations of the state Clean Water Act,
reinstituted adversary court proceedings
in November 1984 by ordering a sewer
connection ban that would have shut
down most Boston-area development. A
state Supreme Court judge overturned
Judge Garrity's order one week later, but
EPA immediately announced that it was
asking the federal judge to impose the
sewer connection ban, and that the
Agency was filing a federal court action
against the MDC and the
Commonwealth of Massachusetts. Soon
thereafter, the Legislature approved the
creation of the Massachusetts Water
Resources Authority (MWRA).
As a result, EPA dropped its proposed
sewer connection ban, but did file a
federal lawsuit in January 1985 to
obtain a firm clean-up schedule under
the direction of the Federal District
Court in Massachusetts.
In the summer of 1985, Federal Judge
David Mazzone entered judgments
against MWRA, MDC, and the state,
finding them liable for numerous
violations of the Clean Water Act.
Following negotiations among the
parties, Judge Mazzone issued the first
remedial order in late December. The
order contained an interim, three-year
schedule of activities, including
immediate improvements to the existing
Deer Island primary treatment plant.
Subsequent negotiations have led to
the following developments:
• MWRA's withdrawal of its
off-the-New-Jersey-shore sludge
dumping application.
• The final selection of Deer Island for
a $1.5-billion secondary plant, followed
by state legislation to remove the
existing prison on Deer Island.
25
-------
Half of Boston Harbor is
closed to shellfishing, and
shellfish taken from the other
half must be run through a
special purification plant.
These youngsters are among
200,000 people who travel to
Boston's islands by cruise vessel
yearly. Officials expect these
numbers to swell to 600,000 by
the year 2000 when cleanup
efforts, partially directed by EPA,
should turn one of the nation's
most polluted harbors into one
of the cleanest. Greg
Supernovich photo.
• MWRA's agreement to barge
construction materials to the
treatment-plant work-site to mitigate
impacts on the neighboring town of
Winthrop.
• An agreement to end sludge dumping
in Boston Harbor by 1991.
• A court order to complete a new
primary wastewater treatment plant at
Deer Island by 1995, and a secondary-
treatment plant by 1999.
• Plans to construct a 7-to-10 mile
sewage discharge tunnel to
Massachusetts Bay, beyond the harbor.
• The new authority's agreement to
accept responsibility for capturing and
treating sewage from the storm-caused
combined sewer overflows.
More activity has taken place to clean
up Boston Harbor since the lawsuit was
filed in 1985 than occurred in the 20
years prior to the suit. Although other
factors, including the newly created
MWRA and greater public interest have
made major contributions, there is
general agreement that ongoing judicial
supervision of the Boston Harbor
cleanup is needed for the next 10 to 15
years. No one can guarantee that current
good faith efforts will continue in the
absence of such pressure.
EPA is fully committed to the
cleanup. The Agency has assigned
approximately three lawyers and 15
engineers to work on the effort.
In the last two years, the federal court
case has helped in other ways.
Previously, it was difficult to excite
even fishermen, swimmers, and boat
clubs about the harbor pollution.
Generations of people had become so
accustomed to the contaminated harbor,
they simply turned to other natural
areas for recreation or pleasure. But the
federal lawsuit prompted a flurry of
publicity and media attention, which
fostered public outcry and interest.
The battle to end pollution in Boston
Harbor will not be won easily. It will be
expensive; MWRA estimates it will cost
roughly $6 billion and take 11 years, it
is the biggest public works project ever
in New England. Inevitably, the cost
and size of the project will mean
substantially higher sewer bills for
Boston-area people, but that should not
deter them. The cost of not cleaning up
the harbor is the only price the people
cannot afford. It is a harbor of filth.
There is a new recognition that
Boston's special seascape includes
lighthouses, sea gulls, salt marshes, tug
boats, and lobster pots—that Boston is
an ocean city. It is a place where land
and water intermingle, atid where a
person can sit on a peaceful island
while viewing a dynamic city. However,
for the city to be livable, its harbor must
be clean.
What's more, there are economic
incentives as well as moral and
environmental imperatives to clean up
the harbor. A pollution-free harbor will
revitalize the fishing industry and add
vigor to other harbor enterprises,
including ferries, restaurants, offices,
hotels, and homes. It will attract more
people. Officials of the Boston Harbor
Islands park expect 600,000 people to
visit the island parks annually by the
year 2000, up from 200,000 people
annually today. In addition, the
commitment by 2.5 million people to
spend billions of dollars on the harbor
must be rewarded. That means the state
and city must provide sorely needed
open space along the waterfront for
public access.
The regulatory agencies and public
have a responsibility to give a clean and
alive harbor to Boston's people and
generations to come. Boston Harbor can
once again become the crown jewel of
New England—not only a thriving
center of commercial activity, but also a
place to live, work, and enjoy, D
(Delano1 is Administrator of EPA's
Region l.j
EPA JOURNAL
-------
-
'
«•
Tough Choices
Ahead for
a West Coast
Discharger
by Corinne Clawson
A Calico Rock Fish swims in a
forest of sea animals living on
the diffuser section of
northwestern Orange County's
outfall pipe five miles offshore in
the Pacific.
For nearly four decades, the Orange
County Sanitation Districts have been
working to protect public health and the
marine environment through sound
management practices and long-term
planning. But with a booming
population, and increasingly stringent
environmental standards, the districts
are continously facing wastewater
management challenges. With the
expiration of the districts' discharge
permit in 1990, some difficult choices
involving trade-offs among
environmental, financial, social, and
engineering impacts must be made.
These decisions must be made at a
time when public funds are in short
supply, and painful trade-offs are the
order of the day. Resources targeted at
one pressing problem are almost
invariably resources diverted from
another—perhaps equally
pressing—problem. For Orange County,
increased protection of the Pacific
Ocean is a priority, but so is continuing
to protect the county's own land and air
quality. Many believe that upgrading the
ocean would mean downgrading the
land and air.
Serving the 1.9 million residents of
the county's northwestern region, the
Orange County sanitation districts
operate two treatment plants that
process 260 million gallons of
wastewater a day. About 80 percent of
the flow is residential and commercial,
while the remaining 20 percent is
industrial.
The sanitation districts currently
operate under the requirements of an
ocean-discharge permit issued by KI'A
and the California Regional Water
Quality Control Board. Ground-rules for
the permit were set down in a 1977
amendment to the Clean Water Act
known as the 301 (h) provision.
This amendment relaxed 1972
provisions of the Act that had required
full secondary treatment for effluent
from all municipal treatment plants
nationwide, regardless of the receiving
waters. The relaxation resvdted from a
consensus that secondary treatment was
appropriate for inland lakes anil
streams, but the oceans, because of their
tremendous assimilative capacity, were
a different case. Considerable scientific
and technical data supported this belief.
Under conditions of the permit, the
sanitation districts are required to meet
all other environmental protection
regulations imposed by federal and state
agencies and to prove that the marine
environment is not adversely impacted.
The districts achieve the permit
standards by providing advanced
primary treatment to all their flow and
secondary treatment to a little more
JUNE 1988
27
-------
than half their flow. To control toxic
pollutants, they enforce an ordinance
that requires industry to clean up
wastewater before discharging it to a
sewer.
An extensive ocean monitoring
program is another requirement of the
sanitation districts' 301 (h) permit. To
date, the results of the monitoring
program demonstrate that the marine
environment near Orange County has
been adequately protected. Sediment
samples indicate that a balanced
indigenous population exists beyond the
zone of initial dilution surrounding the
ocean outfall pipe. Analyses of fish
tissue samples show that measurable
chemical concentrations are well below
the federal Food and Drug
Administration's standards for edible
fish.
Findings from the monitoring program
will be useful in deciding if the
districts' 1<)8<) application for a permit
renewal will include a request for
another ,'H)l(h) ocean waiver.
Other factors will also impinge on
that decision. Full .secondary treatment
of all wastewater would increase energy
use, air emissions, and the quantity of
sludge that would have to be handled
and disposed of. Higher levels of
treatment would also require larger
facilities, and these would occupy larger
tracts of land within an already
overdeveloped county.
If the sanitation districts' plants were
expanded to provide full secondary
treatment of all their flow, the electrical
energy needed for the added treatment
capacity would nearly double, at great
added expense. To meet the energv
demands, one option would be
increased consumption of fossil fuels.
but burning these; would increase air
pollution. On the other hand, increased
use of hydroelectric power would
threaten the area's inventory of wild
rivers and streams.
The districts currently produce
500.000 gallons of sludge a day. Under
full secondary treatment, even without
including expected increases in future
flows, the districts would significantly
increase their sludge production. That
extra sludge would have to be disposed
of somehow, somewhere. Half of the
districts' sludge is now being trucked to
a landfill, while the other half is used
for beneficial agricultural purposes.
Landfill options, however, are difficult
to come by. and composting facilities
are scarce. As a result of all these
factors, it is a constant challenge to
develop a long-term sludge disposal
plan for northwestern Orange County
that is both environmentally sound and
economically feasible.
Of course, these costs—and their
accompanying damage to land, air, and
inland water resources—must be
weighed against reductions that would
occur in the quantities of solids and
pollutants that are currently being
discharged into the Pacific Ocean. This
brings us to the fundamental question:
What is the optimum level of treatment
needed to protect public health in
northwestern Orange County and still
provide balanced environmental
protection? To help answer this
question, the sanitation districts have
devoted $4.2 million to developing an
unprecedented "Action Plan for
Balanced Environmental Management:
Preserving Orange County's Coastal
Ocean Waters."
The plan, when completed next year.
will bring together all available
scientific and engineering knowledge
regarding environmental impacts.
facilities requirements, social and
economic needs, and the long-term
population trends for Orange County. It
will include such long-range
components as a 30-year facilities needs
assessment and a focused 10-year
construction and financing plan that
will look at needs for facilities under
various treatment and disposal
alternatives. The plan will also address
the feasibility of expanding water
reclamation activities and sludge
recycling.
Two of the plan's components will
have direct impact on decisions
concerning the marine environment
near Orange County. The completed
plan will include an environmental
impact report providing an assessment
of the actions that will be necessary to
give balanced protection to the county's
air. land, and water resources, including
those of the nearby Pacific Ocean. The
results of that assessment will
determine what specific proposals go
into the sanitation districts' next
application for renewal of their
ocean-discharge permit.
While gathering sound scientific data,
the districts are also consulting the
public. A Public Participation Program
has been set up, at a cost of $260,000, to
inform citizens of northwestern Orange
County, and to gain insight into their
concerns and wishes. This program
includes public workshops and hearings
as well as brochures and videos.
There are some very tough decisions
ahead both for residents of northwestern
Orange County and the sanitation
districts that serve them. The decisions
finally reached must balance concern
over the Pacific Ocean with concern for
other components of the environment.
such as land and air quality, and the
financial impact of all alternatives must
be carefully weighed. Li
(CIaivson is a Public Information Officer
for the County Sanitation Oislrirts of
Orange Cotuitv.)
Marine monitoring is part of the Orange County Sanitation Districts' wastewater
treatment plan. Currently operating under a five-year Section 301(h) waiver to the
Clean Water Act, they must weigh and measure fish to monitor population trends near the
outfall. Corinne D. Clawson photo.
EPA JOURNAL
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Where Did
Those Salmon
Go?
by Matthew Coco
Everyone loves a good detective story.
While most whodunits are found in
the pages of paperback fiction, an
investigation into a real life mystery is
under way on the coast of Washington.
Dozens of local, state, and federal
employees are looking for clues in one
of the biggest and strangest
disappearances in Washington State
history.
This is not a typical undercover
caper. The detectives are clad in
hipboots and jeans instead of
trenchcoats and deerstalker caps. Their
search involves not a kidnapped heiress,
but thousands of disappearing subjects.
The subjects of this search are coho
(silver) salmon. The detectives are
fisheries and environmental experts
who are seeking reasons for the
diminished salmon production in one of
Washington's principal river systems.
The Chehalis River, long a major source
of salmon, now has one ol the worst
salmon survival rates in the state.
The Chehalis basin drains into Grays
Harbor, a major estuary on Washington's
southwest coast. It drains a region rich
in natural resources. Timber and fishing
have long been the region's economic
mainstays. Bowerman Basin, at the
southern end of Grays Harbor, has been
proposed as a national bird sanctuary in
legislation pending before Congress. The
Basin is a major stopover for birds
migrating up the Pacific Flyway to
summer nesting grounds north of the
Arctic Circle.
Grays Harbor drains the Chehalis and
the Humptulips River, two principal
river basins south ot Washington's
Olympic peninsula. Fisheries experts
are troubled by the fact that coho from
the Chehalis are surviving at only
one-half the rate of those from the
Humptulips. The "gap" in coho
production between the two streams is
even more striking because the Chehalis
is regarded as superior salmon habitat.
Poor coho survival in the Chehalis
has occurred in the past. Low fish
Coho salmon return to their
place of birth to breed. Then
they die. Gcorcje B. Keie? photo.
U.S. Fish and Wildlife Service.
yields were identified in (lit: mid-1950s.
The problem then was the result of low
dissolved oxygen levels, and was traced
to two wood pulp mills that discharged
into the Chehalis near its mouth. Two
municipal sewage treatment plants also
spilled their effluent into the Chehalis
River in the same vicinity. Since then,
industry and municipal treatment
facilities have invested millions of
dollars in pollution controls. Biological
oxygen demand has been dramatically
improved and salmon runs have
improved in the Chehalis. but the
salmon population, in comparison with
the Humptulips. continues to show-
signs of impaired vitality. The lost value
to the Chehalis fishery is around $1
million annually.
The scientists are not probing a
massive fish kill, where the "villain"
can usually be readily identified.
Instead, they are attempting to
determine the cause or causes of
long-term salmon mortality. The young
fish are evidently beginning their
migration to the sea, but they art; not
returning as adults to spawn in the
freshwater streams where they wore
born. While it is tempting to conclude
that pulp mills and sewage treatment
plants are the culprits, fisheries experts
want a more definitive answer, as well
as greater insight into the physiologic.al
processes governing salmon survival.
Comprehensive studies of salmon,
water quality, and marine life in Grays
Harbor are now under way. These art;
joint undertakings by the Washington
Departments of Fisheries and Ecology,
U.S. Fish and Wildlife Service, EPA
Region 10, and a variety of other
agencies and organizations that arc
providing support services. The Grays
Harbor Regional Planning Commission
functions as a facilitator to marshal!
these agencies and their technical
expertise. Funding has come primarily
from the state legislature, with
additional contributions from I'll'A, the
Grays Harbor Conservation District, and
Weyerhauser and ITT-Kayonirr,
operators of the pulp mills near tin'
mouth of the Chehalis River.
The experts have developed a serins
of hypotheses to be; testeil by
experiments and data analysis:
• Predators are causing salmon
mortality. The study is analyzing both
rivers for squawfish, known predators ot
juvenile saimonids. The fish are
collected by electroshocking. a method
more reminiscent of spv novels than
JUNE 1988
29
-------
*
detective fiction. A specially equipped
boat is used to send an electrical charge
into the river. Stunned fish are then
gathered and the contents of their
stomachs examined for juvenile
salmonids.
Preliminary results of this portion of
the study show a low incidence of
salmonids in the stomachs of the
squaw-fish, indicating that squawfish
predation is not a major factor in the
salmon losses.
• There is something inherent lo the
rearing environment that makes
Chehalis coho less viable than
Humptulips coho. This hypothesis
involves two different possibilities:
either the watersheds produce coho
salmon with differing abilities to
survive in sea water, or there are
pathogens in the Chehalis river that
cause delayed mortality. Both hatchery
and wild salmon from tin; two rivers are
being examined for their ability to
withstand stress. Fish are analyzed for
si/.e, overall health (including the
presence of disease and parasites), and
hormone levels that indicate stress
reactions. Colin will also be placed in
seawater pens to observe their long-term
survivability.
But preliminary results show that the
Chehalis Basin lias excellent rearing
habitat. Coho leaving tributaries to make
their way downstream appear to he at
lea.st as healthy us fish from the
Humptulips,
• There is a difference in water quality
between the Chehalis and Humptulips,
either in the main stem of the Chehalis
or at Inner Grays Harbor. As they near
saltwater in their migration to the sea,
coho normally experience an elevation
in levels of ATP-ase, a hormone that
helps them to acdimati/.e to the new
environment. Scientists want to know
whether water quality changes near the
mouth of the river are affecting the tisb.
Analysis thus far has examined
salmoTi blood chemistry at various
points in the downstream migration
route. A pilot study has already
demonstrated that ATP-ase levels in
Chehalis fish have dropped, not risen,
by the time the salmon reach Inner
Crays Harbor. These data reflect fish
samples taken in the Inner Harbor and
at a location 35 miles upstream, with no
samples taken in-between. The current
study is aimed at determining exactly
where in the river's course the drop in
ATP-ase takes place.
More precise information about the
pace of migration is being gathered
through the use of sonic tags placed in
the gut of the fish before they begin to
swim to the ocean. Information
developed about the speed of migration
and the exact pathway will form the
basis for the showpiece of the entire
analysis, a study using a specially
designed barge with juvenile coho
salmon penned beneath the water. The
barge will attempt to duplicate the
cohos' downstream journey. Fish will be
The young fish are evidently
beginning their migration to
the sea, but they are not
returning as adults to spawn
in the freshwater streams
where they were born.
EPA JOURNAL
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Seining in the Chehaiis River at
Grays Harbor to see what marine
life is present. Blood, livers,
enzymes, and stress levels of
captured salmon are analyzed.
Photo by The Daily World,
Aberdeen, Washington.
sampled for blood chemistry at various
points on the river and the results
compared with water quality readings at
the same locations,
A companion study will collect
effluent from the Aberdeen sewage
treatment plant and the two pulp mills.
Fish will be exposed for up to one week
to different concentrations of these
effluents, mimicking the dilution effect
of river and harbor water. After again
analyzing enzyme and hormone levels,
and the ability of the fish to
osmoregulate (maintain constant
internal levels of salt and water as they
pass from fresh to saltwater), the fish
will undergo a seven-to-nine-month
period in saltwater pens. This phase of
the project will look for delayed
mortality or sublethal effects from the
earlier effluent exposure.
In addition to the salmon studies,
EPA Region 10 is analyzing the
bioaccumulation of toxics in fish and
shellfish at various sites in Grays Harbor
where pollution is suspected.
Scientists hope that the result of al!
this investigative work will be; a clearer
picture of the effects of human activities
on marine life. They also hope to
develop better management of the coho
fishery, and to reclaim this valuable
commercial and recreational resource,
which is so symbolic of the wild and
free waters of the Pacific Northwest, a
(Coco is CongressioFiul Liaison, EPA
Region 10.)
Fisheries biologist Steve
Schroeder, Washington State
Department of Fisheries, using
electro-shock device in the
Humptulips River. The aim is to
stun and check squawfish to see
if they are eating the salmonids.
Photo by The Daily World,
Aberdeen, Washington.
JUNE 1988
31
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EPA Divers:
Getting Down
to the
Nitty Gritty
by Roy Popkin
They tell jokes on themselves: "What's
n large orange monster from the deep
that smells like a hog farm on a hot
summer evening? No, it's not the Loch
Ness monster. It's just another EPA
Region 4 diver completing a routine
operation." Or, "That photo looks
overexposed because it's solid black, but
it really shows EPA divers at work."
Translated, the first "joke" describes
an EPA scientist wearing a dry suit and
full face gear who has just emerged from
a 60-foot, zero-visibility descent into a
six-foot bed of bypassed sewage sludge
during a sediment oxygen demand
study. The second reflects the fact that
over 70 percent of the dives made by
EPA's underwater teams take them into
poor visibility or total darkness created
by sediments, underwater growth, and
pollutants,
From the "Flower Garden" in the Gulf
of Mexico to the polluted bottom of
Boston harbor and Seattle's Puget Sound
and the site of the "Delaware Wreck" in
the Atlantic: Ocean, EPA divers are
doing a job that is far from the glamour
of a Gousteau film or a Barbados TV
commercial. They don't find sunken
treasure or the remains of privateers, but
they do find evidence of illegal
dumping, the impacts of on-shore
pollution, and. in many ways, a
scientific treasure trove.
EPA's divers art! not a separate
organ/.ational unit, although their role
has been formally recognized for at least
10 years. There are a formal certification
and training program, "dive masters" in
a number of locations, and a diving
chapter in the Agency Safety Manual.
Many of the dives made by
EPA's underwater teams take
them into poor visibility or total
darkness. This diving candidate
at Gulf Breeze, Florida, uses a
modified mask that gets its air
supply from the surface. This
type of dry suit has been safely
used in hazardous environments,
such as oil spills. Steve Barsky
photo.
12
EPA JOURNAL
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Currently, there are about 35 men and
women who are EPA-certified divers, an
equal number with equivalent
certification, and arrangements with a
small number of contract divers from
such resources as the University of
Rhode Island. Even though diving is not
an official EPA job category.it is an
important activity performed by EPA
marine biologists, engineers,
technicians, and others whose jobs
require underwater sampling, research,
or exploration. In fact, only one-fourth
of the Agency's divers ever dove for
sport or recreation. Most of them
learned diving skills because they
needed them to better perform their
EPA duties. This year three members of
the Emergency Response Team assigned
to Edison, New Jersey, are being trained
as divers.
Says Jonathan Amson, the dive master
for EPA headquarters and Regions 2 and
3: "EPA diving is hard work; it's not
macho. It's not like sport diving. It's not
playing. You may have six to eight
things to do on the bottom and only 15
minutes in which to do them. It's a
necessary part of the Agency's high
quality science. Fortunately, you can
make a diver out of a scientist even if
you can't always make a scientist out of
a diver."
The divers support a variety of EPA
programs involving ocean dumping,
Section 404 estuary actions, waste
management activities related to spills,
National Pollution Discharge
Elimination System (NPDES) permits,
and technical assistance to states. They
also perform Superfund reconnaissance,
enforcement efforts (where they become
underwater detectives), and the
collection of data for water quality,
oceanographic, and other ecological
surveys. About a quarter of the dives are
done from the EPA Ocean Survey Ship,
the Peter W. Anderson, two to 150 miles
off-shore. And perhaps another 25
percent are inland in rivers, deep lakes,
estuary waters, and quarries—the latter
usually part of Superfund investigations
to determine if drums of toxic wastes
have been dumped there.
According to Amson, who has to
approve all dives planned from the
Anderson, EPA limits diving depths to
130 feet, beyond which decompression
chambers would be required. The
average depth is between 80 and 90 feet,
he says, but Region 4 divers working in
estuaries and shallow harbors often dive
in six to ten feet of water ("sort of like
diving standing on your head").
Perhaps the busiest group is the seven
divers in Region 4. The team is led from
the Athens, Georgia, research laboratory.
Some of them have done over 500
individual dives on EPA missions; the
core group has been diving together
since 1976.
Often called "dean" of the diving
program is Region 4 dive master Don
Lawthorn, an engineering technician
who began diving in 1969, while
working for the Interior Department, but
has never been a recreational diver. He
learned to dive in connection with a
study of effluents from power plants in
the Miami-Fort Lauderdale area. His
deepest dive was 18 miles from Tampa,
in the Gulf of Mexico, where a team of
divers went down over 100 feet to find
flat, ecologically safe areas in which to
dump the product of dredging
operations. One member of that team,
Bruce Reynolds, now stationed at EPA's
Narragansett, Rhode Island, laboratory,
recalls that, in contrast to most dives,
"the water was so clear you could see
other divers 35 yards away and you
could lay out your tools just as you
would in a laboratory."
Diver Phillip Murphy credits "the
uncertainty associated with collecting
bottom samples through remote
devices" as an important factor behind
the creation of the team. Obviously a
water quality model, for example, is
only as accurate as the data input to it.
New and innovative approaches were
developed that required diving for gear
deployment and data collection. Today,
all sediment oxygen demand chambers
in waters deeper than three feet are
placed by diving teams to protect the
integrity of the samples and resultant
models. The lidded chambers used for
sediment samples and monitoring the
rate at which sediment uses up oxygen,
are anchored so they don't leak. Because
each operation involves seven
chambers, attached to 18 cables,
The worst place Reynolds has
worked is the bottom of Long
Island Sound, where heavy
algae growth and sediments
make it so "totally dark you
can't tell whether your eyes
are open or closed."
deploying them is tricky and
necessitates being under water longer
than one can breathe without a mask
and tank. The danger of becoming
entangled in the mass of cables means
the divers work in pairs.
Unfortunately for the divers, such
studies are usually related to the
cleanup of degraded waters. "Dirty
water diving" involves chemical and
biological hazards such as oil/asphalt
spills and bypassed sewage sludge,
physical conditions such as zero
visibility and currents approaching
three knots or more, and a variety of
marine creatures.
Amson provides another insight into
how divers have improved EPA's
underwater science. His first EPA dive,
in 1973, was to place monitoring
equipment in the "Flower Garden," a
coral reef 150 miles southeast of
Galveston in the Gulf of Mexico, for the
purpose of measuring the results of
effluent from the mouth of the
Mississippi River. "In those days," he
says, "there was a lot of trial-and-error
with results that often didn't show what
was needed. Since the diving program
began, we have done innovative things
like using the ship and trailing tape
cameras to study the bottom. We can
track densities and movement of
chemicals because we can return to the
exactly the same place time after time to
monitor the growth or impact of
pollutants on the same groups of
underwater plants, which may be only a
few inches tall."
Dive master Jim Patrick at the Gulf
Breeze Laboratory was another instigator
of the "formal" EPA dive program. "By
1978, there had been a lot of shallow
water diving in the south and up at
Narragansett. Region 4 had a team. The
time seemed right to formalize what was
going on. There was a need to get
serious about it." Patrick contacted
Tony Brown, director of the Agency
safety program, who took steps to set up
an appropriate training program. Now
there are one or two EPA training
programs annually, at Gulf Breeze.
Initially, the training was provided
under a contract with the National
Oceanic and Atmospheric
Administration (NOAA). Now it is
conducted by EPA. Considerable
emphasis is placed on the physics and
physiology of diving, diving into
contaminated waters, and accident
prevention.
Safety is a paramount consideration.
In addition to the 130-foot depth limit,
EPA divers are not allowed to go into
JUNE 1988
33
-------
areas with unknown dangers. In
Superfund investigations, for example, a
remote observation vehicle is often used
first to find out what might be in a
quarry or deep lake. Divers going into
known or suspected pollution wear a
double-lined suit specially developed by
the EPA and NOAA called the "SUS"
(suit under suit). It was designed to
provide maximum protection from
chemicals in the water. Also, a buddy
system is used to protect divers against
being trapped, alone, in the dark.
Patrick himself recalls collecting
samples for a pathologist in a channel at
the bottom of Pensacola Bay. It was
dark, and littered with bridge pilings
and pieces of steel cable. He and his
buddy had to keep each other out of
trouble. Actually, the most serious
accidents to EPA divers have been
ruptured eardrums, but dive master
Dwayne Kama of Region 10, whose
divers work in heavily trafficked Lake
Union and Puget Sound around Seattle,
worries about the danger from boats of
all sizes whose pilots "often ignore our
flags and markings."
On the east coast, EPA divers are
involved in a number of biomonitoring
research projects, in which they test the
effects of pollution on mussels placed in
underwater cages. The divers have to
collect, replace, and otherwise service
the mussels and the cages. They also
collect sediment cores for analysis, as
well as collect worms and small
shellfish with a suction dredge that
works like a small vacuum cleaner.
They dive into extremely polluted areas
like Boston Harbor to study the impact
of pumping sewage into the harbor. The
worst place Reynolds has worked, he
says, is the bottom of Long Island
Sound, where heavy algae growth and
sediments make it so "totally dark you
can't tell whether your eyes are open or
closed."
For other regions he has helped check
the fate of sewage sludge in the New
York Bight, the effluent from a big
chemical plant in Toms River, New
Jersey, and was part of a diving team
that examined a 750- by 150-foot floating
drydock deliberately sunk in 120 feet of
water 30 miles off the Delaware Coast,
at an Atlantic Ocean site informally
known as "Delaware Wreck." The team
studied the wreck to see how the
wooden parts had withstood
submersion, what underwater plants
were growing on it, and whether fish
had turned it into a habitat.
In another unusual east coast project,
Richard Traver, an engineer at the EPA
Releases Control Branch in Edison, New
lersey, is coordinating an underwater
search the Army is conducting in
Chesapeake Bay to locate drums of
white phosphorus dumped by the
Aberdeen Proving Ground in the early
1920s.
Kama heads the only dive team on
the west coast. Its divers, one of whom
is stationed in Alaska, do many
inspections related to NPDES
complaints, generally in locations
around company or publicly owned
treatment works outfalls. They also do a
lot of underwater investigative work for
Superfund and did the underwater
sampling that located hydrocarbons in
Seattle's Lake Union, subsequently
posted as unsafe for swimming and
fishing. They also check for organic
enrichment under floating fish farms in
the area.
The divers frequently participate in
enforcement investigations. Three years
ago, Reynolds was asked to collect
samples off a Rhode Island company's
outfall to see if the company was
dumping pollutants illegally. The
"above water" team included the Rhode
Island state police and state
environmental inspectors. Reynolds and
his colleagues found blasting sand in
the bottom sediments; the company was
ultimately fined for its actions.
There was one Region 10
investigation that could have been
especially dangerous. Although most of
the companies being inspected are
friendly, Kama recalls that in this
instance there was a phone call to the
regional office in which the caller
implied that a lift suspended over the
pier would be dropped on the divers.
The harbor police boat crew working
with the divers donned their guns while
the divers continued below, in muck so
dark they had to hold hands to keep in
contact. They did find, by the gritty
feeling, illegally dumped pollutants.
The company was convicted.
On the lighter side, EPA divers do run
into marine creatures, but to date they
have not caused serious problems.
Murphy reports that a manatee cub once
mistook an EPA diver in a wet suit for
its mother and paired with him until
driven away, and Amson came up from
a dive off the Delaware coast to be asked
if he'd seen a six-foot shark close to
him. He hadn't, even though sharks
were his special interest when he was
in graduate school; the big fish had left
him alone during the dive. EPA divers
checking effluent discharges from a
seafood plant in Petersburg, Alaska.
found a giant octopus living in an
outboard motor casing.
Light moments, however, are few and
far between. Says diver Reynolds,
"Sports divers run around, take
pictures. It's all fun. Research diving
can be dangerous. It's all work ... but
worthwhile." o
(Popkin is a Writer/Editor for EPA's
Office of Public Affairs.)
EPA Diving Training Director Jim
Patrick exits the water during
diver certification training.
Instruction is given in diving
physiology, use of underwater
equipment, and safety
procedures required to monitor
pollution or to document
pollution damage.
34
EPA JOURNAL
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What to Do
With Those
Old Oil Rigs
by Clay Fulghum
What's almost twice as tall as the
Washington Monument, weighs
hundreds of tons, and attracts visitors of
both the two-legged and finned
persuasions?
Actually, the riddle has multiple
answers, all in the form of oil-drilling
platforms, most of them in the Gulf of
Mexico. These platforms, or rigs, as they
are often called, can extend to depths of
1,000 feet and more. They have become
popular gathering spots for a variety of
sea creatures from barnacles to
barracuda—as well as for enthusiastic
sport and commercial fishermen.
The platforms—over 4.000 in U.S. and
state waters—are susceptible to the
ravages of time, not to mention weather.
And not only that. The oil fields
beneath them are being used up. In fact,
over 1,500 platforms will be retired and
dismantled between now and the year
2,000 at a cost that the National
Research Council has estimated at over
$1 billion.
They'll be retired, that is. unless
another use can be found for them.
Enter Villere Reggio, point man for
the Rigs-to-Reefs program of the
Minerals Management Service (MMS),
Department of Interior. He thinks it
would be imprudent at best to scrap the
4,000 acres of marine habitat now
provided by producing platforms in the
Gulf and points to the fact that offshore
oil and gas structures can act as
excellent artificial reefs, attracting
bryozoans, mussels, mollusca,
anemones, sponges, corals, crabs,
shrimp, red snapper, grouper, and
others too numerous to name, to form a
complete food web.
So, Reggio says, take advantage of a
good thing. Instead of paying millions of
dollars to establish artificial reefs out of
other materials, as the United States and
*
other countries are now doing, use the
materials at hand. Make the oil
companies happy, along with
environmentalists, fishermen, and fish.
An easy solution; everybody wins.
Unfortunately, it's not quite as simple
as he suggests; even though the program
is gaining momentum with 10 such
rigs-turned-reefs already in place and
others well on the way to changing from
oil producers to fish habitats.
In fact, it might be argued that
determining exactly how to deal with
aging oil platforms is the really
challenging riddle, and there are a
variety of answers.
Some charge, for example, that
converting oil and gas structure to reefs
is a way for oil companies to avoid
expensive disposal procedures, which
can easily cost $1-4 million per
platform.
Says Sally Ann Lentz, an attorney for
the Oceanic Society: "It's an excuse for
dumping; it's not based on a scientific
need for a structure."
Citing a potential for navigational
hazards that could lead to pollution
incidents, she contends that oil
platforms worldwide should be
completely removed when their useful
This 300-ton oil rig platform was barged from Louisiana to offshore Florida to become an artificial reef. It was placed on its side near
Pensacola about 175-feet deep in the Gulf of Mexico. Not shown, the platform's upper section was placed nearby. Tenneco Inc. photo.
JUNE 1988
35
-------
life is ended, unless there is a
demonstrated need for a reef in a
specific location.
The Department of Defense (DOD) has
similar concerns. "The DOD does not
object to making an oil rig a reef if the
reef is placed where it is not a
navigational problem," says Geoffrey
Greiveldinger, Special Assistant for
Ocean Policy Affairs. "But we don't
want reefs just anywhere, and we don't
want large numbers of them on the
Outer Continental Shelf. Vast numbers
would cause concern."
As a case in point, a West German
submarine last March collided with a
Norwegian platform in the North Sea.
The DOD also expressed national
security reservations, claiming that
enemy submarines could hide in
the rigs-turned-reefs (as they could hide
in producing platforms), escaping efforts
to detect them with SONAR.
Some commercial fishermen, notably
shrimpers, take issue with the
rigs-to-reefs concept too, not just over
the issue of possible obstruction of the
water column but also obstruction of sea
bottoms. They complain that
subcontractors hired by the oil industry
to clean up after a platform removal
don't always do their job.
"We're breaking nets all the time on
equipment that should've been brought
to land and disposed of
properly—pieces of platform,
handrailings, iron doors," said Tee John
Maljevich, President of Concerned
Shrimpers of America. "They don't
remove enough of the garbage for the
bottom to be trawlable."
He's not against converting rigs to
reefs, he says, just against trading
trawlable land, where an artificial reef
might be established, for untrawlable
land where an old platform has been
removed.
Proponents of rigs-to-reefs say,
however, that every effort will be made
not to intrude on shrimpers' trawling
areas when establishing new reefs.
Moreover, federal regulations require
the complete clearing of a site as part of
a removal operation; failure to do so is
illegal.
Conservationists are another group
troubled by the prospect of removing
thousands of oil platforms in the next
few decades—whether or not they're
converted to reefs. They claim that the
explosives used to sever the platform
legs may damage marine life.
Lynn Davidson, marine habitat
coordinator for Greenpeace, says she
began to get calls from Gulf Coast
shrimpers about two years ago telling
her that recent turtle strandings were
not their fault but rather the fault of oil
companies that were tearing down
offshore platforms.
Indeed between March 19 and April
19, 1986, the National Marine Fisheries
Service (NMFS) of the Department of
Commerce verified the stranding of 51
sea turtles, primarily the endangered
Kemp's Ridley turtle, along with 40
dolphins, on beaches of the upper Texas
coast; during the same time period, 22
different explosions took place in
Determining exactly how to
deal with aging oil platforms
is the really challenging
riddle, ana there are a variety
of answers.
adjacent waters. The NMFS reported
"circumstantial evidence suggesting that
at least some of the strandings of marine
animals may have been due to
underwater explosions used to remove
oil platforms."
As a result of this incident MMS now
consults with NMFS before explosions
take place. Attention is also being paid
to appropriate sizing of explosive
charges and monitoring for sea turtles
both before and after demolitions.
The oil companies are attempting to
deal with the "potential" problem of
turtle deaths by alternate means of
severing platform legs—including
cryogenics. But, they argue, given the
current state of technology, almost the
only other option open to them is to
send down a diver with a torch, a
dangerous procedure. Says Michael
Zagata, director of Tenneco Oil
Company's environmental and safety
department: "We don't want to kill
people or turtles."
The oil companies, sea turtle
champions, and others could be
satisfied if platforms were simply left in
place to become fish habitats. There
would be neither disturbance of
biological communities nor removal
expenses. But because the structures
would be potential navigational hazards
and because there are other legal and
liability problems, this option is not
likely to be chosen very often, according
to MMS's Reggio. However, a new
standard is now being negotiated by the
International Maritime Organization, of
which the United States is a member,
which would relax current international
strictures against leaving some large oil
and gas structures at least partially in
place.
But there is another group with
special concerns in the rigs-to-reefs
drama: the sport fishermen. They
perhaps stand to benefit the most from
leaving the rigs in place.
Says Norville Prosser, Vice President
of the Sport Fishing Institute:
"Well-designed, environmentally sound
artificial substrate are very important to
recreational fishing because they attract
fish and increase the biological
community." But in the absence of
management, conflict can occur among
commercial fishermen, recreational
fishermen, and divers. Commercial
fishermen, especially those using very
efficient traps, can virtually eliminate
the fish around a reef, according to
Prosser.
"We've systematically overfished mos
if not all our nearshore finfish stocks of
importance to both recreational and
commercial fishing," he says. "We have
not yet entered the era when marine
fishery management is providing for
conservation of fish stock. We have a
long way to go and a short time to get
there."
Despite the thorny issues involved,
the rigs-to-reefs program is gaining
impetus, and oil platforms will be
joining other artificial reefs off the U.S.
coastline. Both rigs-to-reefs and reefs
composed of other materials were given
a boost when Congress passed the
Fishing Enhancement Act in 1984
establishing standards and requiring
development of a long-term national
plan for artificial reefs.
MMS as early as 1983 announced a
policy encouraging a properly permittee
entity, usually a state, to take
responsibility for turning retired
platforms in state waters into reefs, thus
releasing the oil companies from MMS
regulations requiring them to dispose of
the structures. Disposal typically
involves transporting a structure, often
in pieces, ashore to sell it for scrap.
Several states, including Florida,
Louisiana, and Texas, now have
rigs-to-reefs programs in place or are
actively developing them. Naturally,
reef advocates think this is great.
Tenneco, which has donated two
platforms to the state of Florida, has
gotten hundreds of letters from Florida
citizens offering thanks, he said. "The
public is telling us they (the
rigs-turned-reefs) are valuable." a
(FuJghum is a free-lance writer.}
36
EPA JOURNAL
-------
Air Toxics:
A Headache
for the
Great Lakes
by Jane Elder
Imagine visiting friends in Duluth for a
late summer picnic: a feast ot sweet
corn, raspberries, and fresh lake trout
straight from the cold depths of Lake
Superior. As the plates are passed
around, a woman, obviously pregnant,
passes up the trout. Her surprised host
asks, "Not hungry?" "Yes," she replies,
"but I worry about the PCBs." Her host
protests, "Honey, there's nothing wrong
with that fish. It was caught fresh this
morning." "If it's all just the same." she
answers. "I'll pass."
It's not surprising that our host was a
bit defensive. Lake Superior just doesn't
look like a polluted lake. The water is
clear and cold, and there are few cities
and industries on the shores. Yet even
when discharge from industrial sites
and sewage treatment plants is isolated
or well-controlled, the lakes are still
vulnerable to an onslaught of pollution
from the sky.
Although FOB levels are slowly
declining in all the Great Lakes,
sufficient concentrations are present in
the water and in the food chain to be of
major concern. This spring, the states
warned consumers to avoid eating the
large lake trout (30 inches and up) from
Lake Superior. For the first time, not
even Superior's sparkling waters could
be assumed safe. (Fish advisories for the
other Great Lakes have been issued lor
many years.) People were surprised
because direct discharges of PCBs into
Lake Superior no longer exist. The PCBs
Iniil In lie corning Irom lite air.
Thus, PGB contamination of Lake
Superior fish adds to the growing
concern over the impact ol toxic air
A Great Lakes scene. The
lakes were once thought to be
immune from pollution
effects. Progress has been
made in learning about and
dealing with their
environmental problems. One
of the latest concerns about
the lakes' water quality
centers on toxic air pollutants.
Mike Brisson photo.
JUNE 1988
37
-------
Concerns about toxic pollution
in Great Lakes waters have
been heightened by the effects
on Great Lakes fish.
pollution on the Great Lakes. With the
largest surface area of all the Great
Lakes, Superior is perhaps the most
vulnerable to airborne pollution.
Research dicates that atmospheric
sources are responsible for perhaps 80
percent of the PCBs entering Lake
Superior.
Toxic pollution in the Great Lakes
emanates from many sources, including
direct discharge from waste pipes,
runoff from land, and even from
exchange with contaminated ground
water and lake sediments. However,
growing evidence indicates that airborne
sources may be the single largest
contributor of new toxic pollution to the
upper Great Lakes, and a significant
source—perhaps 20 percent—in the
lower lakes.
Atmospheric contributions to Great
Lakes pollution were first identified in
the late 1970s when land-based sources
of phosphorus couldn't account for total
phosphorus levels in the lakes. The
atmosphere turned out to be the culprit
for a significant portion of the
phosphorus. More troubling was the
discovery of toxaphene in fish samples
in an inland lake on Isle Royale
National Park. Toxaphene was used
primarily as a boll weevil pesticide in
the South and also in stockyards in the
West. It was rarely applied in the Great
Lakes region. Isle Royale, in the
northern reaches of Lake Superior,
could only have been contaminated
through atmospheric inputs.
Furthermore, Isle Royale was not the
only site contaminated in this way.
Today, although banned from use, the
pesticide remains one of the substances
of greatest concern throughout the Great
Lakes.
The huge surface area of the Great
Lakes watershed—94,000 square
miles—provides an enormous catch
basin for rain, snow, and dry
deposition. From lead particles in the
heart of an ice crystal to a chemical
soup in a rain drop, pollutants find
their way easily into the lakes.
Concerns about toxic pollution in
Great Lakes waters have been
heightened by the effects on Great Lakes
fish. Over 25 species of fish are either
banned or discouraged for human
consumption in the Great Lakes.
Concentrations of bioaccumulative
toxics (chemicals that concentrate in
living tissue) are the primary reason for
concern. Bioaccumulative contaminants
in the Great Lakes include PCBs and
dioxin, as well as toxaphene, DDT, and
other pesticides. While many of these
substances are now banned from use in
the United States, they are still present
in the upper atmosphere and continue
to reach the lakes from the sky. Some of
these materials are still used in other
countries or reach the atmosphere
through careless incineration practices.
Thus, they come from sources as nearby
as the local waste incinerator or as far
away as Mexico and Asia.
In addition to contamination of the
food chain, another
phenomenon—widespread evidence of
cancer in fish—has raised concerns.
Some pollutants are not passed up the
food chain, but instead are easily
metabolized by living organisms. PAHs
(polynuclear aromatic hydrocarbons) fall
in this category. One PAH in particular,
benzo-a-pyrene, is a known human
carcinogen also linked to the high
incidence'of fish cancers in the lakes.
PAHs are emitted in numerous
combustion processes and are a
particular concern in coke oven
emissions, for which EPA has recently
proposed new regulations.
In spite of what we are learning about
contaminated food and cancers in fish,
the United States continues to regulate
only a handful of toxic chemicals as air
pollutants. Current regulations address
only seven of the most deadly air
pollutants (over 800 toxic substances
have been identified in trace amounts in
the Great Lakes), and the procedure for
regulating more substances is slow atid
complicated. Currently, EPA must prove
that a chemical is hazardous to human
health from direct exposure before it
can regulate it under the Clean Air Act;
secondary exposures through food and
drinking water are not considered under
regulatory criteria. Thus, hundreds of
toxic air pollutants that endanger
human health and the environment go
unregulated in the United States,
whereas Ontario, for example, regulates
almost 100 toxic air pollutants.
These problems are not unique to the
Great Lakes. As one of the world's more
studied ecosystems, however, the Great
Lakes often indicate the emergence of
new environmental problems first.
By and large, what goes up must
come down. Each year, millions of tons
of toxic pollutants go up into the
atmosphere from tall stacks, tail pipes,
open factory vents, evaporation from
waste ponds and landfills, and many
other sources. Every day, untold tons of
toxics mix in the atmosphere or fall
back down to earth in the form of rain,
snow, or dry deposition. And so we live
with them every day in our lungs and
tissues, in the water we drink, and in
the fish we eat. Airborne toxics present
the Great Lakes region and the nation
with important environmental and
public health problems which need to
be faced and resolved, o
(Elder is the Midwestern Representative
for the Sierra Club.)
Editor's note: In November, the U.S. and
Canada signed a series of annexes and
amendments to the 1978 water quality
agreement to protect the Great Lakes.
Annex 15 of the agreement focuses
specifically on toxic air pollution and
both countries pledged to develop
control programs for persistent toxic
substances which reach the Great Lakes
from airborne sources.
38
EPA JOURNAL
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On Another
Subject:
To Eat or
Not to Eat
by Carole Sugarman
'
USDA photo.
Amazing how eating strawberries may
both prevent cancer and cause it.
Same for eating cabbage, broccoli, and
carrots. At least that's the conclusion
one can draw from two new books—one
of which raises fears that certain foods
contain disease—causing pesticides, the
other that raises hope that some of those
same foods may combat illness.
It's enough to drive you to drink.
(Which, of course, may either help your
heart or cause cirrhosis.)
"Pesticide Alert: A Guide to
Pesticides in Fruits and Vegetables," by
Lawrie Mott and Karen Snyder (Sierra
Club Books, $6.95), discloses that
pesticide residues were found more
often on strawberries than any other
fruit or vegetable listed among the 26 in
the book. One of the pesticides used on
strawberries is a "probable human
carcinogen," according to the authors,
and there is "some evidence of
carcinogenicity" with another chemical
used on the fruit.
Flip to page 282 of "The Food
Pharmacy: Dramatic New Evidence that
Food is Your Best Medicine." by Jean
Carper (Bantam, $18.95). One of the
"possible therapeutic effects" listed for
strawberries is that the fruit has been
linked to lower rates of cancer deaths.
Carper cites Italian jnvestigator.s who
have recently noted that strawberries
can block the formation of
cancer-causing nitrosamines in the
intestinal tract. Strawberries also capped
a list of eight foods most linked to lower
rates of cancer deaths among a group of
1,271 elderly individuals in New Jersey,
Carper adds.
The books are written in similar
formats—alphabetized guides to foods
from apples through watermelon (yogurt
in Carper's case) and their risks (Mott)
or benefits (Carper). Both books are
written by reputable individuals well
known in their fields. Mott, a senior
staff scientist with the National
Resources Defense Council, is a leading
environmentalist who regularly testifies
in Congress for stronger pesticide laws.
Carper, a former senior medical
correspondent for CNN, is the author of
15 nutrition and health guides.
Yet the books come to opposite
conclusions. Whom, then, does a reader
believe? Is the risk of eating produce
greater than the risk of not eating it? Are
organically grown fruits and vegetables
the only answer?
It's a conundrum, this modern
dilemma caused by science's ability to
detect minute amounts of pesticide
residues or natural chemicals in foods.
Channeling this data to the supermarket
shopper is even a trickier business,
since scientific findings don't
necessarily translate into practical
information.
But consumers want answers. They
want to know whether to buy
strawberries or to ban them. They want
magic bullets, yes-or-no responses.
Unfortunately, there aren't many.
In this context, neither book should
be taken to its practical extreme. That
means that foods such as strawberries
shouldn't be eliminated from the diet,
nor should shoppers buy them up like
loaves of bread before a snowstorm.
Rather, readers should realize that
both authors have to overestimate their
case, making logical leaps based on
inconclusive information, simply to
make a point. The specifics are not as
important as the residual message.
For Carper's book, the message is that
science is on the threshold of some
pretty provocative findings in regard to
food as medicine. For Mott's book, it is
that there are serious flaws in the way
that pesticides are regulated and that
consumers' power in the marketplace
could be the driving force behind
change.
Realize, also, that while both books
rely on facts, their prescriptions are a
matter of each author's own view of
risk.
Carper admits that her book is on the
"revolutionary side of conventional
nutrition," but that "clues, as we know
from the past, often precede by decades
establishment blessings, and waiting for
more knowledge can he a mistake." For
Carper, there is little risk in eating foods
such as apples, kale, and garlic even if
they don't end up preventing any
diseases. What we don't know can't hurt
us.
Mott does not suggest that consumers
stop eating fresh produce, but she does
suggest that they wash all produce, pwil
it when appropriate, grow their own
food or consider buying organically
grown. Many of her fears seem to center
around a lack of information on
pesticide residues—"unfortunately, the
overwhelming majority of pesticides
used today have not been sufficiently
tested for their health hazards," she
writes. For Mott. what we don't know
can hurt us.
We live in a world of risks. That
doesn't mean we can't or shouldn't do
everything we can to reduce them.
But in the meantime, enjoy the
strawberry season. Just go easy on the
whipped cream, Q
(Reprinted with permission from The
Washington Post.)
JUNE 1988
39
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Appointments
by Andre Freeman
|ohn Arthur Moore has been
named Deputy Administrator
of EPA. replacing A. James
Harnes who will be leaving
the Agency this month.
Since 1983, Dr. Moore has
served EPA as Assistant
Administrator, Office of
Pesticides and Toxic
Substances. In that capacity
he was responsible for
administering the Toxic
Substances Control Act and
the Feeler;) 1 Insecticide,
Fungicide, and Rodenticide
Act.
Before joining EPA.
Moore spent 1969 to 1983
working at the National
Institute of Environmental
Health Sciences. Thorn he
served as Associate Director
of Research Resources, and as
Director of Toxicology
Research and Testing
Program; and then Deputy
Director, National Toxicology
Program. From 19(>3-19(>9 Dr.
Moore was Assistant
Director, School of Medicine,
at Western Reserve
University and later became
Assistant Professor at
Michigan State University in
the department of Veterinary
Surgery and the Center for
Laboratory Animal
Resources.
Among his many honors
and achievements, Moore
received the Honorable
Presidential Rank
Award—Distinguished
Executive of 1986.
Martha G. Prothro has
recently been named
Director, Office of Water
Regulations and Standards,
Office of Water.
Prothro joined EPA in
August of 1973, as a staff
attorney, Enforcement
Proceedings Branch. Division
of Stationary Source
Enforcement, Office of
Enforcement. Until 1980, she
worked with the stationary
source air enforcement
program, serving as a Section
Chief beginning in October
1975, and as Chief of the
Enforcement Proceeding
Branch from January 1977 to
March 1980, when she
became Director of the Noise
and Radiation Enforcement
Division. From April 1981
until her recent appointment,
Prothro served as Director,
Permits Division, Office of
Water Enforcement and
Permits.
Elaine G. Stanley was
recently appointed to the
position of Deputy Director,
Office of Waste Programs.
Office of Solid Waste and
Emergency Response
(OSWER). Stanley's duties
will include assisting in
implementing the solid waste
and emergency remedial
response enforcement
policies for the Superfund
and Resource Conservation
and Recovery Act (RCRA).
From April 1987 to July
1988, Stanley was the
Director of the RCRA
Enforcement Division in the
Office of Waste Programs
Enforcement. She was
responsible for the National
Program of Compliance and
Enforcement under RCRA.
Prior to that assignment,
Stanley served as the Deputy
Director of the Hazardous
Site Control Division which
was responsible for managing
the billion-dollar, long-term
site cleanup program under
Superfund. From 1981 to
1986, she served as a Special
Assistant to the Director of
OSWER. In that capacity, she
provided advice and analysis
on legislation, program
management, and external
affairs issues. Stanley was a
key manager of the effort to
re-authorize the Superfund
legislation in 1985-1986, as
well as overseeing initial
efforts at its implementation.
C. Marshall Cain has been
named Deputy General
Counsel for Litigation.
Legislation and Regional
Operations.
Cain was a trial lawyer for
the law firm of Richardson,
Plowden, Grier, and Howser
in Columbia, South Carolina,
from 1984 until the time of
his appointment as Deputy
General Counsel.
From 1981 to November
1984, he served as Deputy
Assistant Attorney General in
the office of Legislative
Affairs at the Department of
Justice. During the 21-year
period that Cain practiced
law, he served eight years in
the state legislature and two
years as Executive Assistant
to the Governor.
William Farland has been
named Director, Office of
Health and Environmental
Assessment (OHEA), in EPA's
Office of Research and
Development.
In 1979 Dr. Farland came
to Washington on a joint
appointment with George
Washington University
Medical School and EPA's
Office of Toxic Substances
(OTS). Among a number of
positions at OTS, Farland
served as the Deputy Director
of the Health and
Environmental Review
Division, with major
responsibilities for assessing
the effects of new chemical
substances.
In 1986 Farland was
appointed Director of the
Carcinogen Assessment
Group in OHEA, while
serving at the same time as
Acting Director of the
Reproductive Effects
Assessment Group. He was
also appointed a charter
member of the EPA's Risk
Assessment Forum. From
October 1987 to July 1988,
Farland served as the Acting
Director of OHEA. a
(At press time, it was also
announced that Victor J.
Kimm, Deputy Assistant
Administrator for Pesticides
and Toxic Substances, would
be Acting Assistant
Administrator, replacing
Moore. Susan Vogt, Deputy
Director of the Office of
Toxic Substances, would be
named Deputy Assistant
Administrator. Reports on
these shifts will be in the
next Journal.)
(Freeman fs on intern /or
EPA Journal.)
.10
EPA JOURNAL
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And that is that!
Raymond Muzika photo.
Back Cover: A lot of us are here!
Aerial view of Cape May. In spite
of population growth along the
Cape May shore, officials there
are proud of the fact that the
area hasn't had the pollution
washups troubling some
beaches in northern New Jersey
and New York. Popularity and
population pressures are fast
becoming an environmental
challenge along the U.S. coasts.
It is estimated that by 1990,
more than 70 percent of our
entire population will live within
50 miles of the nation's
coastlines, including the Great
Lakes. Photo by Bill Weems,
Woodfin Camp, Inc.
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