OCEAN DUMPING IN THE
UNITED STATES-1975
Third Annual Report
of the
Environmental Protection Agency
on Administration
of Title I
-------
OCEAN DUMPING IN THE
UNITED STATES-1975
Third Annual Report
of the
Environmental Protection Agency
on Administration
of Title I
Marine Protection, Research, and Sanctuaries
Act of 1972, as amended
JUNE 1975
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Water and Hazardous Materials
Washington, D. C. 20460
-------
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JUL S 0
THE ADMINISTRATOR
Dear Mr. President: *
The Marine Protection, Research, and Sanctuaries Act of
1972, as amended, requires an annual report from the
Administrator of the Environmental Protection Agency on his
administration of the ocean dumping permit program authorized
under the Act. The third annual report for this program is
transmitted with this letter.
The ocean dumping permit program became effective
April 23, 1973; final regulations and criteria were published
October 15, 1973. This report covers activities during fiscal
year 1974.
Sine
Ru
Honorable Nelson A. Rockefeller
President of the Senate
Washington, D.C. 20510
Enclosure
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JUl 3 0
THE ADMINISTRATOR
Dear Mr. Speaker:
The Marine Protection, Research, and Sanctuaries Act of
1972, as amended, requires an annual report from the
Administrator of the Environmental Protection Agency on his
administration of the ocean dumping permit program authorized
under the Act. The third annual report for this program is
transmitted with this letter.
The ocean dumping permit program became effective
April 23, 1973; final regulations and criteria were published
October 15, 1973. This report covers activities during fiscal
year 1974.
Honorable Carl B. Albert
Speaker of the House
of Representatives
Washington, D.C. 20515
Enclosure
-------
TABLE OF CONTENTS
Page No.
I. Introduction and Summary 1
n. Permit Operations 5
EH. Analysis of Existing Dumping Activity 23
IV. Baseline Survey Program 33
V. EPA Research Program 41
VI. Dredged Material Disposal 47
VII. Ocean Incineration: A New Technique 51
in Ocean Disposal
Public Participation in the Program 55
IX. The Future of Ocean Dumping as a 57
Means of Disposal
-------
LIST OF TABLES
Table No. Title Page No.
1. Permits in Force During Calendar Year 1974
Region I 10
Region II 10
Region m 17
Region VI 17
Region EX 18
Headquarters 18
2. Permits Denied and Dumpers Phased Out 19
During 1974
3. Ocean Dumping Violations Referred to EPA 20
4. Ocean Disposal: Types and Amounts, 24
1974 and 1973
5. Annual Inputs of Mercury and Cadmium 26
Due to Ocean Dumping Off the Atlantic
Coast
6. Barges Authorized for Ocean Dumping 28
7. Barge Trips for Ocean Dumping 31
8. Dredged Material Dumped in the Ocean -1974 48
LIST OF FIGURES
Figure No. Title Page No.
1. Permit Procedures 7
2. Inter-Regional Permits 8
vi
-------
I. INTRODUCTION AND SUMMARY
This is the third annual report of the Environmental Protection
Agency (EPA) to the Congress on the implementation of Title I
of the Marine Protection, Research, and Sanctuaries Act of 1972,
as amended, (referred to in this report as "the Act"). The Act
became effective April 23, 1973, and since that time all ocean
dumping of waste materials transported for the purpose of dumping
has been done under permit from EPA except for dredged material,
which is regulated by the Corps of Engineers.
When the program was first initiated many procedural and
technical decisions had to be made on an interim basis because
of the need to implement the Act rapidly and the general lack of
specific knowledge of the impact of ocean dumping on the marine
environment. It was also apparent that the widespread practice
of ocean dumping, which had been going on for many years, could
not be stopped instantaneously without allowing time for the develop-
ment of acceptable alternatives. During the two years since the
Act became effective, the interim procedures and criteria have
been replaced by improved regulations and criteria, better laboratory
methods of analysis have been developed, a program of baseline
surveys has been initiated, and many dumpers of toxic wastes
have been phased out or are on firm implementation schedules.
This annual report covers the second full year of regulation
of ocean dumping by EPA under Title I of the Act, and it offers
the first opportunity to make quantitative comparisons of how ocean
dumping has changed since the Act became effective.
Eleven ocean dumping sites in the Atlantic Ocean and the Gulf
of Mexico are now in active use for municipal and industrial wastes.
There is no dumping of these wastes in the Pacific, although
municipal sewage sludge is discharged to the ocean through out-
falls. These discharges are regulated under the permit system
of the Federal Water Pollution Control Act Amendments of 1972.
Ocean dumping site surveys are being conducted on three sites,
and additional surveys are due to begin this year. These surveys
are designed to provide the scientific data for Environmental
Impact Statements (EIS) to be prepared for each dumping site
designated on other than an interim basis and to determine as
the basis for dumps it e management the effects of disposal in the
oceans of a variety of wastes. Regulations for the designation
and management of ocean dumping sites are being developed and
will include the requirements for baseline and trend assessment
surveys, and an interagency agreement concerning cooperative
-------
efforts in such surveys has been developed with the National
Oceanic and Atmospheric Administration (NOAA) . A detailed
baseline survey is currently being conducted in the New York
Bight for an alternate site for sewage sludge disposal. EPA is
also studying and evaluating two dump sites, one industrial and
one municipal, off Delaware Bay, and is cooperating with NOAA
in studies of a deepwater site off the continental shelf east of Cape
Henlopen, Delaware. The Corps of Engineers has underway a
five-year dredged material research program which will provide
information to assist EPA in revising the dredged material criteria.
In addition, results of the Corpssponsored studies will give EPA
a better data base from which to evaluate dredged material disposal
sites.
Theee studies are being supplemented by EPA research
activities including conducting investigations into ecological
processes and effects of ocean dumping.
Ocean dumping activity shows a net increase in ocean dumping
of about 1.6 million tons from 1973 to 1974, excluding dredged
material. This net increase is the result of an increase in dumping
of construction and demolition debris of about 1.1 million tons
combined with a slight overall increase in dumping of both in-
dustrial wastes and sewage sludge over the same period. However,
during the coming year, EPA expects to phase out many industrial
dumpers as alternate methods of disposal are developed and
implemented. Based on existing permits and permit applications,
there should be no dumping in the Pacific Ocean, and dumping
in the Gulf of Mexico should be about 10 percent of the 1973 level.
All dumping of municipal sewage sludge originates in the
New York and Philadelphia metropolitan areas, and the volume
dumped increased slightly between 1973 and 1974. This was due
to the increase in the volumes of sewage treated and the upgrading
of some municipal sewage treatment plants.
Surveillance of dumping activities is assigned by the Act to
the Coast Guard. The Coast Guard's enforcement program is
keyed to close surveillance of the disposal of toxic materials
with spot-checks of non-toxic material dumps.
All violations of permit conditions and illegal dumping
reported to EPA are subject to enforcement action through the
assessment of civil penalties, and, where necessary, criminal
proceedings. From April, 1973 to December, 1974, there were
983 ocean disposal surveillance missions undertaken by the
Coast Guard; 36 violation notifications were referred to EPA.
-------
These were all investigated. Letters of warnings were issued
and formal enforcement actions were taken.
The past year has seen the first use in the United States of
a technique in ocean disposal commonly used in Europe for the
past few years. This is ocean incineration, and it is useful for
the disposal of toxic wastes with a high caloric value. Last
October a specially designed incinerator ship capable of burning
4,200 tons of chemical wastes per mission, incinerated organo-
chlorine wastes with greater than 99.9 percent efficiency at a
site 143 nautical miles south of Galveston, Texas. These wastes
are highly toxic and could not be dumped directly into the marine
environment. Incineration converted these wastes to hydrogen
chloride and carbon dioxide in quantities innocuous to the oceans
and the atmosphere.
The major problem in the future is anticipated to be increased
pressure to dispose of wastes in the ocean which result from
more and better waste treatment facilities removing increased
amounts of wastes from both municipal and industrial waste
streams. The basic EPA approach has been to attempt to find
and use the least environmentally damaging site and method of
disposal for each waste whether it involves land, air, or water.
Much additional study is needed on all disposal methods, in-
cluding land disposal and incineration as well as ocean dumping,
before the state of the art will be sufficient to allow the selection
of the best environmental alternative in all cases.
-------
H. PERMIT OPERATIONS
The Act absolutely prohibits the dumping of high-level radioactive
wastes and all biological* chemical, and radiological warfare agents
in the ocean. The dumping of all other wastes, except dredged
material, is to be strictly regulated by EPA. The basis for
regulation is given in the form of general criteria which require
EPA to balance the following factors in coming to a determination
whether to issue or deny a permit:
1. The need for the proposed dumping, as determined by
EPA.
2. The effect of the dumping on the marine environment.
3. Social and economic considerations involving the dumping,
including effects on health and welfare, fishery resources,
recreational values, etc.
,4. Alternate means of disposal, including alternate methods of
treatment, land-based disposal, and recycling.
5. The feasibility of dumping beyond the continental shelf.
These same criteria apply to the issuance of permits under
Sections 402 and 403 of the Federal Water Pollution Control Act
Amendments of 1972 for outfall discharges into the ocean.
To carry out this responsibility, the Administrator of EPA is
authorized to promulgate regulations, designate areas where ocean
dumping may be permitted, and designate critical areas where
dumping is prohibited. EPA must also give public notice and allow
opportunity for public hearing before any permit is issued.
Dredged material may be dumped by the U. S. Army Corps of
Engineers permittees after the proposed permit has been reviewed
and agreed upon by EPA. In issuing such permits the Corps is
required to use EPA-designated sites wherever feasible, but the
Corps may use other sites if they determine that disposal at the
EPA sites is not economically feasible and EPA grants a waiver.
EPA must grant a waiver within 30 days unless it makes the deter-
mination that such disposal will have an unacceptable adverse effect
on the environment.
Responsibility for surveillance of dumping operations to ensure
that permit conditions are met is assigned to the U. S. Coast Guard.
EPA, however, has the authority to assess civil penalities for
-------
violation of permit conditions. There is also a provision for criminal
action,
Title n of the Act requires NOAA to conduct a comprehensive
program of research and monitoring regarding the effects of the
dumping of material into ocean waters. Title m gives to NOAA
authority to establish marine sanctuaries.
Figures 1 and 2 show the procedures used by the EPA Regional
offices in processing permit applications.
Section 220.3(d)(2) of the Ocean Dumping Final Regulations
and Criteria specifies that an "interim permit will require the
development and active implementation of a plan to either elimi-
nate the discharge entirely from the ocean or to bring it within
the limitations of..." the ocean dumping criteria. The expiration
date of an interim permit is determined by completion of sequen-
tial phases of the development and implementation of the required
plan and does not exceed one year from the date of issue. An
interim permit may not be renewed, but a new interim permit
may be issued upon satisfactory completion of each phase of the
development and implementation of the plan.
A survey of the EPA Regional offices indicates that those
previous permittees who have been required to phase out ocean
dumping during 1974 have found many alternate methods of dis-
posal, such as deep well injection, land incineration, landfill,
storage, recycling, and industrial waste treatment, such as
neutralization, biotreatment, and carbon adsorption.
Other permittees who are on current implementation plans
are examining these and other alternatives to ocean disposal.
In some cases the permittees have presented draft implementation
plans to the Regional offices containing alternatives to ocean dis-
posal not environmentally acceptable to EPA. These permittees
have been requested to review again the alternatives available to
them and report back to the region.
In July 1974, Region n initiated a comprehensive sludge
management program for the New York-New Jersey metropolitan
area designed to select environmentally acceptable alternatives for
ultimate disposal of sewage sludge. The overall program considers
three aspects of the problem: (1) state of the art of alternatives
to ocean dumping of sewage sludge; (2) an in-depth study of a
selected number of the most environmentally acceptable alterna-
tives i and (3) recommendations for a legal-institutional sludge
-------
APPLICATION SUBMITTED
TO REGION
PRELIMINARY EVALUATION OF APPLICATION
PUBLIC NOTICE QF APPLICATION WITH TENTATIVE DECISION
TENTATIVE DECISION TO ISSUE TENTATIVE DECISION TO DENY
REQUEST FOR HEARING
HEARING
N
I FINAL EVALUATION. OF APPLICATION |
ISSUANCE OF PERMIT
DENIAL OF PERMIT
NOTIFICATION
OF COAST GUARD
SURVEILLANCE
MONITORING OF DUMP SITE]
ENFORCEMENT ACTION
FIGURE 1. PERMIT PROCEDURES
-------
Application Submitted to
Initiating Region
Technical Evaluation
of Need and Alternatives
by Initiating Region
Initiating Region Forwards
Application and Technical Evaluations
with Recommendations for
Issuance or Denial of Permit
Site Region Evaluates
Impact of Proposed Dumping
on Site
Disposal Site Region
Forwards Application with
Impact Evaluation with
Recommendations for
Issuance or Denial of Permit
to Headquarters
Headquarters Reviews Information
from both Regions and Makes
Tentative Determinations
for Issuance or Denial of Permit
Public Notice is given in
both Regions with Opportunity
for Hearing in both Regions
Recommendations Forwarded
to Administrator
Final Action by Administrator
FIGURE 2. INTER-REGIONAL PERMITS
-------
management system. During 1974, preliminary investigations
were completed on amounts and types of municipal wastes presently
generated and projected future volumes. A general survey of
major alternatives to ocean dumping of sewage sludge was also
completed. This study has the support of all municipal sewage
sludge authorities in the area and will be continued with a target
date for completion and final report in late 1975.
Region HI, in issuing an interim permit to the City of Phila-
delphia in February of 1974, required them to identify sources of
heavy metals to determine whether they should be required to
eliminate ocean dumping entirely or whether the sewage sludge
could be brought within the limitations of the criteria. The interim
permit issued to Philadelphia in February of 1975 is currently under
review by the EPA Administrator.
Table 1 lists by Regional offices those permits in force during
1974, the type of permit, the material dumped, the date the most
current 1974 permit was issued and expires, and the maximum
quantity of waste allowed to be dumped under the permit.
Table 2 lists by EPA Regions those permits denied and dumpers
phased out during 1974. It should be pointed out that prospective
applicants are often encouraged by Regional personnel to seek alter-
natives to ocean disposal; these companies do not appear on the
"Permits Denied" list since they have not actually filed an appli-
cation or gone through the steps prior to issuance or denial of a
permit.
Title I of the Act provides that the Coast Guard shall conduct
surveillance and other appropriate enforcement activity to prevent
unlawful transportation of material for dumping, or unlawful
dumping.
The Coast Guard's enforcement program is keyed to close
surveillance of the disposal of industrial waste materials and spot
checks of sewage sludge and dredged material disposal. Surveil-
lance methods include escorting or interception of dumping vessels
at the dump site by vessels or aircraft, spot checks of ships' logs,
and the use of ship-riders to ascertain position and dumping rate.
From the inception of the program in April, 1973 to December,
1974, there were 983 ocean disposal surveillance missions; 36
violation notifications have been referred to EPA encompassing
154 apparent violations. Table 3 summarizes these violations.
The large number of violations in the category of dumpers1 failure
to notify the Captain of the Port (COTP) is apparently due to a
problem of communications and bookkeeping involving the
-------
TABLE 1
PERMITS IN FORCE DURING CALENDAR YEAR 1974
Max. quant.
Applicant /Type Permit
Region I
Safety Projects & Eng.
special
Pine State By-Products
special
McKie Co.
emergency
Material
Dumped
misc. lab
reagents
wash -down
water
scrap ferrous
metal trimgs.
Date
Issued
11/20/73
4/04/74
4/22/74
Date
Expired
11/15/74
1/13/75
5/20/74
Allowed Under
Permit
5, 500 gal.
180,000 gal.
3, 500 T
Region n
Middletown Sewerage Auth.
interim
Passaic Valley Sew. Auth.
interim
Middlesex Co. Sew. Auth.
interim
Modern Transp. Co.
interim
Bergen Co. Sew. Auth.
interim
Linden Roselle Sew. Auth.
interim
Joint Meeting of Essex &
Union Counties
interim
Borough of Fairfield
interim
City of Long Beach
interim
sewage sludge 4/15/74 4/14/75 4,276 c.y.
11 " " 672,222 c.y.
" " " 422,805 c.y.
" " 471,111 c.y.
" " " 294,000 c.y.
11 " " 240,288 c.y.
11 " " 160,333 c.y.
" " " 4,741 c.y.
. " . " 15,012 c.y.
10
-------
TABLE 1 (CONT'D)
PERMITS IN FORCE DURING CALENDAR YEAR 1974
Applicant/Type Permit
County of Nassau
interim
County of Westchester
interim
West Long Beach Sew. Dist.
interim
City of NY-Wards Island PI.
interim
City of NY-Hunts Point PI.
interim
City of NY-26th Ward PL
interim
City of NY-Coney Isl. PI.
interim
City of NY-Owls Head PL
interim
City of NY-Newton Creek PL
interim
City of NY-Tallman Isl. PL
interim
City of NY-Bowery Bay PL
interim
City of NY-Rockaway PI.
interim
City of NY-Port Richmond PI.
interim
City of NY-Jamaica PI.
interim
Material
Dumped
Date
Issued
Date
Expired
sewage sludge 4/15/74 4/14/75
Max. Quant.
Allowed Uhdei
Permit
672,600 c.y,
95,250 c.y,
1,852 c.y,
455,779 c.y
309,247 c.y
321,363 c.y
247,117 c.y
427,561 c.y
1,181,064 c.y
92,530 c.y
481,402 c.y
55,112 c.y
66,304 c.y
365,965 c.y
11
-------
TABLE 1 (CONT'D)
PERMITS IN FORCE DURING CALENDAR YEAR 1974
Applicant/Type Permit
City of Glen Cove
interim
Whippany Paper Board Co.
interim
Wm. Schaefer Septic
interim
Caldwell Trucking Co.
interim
American Cyanimid (Ag.
Div.)
interim
Modern Transp. Co.
interim
S. B. Thomas, Inc.
interim
A&S Transp. Co.
interim
American Cyanimid
interim
Allied Chemical
interim
Upjohn Mfg. Co.
interim
DuPont-Grasselli
interim
Material
Dumped
Date
Issued
waste acti-
vated sludge
sewage sludge "
& septic tank
wastes
sewage sludge "
& septic tank
wastes
waste acti- "
vated sludge
digester
cleanout
bakery "
waste sludge
9/01/74
chem. wastes 7/15/74
digester
cleanout
by-product 10/31/74
hydrochloric
acid
pharmaceu- 9/15/74
tical wastes
Date
Expired
sewage sludge 4/15/74 4/14/75
7/15/74 7/14/75
Max. quant.
Allowed Under
Permit
15,000 c.y.
91,250 c.y.
10,400 c.y.
41.500 c.y.
1,300 c.y.
9/1/74 8/31/75 13.200,000 gal.
1,082,250 gal.
12/31/74 1.000.000 gal.
7/14/75 36,500,000 gal.
7/14/75 26,133, 000 gal.
9/14/75 27,375, 000 gal.
ind. wastes 10/31/74 7/14/75 185,000,000 gal.
12
-------
TABLE 1 (CONT'D)
PERMITS IN FORCE DURING CALENDAR YEAR 1974
Applicant/Type Permit
Merck & Co.
interim
Chevron Oil Co.
interim
Abbott Chemicals
interim
NL Industries
interim
Mo ran Towing Corp.
special
Pfizer Pharmaceuticals
interim
Merck, Sharp & Dohme
interim
Amerada Hess Corp.
interim
Oxochem Enterprise
interim
Puerto Rico Olefins
interim
Sherwin Williams Co.
interim
Sobin Chemicals Inc.
interim
Material
Dumped
pharmaceu -
tical wastes
refinery
wastes
pharmaceu -
tical wastes
spent sulfate
sol.; inert
ore slurry
cellar dirt
construction
rubble
pharmaceu -
tical wastes
pharmaceu -
tical wastes
Date
Issued
Date
Expired
Max. Quant.
Allowed Under
Permit
7/15/74 7/14/75 5,100,000 gal.
10,950, 000 gal.
9/15/74 9/14/75 1,440,000 gal.
10/31/74 7/14/75 675, 000,000 gal.
5/15/74 5/14/75 14,580, 000 c. ft.
9/15/74 9/14/75 2,500,000 gal.
25. 583,000 gal.
spent caustic 7/15/74 7/14/75 3,239,100 gal.
oxo-alcohol
wastes
petroleum
processing
wastes
paint mgf.
wastes
salicylalde -
hyde mfg.
wastes
9/15/74 9/14/75 26,334, 000 gal.
2,412, 000 gal.
7/15/74
7/15/74
7/14/75
28.000 gal.
7/14/75 2,000,000 gal.
13
-------
TABLE 1 {CONT'D)
PERMITS IN FORCE DURING CALENDAR YEAR 1974
Applicant/Type Permit
International Wire Prod.
interim
Water Tunnel Contractors
special
Mycalex Corp.
interim
Arrow Group Industries
interim
Howmet Corp.
interim
Worthington Biochemical
interim
Reheis Chem. Co.
interim
Material
Dumped
Date
Issued
sludge from 7/15/74
wire drawing &
plating proc.
blasted tunnel 5/15/74
rock
water slurry 7/15/74
of inert glass
sludge from 7/15/74
galvanizing &
plating opera-
tions
liquid waste "
from mfg. of
micro-castings
enzyme extrac- "
tion & fermen-
tation wastes
pharmaceu- 10/31/74
tical wastes
Bristol Alpha Corp.
interim
M/M Mars
interim
Coca-Cola Co.
pharmaceu -
tical wastes
cleaning
wastes
beverage
9/15/74
7/15/74
7/15/74
interim
Curtiss-Wright Corp.
interim
mfg. wastes
rinsing waste
from aircraft
components mfg.
Date
Expired
7/14/75
5/14/75
7/14/75
Max. quant.
Allowed Undei
Permit
120, 000 gal.
380,000 T
5/31/75 1,000,000 gal.
7/14/75 2,400,000 gal.
120,000 gal.
5/31/75 9,300,000 gal.
7/14/75 5, 800,000 gal.
9/14/75 1,092, 000 gal.
673,400 gal
7/14/75 10,800,000 gal
216,000 gal
14
-------
TABLE 1 (CONT'D)
PERMITS IN FORCE DURING CALENDAR YEAR 1974
Applicant/Type Permit
Eagle Extrusion Corp.
interim
Gaess Env. Svc. Corp.
interim
Norda, Inc.
interim
S. B. Penick & Co.
interim
Solvents Recovery Svc.
interim
Tenco Div. of Coca Cola
interim
Nestle Company
interim
U. S. Radium Corp.
interim
Warner Lambert Co.
interim
Material
Dumped
Date
Issued
rinse water
sludge from
cleaning painted
alum, extrusions
pharmaceu -
ticals & org.
chemicals
flavor & fra
grance mfg.
wastes
plant extracts
wastes
used organic
mat'l recycling
wastes
food mfg.
wastes
food mfg.
wastes
non-radio-
active waste
from mfg.
luminescent chem.
pharm. waste 7/15/74
& san. sewage
sludge
Date
Expired
7/15/74 7/14/75
7/15/74 11/01/74
7/15/74 7/14/75
7/15/74 5/31/75
5/31/75
Max, quant.
Allowed Under
Permit
96, 000 gal.
10, 000, 000 gal.
1,200,000 gal
2,010,000 gal
660. 000 gal
250,000 gal
5, 460, 000 gal
6,000,000 gal
150, 000 gal
15
-------
TABLE 1 (CONT'D)
PERMITS IN FORCE DURING CALENDAR YEAR 1974
Applicant/Type Permit
Blue Ridge - Winkler Text.
interim
Pfizer, Inc.
interim
J. T. Baker Chem. Co.
interim
Fritzsche Dodge & Olcott
interim
Evor Phillips Leasing Co.
interim
Riegel Products Corp.
interim
Keuffel & Esser Co.
interim
Schering Corp.
interim
Bell Telephone Labs.
Material
Dumped
Date
Issued
waste activa- 7/15/74
ted & alum
sludge
cosmetics
mfg. wastes
manganous
carbonate prod.
wastes
org, flavoring
chem. wastes
waste reclama-
tion treatment
residues
resin-impregna-
ted paper prod.
wastes
residual coat-
ing sol. from
mfg. reprod.
paper
neut. pharm.
wastes
etching,
plating &
photo process
wastes
9/15/74
7/15/74
Date
Expired
Max. quant.
Allowed Under
Permit
7/14/75 1,800,000 gal.
7/15/74 7/14/75 1, 800, 000 gal.
1,500,000 gal.
420, 000 gal.
25,000,000 gal.
520,000 gal.
1,300,000 gal.
9/14/75 11, 000, 000 gal.
8/31/74
245, 000 gal.
16
-------
TABLE 1 (CONT'D)
PERMITS IN FORCE DURING CALENDAR YEAR 1974
Applicant/Type Permit
Region ni
City of Camden
interim
Rollins Emr. Services
special
DuPont - Edge Moor
interim
Crompton & Knowles
special
City of Philadelphia
interim
Modern Transp. (municipal),
special
Modern Transp. (industrial)
special
Sun Oil Co.
interim
Region VI
Shell Chemical Co.
interim
Ethyl Corp.
interim
DuPont - Beaumont
interim
DuPont - LaPorte
interim
Material
Dumped
Date
Issued
Max. quant.
Date Allowed Under
Expired Permit
digested 8121 /74
sewage sludge
8/21/75 15,000,000 gal.
ind. wastes 9/16/74 12/16/74 1,800,000 gal.
titanium 11/11/74
dioxide wastes
11/10/75 125.000,000 gal.
dye wastes 9/13/74 12/13/74 1,750,000 gal.
sewage sludge 2/13/74 2/13/75 150,000,000 gal.
sewage, septic 4/04/74
&digester sludge
4/04/75 15,600,000 gal.
ind. wastes 4/04/74 4/04/75 2,000,000 gal.
spent caustic 7/15/74 7/15/75 7,980,000 gal.
spent caustic 2/13/74
& digested
biol. sludge
sodium-cal- "
cium sludge
chemical mfg. "
wastes
chemical mfg. "
wastes
2/13/75 66,000 T
8,000 drums
307, 000 T
1/01/75 268,000 T
I u
17
-------
TABLE 1
-------
TABLE 2
Permits Denied and Dumpers Phased Out During 1974
Applicant
Region II
Consolidated Edison
Gaess Environmental Services
Bell Telephone Laboratories
Amerada Hess
Riegel Products
Ansul Company
BASF Wyandotte Corporation
Clorox Company
Remarks
denied
phased out
phased out
plant closed
phased out
withdrew application
denied
denied
Region III
Rollins Environmental Services
Region IV
GAT
DuPont - Belle
DuPont-LaPorte
Shell Chemical Company
(spent caustic portion of waste)
plant closed
phased out
denied by the Administrator
phased out
phased out
19
-------
TABLE 3
Ocean Dumping violations Referred to EPA
April 1973 - December 1974
VIOLATION CG DISTRICT § VIOLATIONS
Dumping short 3 3
7 . 2
12 1
Dumping long 7 1
Dumping without permit HQ 1
1 1
Attempted dumping without permit 1 1
Violating permit conditions* 1 2
3 1
7 1
11 4
Failure to notify COTP 3 113
Liquid wastes spilled enroute 3 2
No Permit on board 3 1
*{ dumping at night, trash/garbage blowing overboard enroute,
not sinking on site, etc.)
20
-------
dumpers, the Coast Guard, and EPA. Steps have been taken to
develop improvements in procedures for notification to the COTP
of departure and arrival times.
The ocean dumping surveillance and enforcement program has
prompted the development of advanced hardware and techniques.
Coast Guard Research and Development is working on a sealed
recording navigation system to be carried aboard dumping vessels
which should help to provide more efficient enforcement with
existing resources. It should also aid the vessel's master in his
navigation.
In several instances the Coast Guard has provided to EPA
both photographic and sworn visual observation evidence of cases
of violation. In one case where evidence of two short dumps was
presented, the violator was assessed a penalty of $40, 000 and
required to install additonal navigational equipment to insure that
further premature dumps would not occur.
Another case of alleged short dumping supported by photographic
evidence provided by the Coast Guard was dismissed by EPA as a
result of additional photographic evidence provided by the alleged
violator. What appeared to be sludge discharging from a barge was,
in the opinion of the Regional Enforcement Division, the resulting
action of self-propelled vessels in shallow water. Rather than waste
being discharged, it was bottom material being disturbed as the
result of certain maneuvers in shallow water. The Coast Guard then
agreed with these findings and the charges contained in the Notice
of Violation were formally withdrawn.
In another instance, two Coast Guard helicopter pilots presented
visual observation testimony of a short dump. A penalty of $25,000
has been assessed against the violator. Two other cases of violations,
one supported by Coast Guard evidentiary material, have resulted in
fines being levied and, in one case, the permit has not been renewed
and the dumping has been terminated.
21
-------
HI. ANALYSIS OF EXISTING DUMPING ACTIVITY
During the two years that the Act has been in effect all previous
unregulated dumping of wastes into ocean waters has come under
strict regulation by the Ocean Dumping Permit Program. The
level of dumping activity that has occurred under EPA permits
since the program became operational is indicated in Table 4.
The absence of complete and accurate dumping records prior
to the implementation of the permit program makes any compar-
ison with ocean dumping activity of past years difficult. It is
evident, however, that ocean dumping of wastes was increasing
when the Act was passed. In addition, both the Senate and House
versions of this Bill reflected the concern that those pollutants,
which were previously discharged into the Nation's waters or air
and are now restricted by the Federal Water Pollution Control
Act Amendments of 1972 and the Clean Air Act, not end up indis-
criminately being dumped in the ocean.
The data in Table 4 show an increase from 1973 to 1974 in
the dumping of industrial wastes, sewage sludge, and construction
debris, with no dumping of explosives and fairly insignificant
dumping of solid waste (in this case, garbage from foreign vessels
which is prohibited by law for health reasons from being brought
to shore). The permit program went into effect in mid-1973,
so the data for that year reflect eight months of dumping activity
extrapolated for 12 months to estimate an annual rate.
In implementing the ocean dumping permit program,
EPA requires a thorough evaluation in all applications of the need
for ocean dumping and the availability of alternate methods of
disposal. This approach has required a number of industrial
dumpers to seek other alternatives. The two years from 1973
through 1974 represent, in most cases, the time that it has
taken industrial dumpers to pursue other alternatives and build
treatment plants or implement other methods of waste disposal.
On the Atlantic coast alone, 47 former dumpers ceased ocean
dumping either by the time the Act went into effect or after having
initially received permits. Another nine companies have either
withdrawn their applications or have been denied permits. At
least 14 current dumpers are scheduled to cease ocean dumping
in June, 1975, and eight more in June, 1976. The increase in
amount of industrial wastes dumped in the Atlantic does not
represent new dumpers, but rather the industrial growth during
which time the companies have been seeking alternatives to ocean
dumping. In fact, the amount of wastes dumped into the Gulf of
Mexico decreased measurably because four out of the seven
original permittees had implemented alternatives to ocean
dumping by the end of 1974.
23
-------
TABLE 4
OCEAN DISPOSAL: TYPES AND AMOUNTS, 1974* and 1973**
(IN TONS, APPROX.)
WASTE TYPE
Industrial Waste
Sewage Sludge
Construction &
Demolition
Debris
Solid Waste
Explosives
TOTAL
ATLA
1974
4, 767, 000
5, 676, 000
2,242.000
0
0
12, 685, 000
JNT1C
1973
3,997,100
5,429,400
1,161,000
0
0
10,587,500
G
1974
950, 000
0
0
0
0
950, 000
ULF
1973
1,408,000
0
0
0
0
1,408,000
PAC
1974
0
0
0
200
0
200 •
:IFIC
1973
0
0
0
240
0
240
TO
1974
5,717,000
5,676,000
2,242,000
200
0
13,635,200
TAL
1973
5,405,100
5,429.400
1,161,000
240
0
11,995,740
* 1974 Source - EPA Regional Offices. Unpublished Reports, updated information, 1974
(12 months of dumping activity).
** 1973 Source - EPA Regional Offices. Unpublished Reports, 1973 (8 months of dumping
activity--May to December 1973 under permits issued by Ocean Disposal Program
extrapolated for 12 months to provide an annual rate).
-------
The increase in the amount of sewage sludge being ocean dumped
off the Atlantic coast is due to increased plant capacity and addi-
tional levels of treatment of municipal waste, not to an increased
number of municipal dumpers. About five million cubic yards of
municipal sludge were dumped in the New York Bight in 1974.
Upgrading present treatment facilities to secondary level (90%
reduction of BOD and suspended solids), plus treatment of the
present raw sewage discharges, will significantly increase the
volume of sludge to be handled. Unless environmentally accept-
able alternate sludge disposal methods are developed this additional
sludge will be dumped in the ocean.
The increase in construction rubble is due primarily to the
current work on the Harlem River water supply tunnel. The
construction debris from this project is being transported
to the cellar dirt site and ocean dumped.
As indicated in Table 4 ocean dumping of barged wastes
is currently utilized as a disposal technique predominately on
the East and Gulf Coasts for industrial wastes and on the East
Coast alone for sewage sludge. This is not merely because
these areas have failed to fully pursue alternatives to ocean
disposal, but rather a combined result of historical usage of
ocean dumping and immediate unavailability of alternate methods
of disposal.
The use of ocean outfall pipes and the availability of land for
disposal on the West Coast have made unnecessary the barging
of wastes to the ocean. Inland disposal of municipal effluents and
sludges in the Gulf Coast states has prevented the development
of ocean dumping of municipal wastes into the Gulf of Mexico,
On the other hand, it has been those areas open to the sea with
a high density of population and industrial development such as
metropolitan New York and Philadelphia that have turned to
ocean dumping. Now these industrial and municipal dumpers are
being required to evaluate the alternatives to ocean disposal.
Based on the concentrations of specific constituents analyzed
to be in wastes dumped in the ocean, the annual input of these
constituents from ocean dumping can be determined. Some
calculations have been made for the amount of mercury and
cadmium dumped off the Altantic Coast as "trace contaminants11
in wastes (Table 5).
25
-------
TABLE 5
Annual Inputs of Mercury and Cadmium Due to Ocean Dumping
Off The Atlantic Coast
1974 1973
Mercury Cadmium Mercury Cadmium
Ibs. Ibs. Ibs. Ibs.
Region H
Industrial 17
Region n
Municipal 3, 532
Region IH
Industrial *
Region HI
Municipal *
69
34,817
744
13,640
*Data not available
145 2.998
5,998 33,173
#
26
-------
In Region n, 99. 5 percent of the mercury and 99. 8 percent of
the cadmium dumped in the ocean conies from the municipal
sewage sludge, with only 0. 5 percent of the mercury and 0.2
percent of the cadmium from industrial wastes. A similar sit-
uation is noted for Region III where the mass loading of cadmium
from municipal wastes is 94. 8 percent of the total cadmium while
dumping of waste acid accounts for 5.2 percent of the total
cadmium.
EPA permits authorize the use of 33 barges in ocean dumping
operations. These are listed in Table 6. Six of the barges are
self-propelled ocean-going vessles; the remainder are not self-
propelled and require the services of a tugboat.
During 1974, about 1, 900 barging trips were made to dump
wastes at the 11 disposal sites at which dumping is permitted
by EPA (See Table 7).
The cost to the permittee of ocean dumping as a disposal
technique varies with the type of waste, the distance to the
dumpsite, and permit requirements. A general estimate can
be made of dumping costs by waste categories:
Mixed Industrial Wastes $12-$14/cubic yard
Acid Wastes $ 2-$ 6/cubic yard
Sewage Sludge $ 2-$ 6/cubic yard
27
-------
TABLE 6
Barges Authorized for Ocean Dumping
by EPA Permits Under The Marine Protection, Research,
and Sanctuaries Act of 1972, as Amended
Barge
Permitted
Transported s)
Permitted
Departure Ppint(s)
Permitted
Waste Type
legion I
Mary M
Safely Projects
& Eng.
Hingham, MA
indust.
Carolinian
Pine State
By-Products
Portland, ME
indust.
legion II
Newtown Creek
Coney Island
Owls Head
Bowery Bay
Ocean Disposal $1
Liquid Waste #1
Sparkling Waters
Susan Frank
ACS
City of NY-EPA
City of NY-EPA
City of NY-EPA
City of NY-EPA
A&S Trans. Co.
A&S Trans. Co. and
Weeks Dredg.
& Contract.
Modern Trans. Co.
A&S Trans. Co.
PCI Internat'l Inc.
Modern Trans. Co.
Spentonbush Trans.
Service
General Marine
Trans. Co.
General Marine
Trans. Co. & Ocean
Disposal Co.
Allied Chemical
Corp.
N.Y., NY
N.Y., NY
N.Y., NY
N.Y., NY
So. Kearny, NJ
Arecibo, PR
sludge
sludge
sludge
sludge
indust.
sludge
So. Kearny, NJ
Arecibo, PR
N.Y., NY
Bayonne, NJ
indust.
pharma.
indust.
sludge
Morristown, NJ
acid
28
-------
TABLE 6 (CON'T)
Barge
Region VI
PATCO-100
Triton
H.L. Jacobs
Z-110
Z-120
Z-122
2502
Z-lll
GAF #1
Chem 810
Offshore No. 2405
Magnolia I
Permitted
Transporter(s)
Port Arthur
Towing Co.
Port Arthur
Towing Co.
DuPont Lessee
Domar Ocean
Trans. Ltd.
Domar Ocean
Trans. Ltd.
Domar Ocean
Trans. Ltd.
Domar Ocean
Trans. Ltd.
Domar Ocean
Trans. Ltd.
Port Arthur
Towing Co.
Dixie Carriers Inc.
Dixie Carriers Inc.
Lockport Chemical
Permitted
Departure Point(s)
Beaumont, TX
LaPorte, TX
Beaumont, TX
LaPorte, TX
Texas City, TX
Beaumont, TX
LaPorte, TX
Beaumont, TX
LaPorte, TX
Beaumont, TX
LaPorte, TX
Beaumont, TX
LaPorte, TX
Beaumont, TX
LaPorte, TX
LaPorte, TX
Texas City, TX
Deer Park, TX
Deer Park, TX
Baton Rouge, LA
Permitted
Waste Type
indust.
indust.
indust.
indust.
indust.
indust.
indust.
indust.
indust.
indust.
indust.
indust.
Co. (Chem. Waste
Disposal Co.)
Region DS
M/V Ramona
H-10 Disposal
Barge I
H-10 Water Taxi
Co., Ltd.
H-10 Water Taxi
Co., Ltd.
Los Angeles, CA
Long Beach, CA
Los Angeles, CA
Long Beach, CA
garbage
garbage
30
-------
TABLE 7
Barge Trips for Ocean Dumping
Region I
Dump Site
Mixed Industrial Waste
Other
Total
Number of
Trips
1
4
Region II
Mixed Industrial Waste
Acid Waste
Sewage Sludge
Other
Total
196
792
400
*
1,388
Region III
Mixed Industrial Waste
Acid Waste
Sewage Sludge
Total
125
97
222
Region VI
Mixed Industrial Waste
Ocean Incineration
Total
219
4
Region IX
Garbage
16
Total number of ocean dumping trips
*Data not available
1854
31
-------
IV. BASELINE SURVEY PKOGRAM
Section 102(c) of the Act authorizes the Administrator to
designate recommended sites or times for dumping, con-
sidering the criteria of Section 102(a). When the interim regu-
lations were published, a list of interim dump sites was included.
These sites were selected from existing information on ocean
dumping and were selected based on historical usage, not on
environmental criteria governing the selection of sites to minimize
damage to the marine environment. This was recognized as a
temporary expedient, and EPA has since made the commitment that
it will comply with the requirements of the National Environmental
Policy Act in the designation of ocean dumping sites for continuing
use.
Regulations are now being developed to establish the procedures
by which ocean dumping sites will be designated for continuing use;
these procedures will include the preparation of an Environmental
Impact Statement (EIS) for virtually all ocean dumpsites presently
in use or proposed for use.
The preparation of an acceptable EIS on an ocean dumping site
requires the collection of a large amount of environmental data at
the site itself and in nearby areas to form the basis for an environ-
mental assessment of the site and to predict the impact of dumping
on the site. The data collection requirements needed for an
environmental assessment of a dump site have been formalized into
a standard baseline survey guideline.
This baseline survey guideline was developed in consultation
with NOAA and serves as the basic plan for all baseline surveys,
with appropriate modifications being made to meet special situations.
The basic plan in any baseline survey is to take samples of both
water and sediments to determine the levels of specific chemical
parameters in and near the dumpsite. Of particular interest are
trace metals and persistent organic compounds that might be present
in wastes dumped at the site. Samples are also taken of living
organisms at and near the site in the water column, at the bottom,
and in the sediments. This broad scale sampling is needed to provide
data on the widest possible range of ecological features at the dump
site so that an accurate assessment can be made of what the impact
of pollutants would be at the dumpsite.
Before any acceptable appraisal of conditions at a dumpsite is
possible, the full range of seasonal or other periodic variations
in conditions must be observed. The baseline survey program
was begun during FY 1974, and during FY 1975, additional studies
-------
have begun. A brief synopsis of each baseline survey presently
being conducted follows.
1. Alternate Sewage Sludge Dumpsite in the New York Bight
Sewage sludge from the New York metropolitan area is cur-
rently being dumped at a site approximately twelve miles from
recreational beaches. While no impact on the beaches has yet
been seen from sludge dumped at this site, increased sewage
treatment in the New York metropolitan area will result in
much greater volumes of sludge to be disposed of during the
next few years. Much of this sludge may have to be ocean
dumped as an interim measure until a permanent form of ulti-
mate disposal is selected and implemented.
In early 1974, EPA requested NOAA to recommend areas
farther out in the New York Bight for study as alternate sludge
dumping sites. NOAA recommended two areas, one just north of
the Hudson Canyon and the other just to the south of the Hudson
Canyon; EPA has begun studies, by contract, of the area recom-
mended by NOAA just north of the Hudson Canyon and about 60
miles from Ambrose Light. The contract calls for three surveys
approximately three months apart depending on weather conditions.
The first survey was conducted during September and October,
1974; the second was conducted during January and February,
1975; and the third survey is scheduled for July and August 1975.
The study area, one of those recommended by NOAA, is 144
square miles and data have been collected at 15 biological stations,
five chemical stations, and three current measurement stations.
The study area is fairly typical of an open continental shelf environ-
ment with a fairly flat and featureless bottom and a diverse biological
community. Seasonal differences between the first two surveys
were observed, particularly in number and variety of organisms
present in the water column. From this site, where no ocean
dumping is now occurring, small quantities of slag were recovered
in some samples and small plastic spheres were recovered from
surface tows. Neither of these materials is typical of sewage sludge.
In addition to providing the required data for an Environmental
Impact Statement, a major output of this study will be the develop-
ment of a monitoring program for the alternate sludge disposal site.
34
-------
2. Philadelphia and DuPont Dumpsites off Delaware Bay.
Prior to the beginning of the Ocean Dumping Permit Program,
Philadelphia had been dumping sewage sludge at a location approxi-
mately 11 miles seaward of the mouth of Delaware Bay. In April,
1973, EPA issued an interim ocean dumping permit to Philadelphia
for ocean disposal of sewage sludge, but required the city to use
a site about 50 nautical miles southeast of the mouth of the
Delaware Bay. Philadelphia has used this designated site up to
the present time. This site is quite close to the site being used
by DuPont for the disposal of waste acid.
Prior to use of the present site by Philadelphia, a single base-
line survey of the site was conducted, and since then, surveys
have been made on a quarterly basis. These surveys have been
a cooperative effort among EPA, universities, industries, and
NOAA. About 20-24 stations are sampled on each survey, primarily
for trace metals in sediments and in organisms. Direct observations
were also made in August, 1974, using a manned submersible.
The close proximity of these two dumpsites makes it logistically
economical to study them both at the same time. The difference
in composition between the two wastes makes it possible to use
different constituents as tracers to describe the movement of
each waste. Using this technique statistically significant differences
in the geographical distribution of trace metals in sediments and
in some organisms have been found. Additional studies are being
conducted to quantify the nature and extent, of these differences
and to establish cause and effect relationships.
3. Toxic Industrial Wastes Dumpsite, East of Cape Henlopen,
Delaware.
This dumpsite is located 106 nautical miles southeast of Ambrose
Light (at the entrance to New York Harbor) and approximately 90
nautical miles due east of Cape Henlopen, Delaware. The area
is bounded by 38°40'N to 39°00'N and 72°00'W to 72°30'W. The
site is off the continental shelf at depths ranging from 1550 meters
in the northwest corner of the site to 2750 meters in the relatively
flat southeast corner. The bottom, for the most part, is character-
ized by a rugged topography. A major topographic feature of the
region, the Hudson Canyon, is to the north, northeast and east of
the toxic waste dumpsite.
This site is used by over 30 different ocean dumpers in the New
York - New Jersey area for the disposal of industrial chemicals.
35
-------
In 1974, a total of 1,148 million gallons of wastes were disposed of
in the site, of which 41 million gallons were in sludge (semi-viscous)
form. All the remaining wastes were in liquid form. Wastes
are dumped by barge just beneath the water's surface at a nominal
speed of 5 knots. Typical waste materials are hydrochloric acid
by-products, inert ore slurry from production of titanium dioxide
pigments, residual sludge from galvanizing and plating operations,
liquid wastes from textile manufacturing, liquid wastes from
etching and photographic processes, water solutions of inorganic
salts, and similar materials resulting from diverse manufacturing
processes. Containerized radioactive wastes were dumped in
a location just south of the present site several years ago and
prior to enactment of the act.
In May, 1974, NOAA began a series of baseline surveys of
this dumpsite in cooperation with EPA, the Virginia Institute of
Marine Science, the Woods Hole Oceanographic Institution, and
the Lament-Doherty Geological Observatory of Columbia University,
and the Smithsonian Institution.
Another cruise is planned for July, 1975, and the final base-
line cruise is planned for February, 1976. The July cruise will
make use of the manned submersible ALVIN, and attempts also
will be made to collect data at the radioactive waste dumping
area south of the dumpsite.
The hydrography of the dumpsite area is complex and the
currents are seasonally variable. Any one of three water masses
may be present at different times or at different levels in the
water column: shelf, slope, and Gulf Stream water have all been
identified. Circulation patterns are affected by mixing across
frontal zones. Currents run predominantly southward along the
coast, while the Gulf Stream runs generally northeastward. The
slope water may circulate in a cyclonic gyre. Surface circulation
is primarily a function of season.
In addition to hydrography, studies have also been made in the
water column of the occurrence and, in some cases, relative abun-
dance of nutrients, zooplankton, ichthyoplankton, and nekton.
The bottom of the dumpsite has also been investigated by means
of echo-sounding, photography, trawling, and quantitative sampling
in order to describe aspects of geology, geochemistry, and benthic
fauna.
Investigations have been made of heavy metal and other con-
taminants in water, sediments, and in the tissues of larger benthic
fishes and invertebrates.
36
-------
4. Farallon Islands Radioactive Waste Dumping Site.
Low-level radioactive wastes were dumped in deep-ocean
disposal sites off the coasts of California and Mainland - Delaware
between the years 1946 and 1966. The gradual phasing out of this
practice began in 1962 and was replaced by burial of the radio-
active wastes on land. Currently there is no ocean dumping of
radioactive wastes but many government agencies have expressed
interest in resuming this waste disposal alternative.
With the passage of the Act, EPA was given responsibility
for developing regulations controlling ocean dumping of wastes
including radioactive wastes not specifically prohibited by statute.
Dumping of high-level radioactive wastes and radiological warfare
agents is specifically prohibited. The final regulations and criteria
for ocean dumping, issued October 15, 1973, require that any
radioactive materials to be dumped must be containerized and
that the container and/or inert matrix retaining the waste must
allow the material to radiodecay to innocuous levels before any
release to the marine environment.
In order to expand on this requirement and to evaluate any
permit requests, it is necessary to obtain information on past
disposal operations to answer such questions as:
(1) Were past disposal practices adequate to prevent any
environmental damage ?
(2) Were techniques used in packaging the radioactive
materials adequate to insure their retention?
(3) If dumping should commence in the future, is it techno-
logically feasible to adequately survey or monitor a
radioactive waste dumpsite to detect any potentially
adverse effects?
To obtain preliminary answers to these questions EPA
developed a pilot study to investigate a formerly used radioactive
waste dumpsite located approximately forty miles west-southwest
of San Francisco, California, near the Farallon Islands, and
centered at coordinates 37° 39'N, 123° 08'W, at a water depth
of 3, 000 feet.
In order to accurately locate and sample within the dumpsite,
and to photographically document the condition of the radioactive
waste containers EPA selected an unmanned, tethered sub-
mersible, the CURV III (Cable-Controlled Underwater Recovery
37
-------
Vehicle), for this study. The CURV HI is operated by the Naval
Undersea Center in San Diego, California, and has a depth
capability of 10.000 feet.
The pilot study was conducted from August 23 through August 31,
1974, with the EPA Office of Radiation Programs supplying the
chief scientist to coordinate the operation.
During the course of the study the operations team achieved
the following:
(1) First location of an actual radioactive waste dumpsite
with supporting documentation as to actual years of usage. (This
is important in determining corrosion rates of the containers,
number of containers dumped, and relative inventory of the
dumped materials from which to assess any radionuclide dispersion.)
(2) First videotape and 35mm coverage documenting the con-
ditions of the radioactive waste containers.
(3) First precision-located sediment samples in a radioactive
waste disposal area. (This was achieved using a videotape moni-
toring system coupled with a specially-devised rosette coring
device.)
(4) Examination of large sponges up to four feet high (possibly
a new genus) attached to the radioactive waste containers; these
may contribute to the biodeterioration of metal containers at the
3, 000-foot depth.
(5) Documentation of edible species of fish in the immediate
vicinity of the containerized radioactive wastes, supporting
potential foodchain transfer.
EPA obtained much preliminary information on container in-
tegrity and design. Through existing records and correspondence
pertaining to past disposal operations in the region of the Farallon
Islands, it was possible to determine the age of the photographed
containers as between 20-22 years old. Those radioactive wastes
packaged in an inner matrix of concrete have maintained rela-
tively good integrity while those packaged in a gel matrix with
a tar liner did not retain the wastes as well. Radionuclide analyses
for strontium, cesium, uranium, thorium, radium, plutonium, and
gross gamma activity are currently being completed, and an oper-
ations report on the Farallon Islands pilot study is soon to be
published. Preliminary results of radiochemical analyses of
sediment samples have detected some levels of plutonium above
38
-------
background in the dumpsite. The implications of the findings
are under investigation and the results will be included in a
forthcoming technical report.
5. Proposed Industrial Waste Dumpsite in the Eastern Gulf of
Mexico
During the summer of 1974, consideration was being given to
the disposal of wastes from the E. I. du Pont de Nemours plant at
Belle, West Virginia, at a site in the eastern Gulf of Mexico. As
part of its permit application DuPont conducted, by contract, a
baseline survey of the proposed dumpsite and continental shelf
areas to the north and east. The permit was ultimately denied and
the site has never been used. The results of this baseline survey,
however, offer an analysis of environmental conditions in tropical
open ocean areas.
The area chosen for this dumpsite is 170 nautical miles south-
east of the Mississippi River and 230 nautical miles due south
of Pensacola, Florida. It is in the deepest part of the Gulf of
Mexico (about 3, 000 meters) and is about 100 nautical miles
from the continental shelf to the north and east of the dump site.
Physical, chemical, and biological investigations were con-
ducted for E.I. du Pont de Nemours in the Gulf of Mexico in
June, 1974. These investigations were designed by DuPont and
the Environmental Protection Agency to provide baseline data
at a proposed disposal site and at continental shelf stations. Five
stations in the eastern midgulf (about 27°N, 87°W) were investi-
gated between June 2-4, 1974; seven stations along the continental
shelf (from east of Tampa, Florida, to south of New Orleans,
Louisiana) were investigated between June 7-13, 1974.
Current velocities in the midgulf were approximately one knot
to the southeast, consistent with the range of current values
reported by the XJ. S. Naval Oceanographic Office (1972) for the
general April - June period. Dissolved oxygen levels in the
midgulf were close to the levels found in surface seawater where
biological activity is not excessive. Ambient light transmission
levels showed 1 percent transmission to as deep as 100 meters.
All of the chemical analyses of seawater from the midgulf produced
results at or below levels for general ocean water with most
variables below their detection limits. Plankton levels of the
midgulf had a mean of 325 individuals per liter. This number,
while low in comparison to inshore waters, is in agreement with
historical data for the mid-Gulf of Mexico.
39
-------
Current velocities at shelf stations were in general agree-
ment with historical data. Dissolved oxygen levels at shelf
stations were generally close to the quantity found in surface
sea water when biological activity is not excessive. Chemical
analysis results of seawater from the shelf stations were approxi-
mately the same as had been measured in the midgulf. In addi-
tion to some trace organics, only mercury and antimony con-
centrations were higher than levels for general ocean water.
Sediment analyses for shelf stations showed barium and cadmium
concentrations higher than USGS reported levels. Four pesticides
and some aromatic hydrocarbons were found in the sediment;
concentrations of these materials were only slightly above
minimum detectable concentrations. Grain sizes of shelf sedi-
ment agreed with historical data. Chemical analyses of plankton
showed heavy metal concentrations generally lower than historical
data. Zooplankton counts, to some extent, paralleled the phyto-
plankton counts. No species of zooplankton or benthos was
conspicuous by either presence or absence. In general, results
were in agreement with available historical data in all aspects
of this investigation.
40
-------
V. EPA RESEARCH PROGRAMS
No sharp line can be drawn between permit operations, baseline
surveys, and research within the overall EPA approach toward
implementation of the ocean dumping permit program. Technical
assistance for permit operations is provided in specialized areas
by the EPA Office of Research and Development. Much information
of value to EPA's research efforts is collected in permit operations
and monitoring and baseline survey activities conducted by EPA
Regions and the Office of Water and Hazardous Materials which is
responsible for coordinating the national ocean dumping permit
program.
The EPA Office of Research and Development has been con-
cerned with marine pollution problems for many years. The
projects supported under this program have been historically
oriented toward estuarine pollution problems and those related to
ocean outfall disposal. With the passage of the Ocean Dumping
Act in 1972, some of these activities were reoriented to provide
a sharper focus on problems related specifically to ocean dumping,
while research directed toward solving other marine pollution
problems was strengthened.
Research efforts related to the ocean dumping permit program
within EPA have been focused in three areas since the inception
of the program in 1973. These are: (1) criteria development,
(2) methods development, and (3) environmental impact assess-
ment. Highest initial priority has been given to the development
and improvement of criteria and analytical methodology, and as
these efforts have brought positive results, additional resources
have been devoted to research directed toward the assessment
of environmental impact.
Of particular concern has been the development of acute and
chronic toxicity levels for mercury and cadmium in ocean waters
and the application of these values to the ocean disposal criteria.
As a result of contract studies with the National Academy of
Sciences directed toward the revision of water quality criteria,
in addition to recent results of in-house EPA research efforts,
information is now available which provides a basis for con-
sideration of modification of the published criteria for mercury
and cadmium; revised criteria for these constituents may be
proposed in the near future.
Initial efforts on analytical methodology have resulted in the
development of an "interim" Ocean Dumping Analytical Methods
Manual which is currently in use by EPA Regions and permit
applicants. As part of this effort a manual of standard bioassay
41
-------
techniques has been compiled and revised as the state of knowledge
has advanced. During the coming year the bioassay techniques
will be revised to incorporate more sophisticated methods of
detecting chronic effects of pollutants on marine organisms.
The environmental impact of ocean dumping is being studied
directly by in-house EPA activities as well as through grants and
contracts. These efforts are being concentrated in three general
areas: trace metal impacts, impacts of persistent organic
compounds such as pesticides, and modeling techniques to pre-
dict impacts.
The following studies are being conducted on the movement
and impact of trace metals in marine waters. While many of
these studies deal primarily with estuarine situations, the
results can, in most cases, be extrapolated to ocean dumping
situations.
1. An industrial waste dump site and a sewage sludge dump
site are being used to test the concept of analytically "fingerprinting"
a waste material by trace metal analysis. Research efforts have
attempted to follow the fate of each waste by following particular
metal "tags11. Results to date indicate an increase in trace metals
in benthic invertebrates at and around the dump sites. Future
efforts will extend the sampling areas in an effort to delineate
the total area of effect of the dumping activities.
2. At a dredged material disposal site in Rhode Island Sound,
where material containing high concentrations of heavy metals
has been deposited, a clear demonstration of deleterious eco-
logical impact is developing. Preliminary data indicate high'
cadmium and zinc concentrations in the water directly over the
dredged material deposit. Histological examinations of tissues
from the clam Arctic a islandica have revealed kidney damaging
concretions in clams found as far as five miles from the site.
Tissue damage was greater in clams found closer to the site.
Concentrations of selected metals in clam tissues have been shown
to be very high relative to uncontaminated controls. Crabs caught
on the dredged material showed abnormally eroded and discolored
carapaces.
3. An extensive field sampling program to evaluate the effects
of metals on benthic animals has been conducted in lower Narragansett
Bay, R. I. This study was designed to develop techniques for evaluating
the ecological impact of a typical industrial discharge containing
large quantities of heavy metals. Metal contamination of benthos
has been demonstrated.
42
-------
4. A study of the movement of trace materials from sewage
sludge into marine biota is being performed. . While prime emphasis
is on metal transport and uptake, consideration is also being given
to investigations of the ecological behavior of chlorinated hydro-
carbons.
5. A study entitled "Dredge Spoils and Sewage Sludge in the
Trace Metal Budget of Estuarine and Coastal Waters" will develop
field methods for assessing metal fluxes from natural sediments.
The study will attempt to develop correlations between water column
metal levels and sediment metal concentrations in the Hudson River
estuary and the New York Bight.
6. A mathematical model to assess the effects of time de-
pendent and time independent sewage sludge stress on marine
plankton systems is under development.
7. A grant entitled "Influence of Dredged Spoils and Sediment
Pollution on Trace Metal Assimilation by Organisms" will use
controlled laboratory experiments simulating ocean dump sites to
assess metal fluxes between sediments and overlying water.
8. A grant to assess contaminant impacts in a historical con-
text will use various radioisotope determinations to date sediment
layers in core samples taken from strategic locations along the
East Coast. It is hoped that contaminant concentrations will
correlate with the age of each layer to provide an estimate of
historical trends of pollution on the Atlantic shelf.
9. A grant entitled "Transport, Fate and Geochemical Inter-
action of Mercury, Cadmium and Inorganic Pollutants in the Coastal
Littoral and Salt Marsh Environment of the Southeastern United
States" is attempting to describe the behavior of discharged
heavy metals.
10. A grant entitled "Chemistry of Mercury in Natural Waters"
is tracing the pathways of mercury in the marine environment.
Particular emphasis is being made on the fate and mobility of
mercury in sediments, surface waters, pore water and biota in
the estuaries of the Gulf Coast region.
The impact of persistent organic compounds, particularly
pesticides and halogenated hydrocarbons, is a matter of major
research interest to EPA. In-house research efforts are directed
toward determining the ecosystem perturbations resulting from the
presence of environmental levels of these materials and developing
bioassay techniques to assess such impacts on a routine basis.
43
-------
In addition to the in-house efforts, the following grant or contract
studies are underway:
1. "A Synoptic Survey of Chlorinated Hydrocarbon Inputs to
the Southern California Bight" is providing information on the rates
at which chlorinated hydrocarbons enter the coastal waters of the
Southern California Bight. Sources of chlorinated hydrocarbons,
such as land runoff, wastewater effluent, direct industrial discharge,
vessel anti-fouling paint, aerial fallout, and ocean current advection
are being investigated. The effects of ocean outfalls on the structure
and incidence of disease in biotic assemblages are also being studied.
2. A grant entitled "Accumulation of Persistent Organic
Compounds in Phytoplankton and Influence on Phytoplankton Growth"
is being performed in the Puget Sound region.
On a broader scale, EPA research is directed toward the
application of mathematical modeling techniques to predict the
fate of pollutants in the marine environment and to assess their
effects on marine ecosystems.
1. An in-house study of ocean dumping impact in the New York
Bight will provide information essential to proper management
of ocean disposal sites. The purpose of the project is to develop
a predictive capability to describe the fate of sewage sludge dis-
charged from moving barges into a near-shore ocean environment.
Mathematical models have been devised to predict the time-spa-
tial distribution of sewage sludge originating from barge disposal.
Work is being performed to field-verify this model. A biological
baseline of the natural condition ofbenthic communities in the
New York Bight has been established for comparative study of
existing and future environmental alterations due to ocean disposal.
2. Another in-house study is developing biological assessment
techniques to determine the "health" of marine ecosystems using
biological indices. This approach can be used to assess the impact
of stresses such as ocean dumping and outfall discharges upon
community structure and population dynamics of locally residing
biota in polluted and non-polluted marine environments.
3. A numerical hydrodynamic model study for the pollutant
flushing in Prudhoe Bay, Alaska is being carried out in-house.
A limited field investigation will be undertaken during the ice-free
season this summer.
4. The usefulness of currently available analytical techniques
for objective and quantitative evaluation of species, populations.
44
-------
and community responses to environmental changes will be the
focus of a grant entitled "Quantitative Response Characteristics
of Coastal Fish and Benthic Invertebrate Communities. "
5. A study entitled "Biological Analysis of Primary Pro-
ductivity and Related Processes in New York Harbor as Reflective
of Changing Water Quality" is investigating those processes and
factors which might contribute to massive algal blooms. This study
will provide information relevant to the kinds of treatment required
for municipal waste discharges. In addition, the study will inves-
tigate whether the water quality of the New York harbor region is
being affected by materials flowing into the area from offshore
sludge dumping sites.
6. A grant entitled "Fate of Pollutants Discharged from Coastal
Outfalls" is investigating the chemical factors affecting the fate
of pollutants. This will include field and laboratory studies.
7. A grant entitled "Retention of Pollutants in Fjords" is in
its third year. Here, mathematical models of circulation, nutrient
transport and phytoplankton dynamics have been simulated and
compared with historical data in Puget Sound. Present plans call
for further study of the deep circulation below the sill depth and
further biological work.
8. As part of a grant entitled "Biological Control of Microbial
Pollutants in Natural Waters, " a mathematical model of the die-off
of bacteria released from ocean outfalls has been developed.
45
-------
VI. DREDGED MATERIAL DISPOSAL
Under the authority of Section 103 of the Act, dredged material
may be dumped under permits granted by the U. S, Army Corps
of Engineers after the proposed permit has been reviewed and
agreed upon by EPA- In issuing such permits the Corps is required
to use EPA-designated sites wherever feasible, but the Corps may
use other sites if:
1) they determine that disposal at the EPA sites is not
economically feasible, and
2) EPA makes the determination that such disposal will not
have an unacceptable adverse effect on the environment.
Each EPA Regional Office is provided copies of Public Notice
of the Corps' intent to issue a permit for dredging and disposal
of dredged material. Each notice is reviewed for its compliance
with the EPA criteria for disposal in the ocean. During 1974,
about 110 such notices were reviewed. Region I (Boston) reviewed
20, Region n (New York) 50, Region HI (Philadelphia) 1, Region
IV (Atlanta) 20, and Region DX (San Francisco) 19. Ocean disposal
of dredged materials in Regions VI and X (Dallas and Seattle) is
done by the Corps.
Table 8 shows the volume of dredged material dumped
during CY '74. This shows a volume more than twice that dumped
during 1973. Most of the increase occurred in the Lower Mississippi
Valley (the New Orleans District of the Corps of Engineers). This
increase is caused by the additional dredging of the Mississippi
River required from the results of flooding in the lower Mississippi
Valley over the past two years. This volume may be expected to
be at a similar or perhaps greater level next year. Additional
increases may be expected during the next few years in several
Districts resulting from the dredging required to deepen channels
to the home bases for the U. S. Navy's new submarines.
The River and Harbor Act of 1970 (P. L. 91-611) authorized
the Chief of Engineers, under the direction of the Secretary of
the Army, to conduct a comprehensive program of research,
study, and experimentation relating to dredged material. In May
1971 the U. S. Army Engineer Waterways Experiment Station at
Vicksburg, Mississippi, was assigned the task of defining and
assessing the problem and developing a research program.
47
-------
TABLE 8
DREDGED MATERIAL DUMPED IN OCEAN - 1974
Corps ofEngrs. Permits Total
(Cu. Yds.)(Cu. Yds.) (Cu. Yds.)
New England Division 1,340,400 921,800 2,262,200
North Atlantic Division 8,234,543 3,475,849 11,710,392
South Atlantic Division 2,931,748 2,.979,500 5,911,248
Lower Mississippi Valley Division 54,600,000 - 54,600,000
Southwestern Division 9,743,982 - 9,743,982
South Pacific Division 7,162,918 1,292,500 8,455,418
North Pacific Division 5,982,280 - 5,982,280
89,995,871 8,669,649 98,665,520
48
-------
A five-year Dredged Material Research Program was
conceived with the objective of providing through research
definitive information on the environmental impact of dredging
and dredged material disposal operations and to develop technically
satisfactory, environmentally safe, and economically feasible
dredging and disposal alternatives, including consideration of
dredged material as a natural resource. Execution of the
program was assigned to the Waterways Experiment Station and
research was initiated in March 1973. The Corps estimates
the total cost of this research program at $30 million.
The Dredged Material Research Program is divided into
4 projects, each directed by a full-time project manager and
each with its own project staff:
- Aquatic Disposal Research Project
- Habitat Development Research Project
- Disposal Operations Research Project
- Productive Uses Research Project
Although all of the above projects have a bearing on ocean
disposal of dredged material, the Aquatic Disposal Research Project
is perhaps the most significant. The objective of this project is
to determine the magnitude and extent of effects of aquatic
disposal on organisms and the quality of surrounding water, and
the rate, diversity,, and extent disposal sites are recolonized by
benthie organisms.
The Dredged Material Research Program consists of 150 work
units and by the end of 1974, the program was about 40 percent
completed. The Corps anticipates completing the program by
FY '78, as originally planned.
Some of the more significant findings of the program to
date have been:
o The historical dumping in the Pacific Ocean site off the mouth
of the Columbia River does not appear to have had a chemical
or water quality impact on the surrounding area. The bottom
dwelling biota in the Pacific Ocean site appear to be enriched
due to the accumulation of finer grained sediments on the
bottom. The physical impact of dumping at the Pacific Ocean
site appears minimal.
.49
-------
o Historical disposal (75 years) at Batons Neck (Long Island
Sound) gives no indications of detrimental water quality and
biological impact on Long Island Sound. The fishing is
excellent in the area and bottom biota representative of central
Long Island Sound. The physical impact of the historical
dumping in Long Island Sound (13, 000, 000 cu. yds.) has
resulted in piles or mounds on the bottom. These mounds,
in turn, are reported to have enhanced lobster habitats.
o Turbidity increases during disposal at a site off Galveston,
Texas, could not be detected over background levels due to
storm-induced natural turbidity.
o Toxic heavy metals and organic pesticides do not appear to
be released and are apparently very stable in sediments.
o Aerobic conditions in disposal site water retard the release
of some nutrients and most toxic heavy metals. Anoxic
conditions in disposal site water enhance the release of some
nutrients and only a few toxic heavy metals.
o Most chemicals do not appear to be released from underwater
dredged material deposits at greater rates than those released
from natural sediments. Ammonia and manganese are
released to overlying water but are rapidly lost to the aquatic
system.
Calendar Year 1975 represents the approximate apex of the
scheduled scope and funding of the Dredged Material Research
Program. Work will be underway by the end of the year in all
program tasks.
In conjunction with the Corps of Engineers, EPA plans to hold
a workshop on dredged material, disposal in Fiscal Year 1976.
This workshop will concentrate on dredged material disposal criteria,
application and utilization of the elutriate tests in operational modes,
standardized procedures, and if needed, recommended revisions
to the tests.
50
-------
VH. OCEAN INCINERATION: A NEW TECHNIQUE IN OCEAN
DISPOSAL
Under the ocean dumping program, if there are viable, feasible
alternatives to the direct disposal of the material into the marine
environment, either by incineration or any other way, then those
methods should prevail. Ocean incineration is one of these alter-
natives. Chemical wastes are taken aboard specially designed
and equipped vessels and transported to specified locations in the
ocean. There, onboard incinerators are fuel fired to a predeter-
mined temperature, the waste valves are opened, and waste is fed
into the incinerator. The nature of the wastes being incinerated
is such that once they hit this pre-heated incinerator they continue
to burn and the fuel feed is cut off. Efficiencies of these inciner-
ations are greater than 99.9 percent complete combustion.
Ocean incineration has been conducted routinely for two years
in the North Sea for industries in the Netherlands, Scandinavia
and Great Britain. Presently, three such vessels are in operation
wiih a fourth, a much larger one, under construction.
On September 27, 1974, EPA determined that ocean incineration
of wastes is under the purview of the Act. On October 10, 1974,
a research permit was issued for incineration at sea of 4,200
metric tons (MT) of organochlorine wastes from Shell Chemical
Company's Deer Park, Texas, plant. The wastes were a mixture of
low molecular weight chlorinated hydrocarbons consisting primarily
of trichloropropane, trichloroethane, and dichloroethane. These
wastes originated from the plant's production of glycerin, vinyl
chloride, epichlorohydrin, and epoxy resins.
The incineration took place during October 20-28, 1974, in
the Gulf of Mexico at a new dumping site approximately 130 nautical
miles from the nearest land. The wastes were incinerated aboard
the M/T Vulcanus, which is owned by Ocean Combustion Services,
B. V., of the Netherlands. The two high-temperature incinerators
aboard the Vulcanus are designed to burn upwards of 99. 9 percent
of organochlorine wastes. The resulting emissions consisted
primarily of hydrogen chloride, carbon dioxide, and water; they
were discharged directly into the atmosphere without scrubbing.
In accordance with conditions of the permit, a substantial
monitoring effort was undertaken to determine the feasibility
of this waste disposal technique and the impact of the emissions
on the marine environment. A large amount of data was gathered
during the incineration. Following review of the results, EPA
concluded that, although there were some shortcomings in the
51
-------
the monitoring efforts, conditions and criteria of the initial
research permit had been met. No significant adverse impact
on the environment was noted from the monitoring study.
On November 27, 1974, EPA granted a second research permit
to incinerate another shipload (4, 200 MT) under essentially the
same conditions as for the first shipload. Some monitoring
requirements were modified to correct some gaps in the
information gathered on the first incineration.
The second research burn took place December 2 -9, 1974.
On December 10 EPA scientists and representatives of Alabama,
Florida, Louisiana, and Texas met and unanimously concluded
that incineration by the Vulcanus of Shell's remaining organo-
chlorine wastes, under the same conditions imposed by the
two research permits, was an environmentally compatible
means of disposing of the wastes. On December 12, EPA issued
an interim permit for incineration of the remaining 8,400 MT.
The wastes were incinerated in two loads, on December 19-26,
1974, and on December 31, 1974, through January 7, 1975.
The final report on this incineration will be published in the
near future.
The U. S. Air Force has applied for an ocean dumping permit
for the ocean incineration of its stocks of Herbicide Orange. They
have also requested EPA to assist them in exploring the feasibility
of reformulation or reprocessing.
As a preliminary step in the evaluation of their permit appli-
cation, a public meeting was held in Washington on February 19, 1975,
to receive public comment on the Air Force proposal. The meeting
was attended by about 60 people, including representatives of
several environmental interest groups. The general public reaction
to the proposal to incinerate Herbicide Orange at sea was favorable,
provided adequate monitoring of the incineration was done and that
conditions of practically complete combustion were maintained. While
reprocessing or reformulation were recognized as potentially feas-
ible alternatives, concern was expressed about the potential for
environmental damage during continued storage and transportation
to a reprocessing site.
On March 24, 1975, notice was published in the Federal Register
of the receipt of the application, the tentative determination to
grant the Air Force a research permit allowing the incineration of
4,200 metric tons or less, and the proposed designation of a site
for the burn.
52
-------
Public hearings were held on this permit application in Honolulu
on April 25, 1975, and in San Francisco on April 28, 1975. At these
hearings the Air Force presented extensive testimony indicating
that the proposed ocean incineration would do no harm to the marine
environment or cause any effects in the air. They also indicated
an intent to investigate reprocessing proposals by conducting
pilot plant studies on a small amount of the Herbicide Orange to
see whether the claims made by the reprocessing firms were valid.
They requested a reconvening of the hearing in Washington at a
later date after the pilot plant studies were completed.
Other comments were also made at the hearings regarding the
potential for environmental impact of the incinerator emissions,
and full consideration will be given to all comments before a
final decision regarding the ultimate disposal of Herbicide
Orange is reached.
53
-------
. PUBLIC PARTICIPATION IN THE PROGRAM
Section 222.5 of the Ocean Dumping Final Regulations and
Criteria provides that any person may request in writing a public
hearing to consider the issuance or denial of any ocean dumping
permit application following public notice of receipt of such
application.
During 1974, 12 public hearings were held - one by Region I,
three by Region n (one each on municipal and industrial permit
applications on the mainland, and one in Puerto Rico), three by
Region m, three by Region VI, and two by Headquarters.
Hearing attendance averaged 135 at the Region H hearings, 70
at the Region in hearings, and 55 at the Region VI hearings. In
addition to representatives of EPA and the applicants, other
Federal agencies. Federal, state and local officials, environ-
mental groups, aeademia, concerned citizens and the news media
attended these hearings. Those who wished to make statements
on the proposed dumping did so. Television and newspaper cover-
age of the hearings was often extensive, and public participation
was spirited. Many citizens expressed concern regarding the
possible degradation of the oceans and, in Region H, fear that
sewage sludge from the New York Bight was moving toward the
beaches of Long Island.
A three-day public hearing was conducted by EPA Headquarters
in Pensacola, Florida, in July 1974, on an application from DuPont-
Belle, West Virginia, to dump chemical wastes in the Gulf of
Mexico. This hearing was attended by approximately 250 persons.
Extensive scientific testimony was presented on behalf of the
applicant, and by representatives of the Gulf states who opposed
the proposed dump. As a result of this hearing, the Administrator
of EPA determined in October to deny the permit until further
technical studies could clarify the environmental concerns re-
garding the ecological impact of the dumping operation.
Headquarters also conducted a public hearing on the appli-
cation of Shell Chemical Company to incinerate organochlorine
wastes at sea. Following the hearing, a research permit was
issued to Shell to incinerate 4,200 metric tons of this waste on
a specially designed incinerator ship. A technical conference
was held after this first burn to evaluate the results of extensive
monitoring conducted during the burn. Even though no adverse
effects to the marine environment were observed, a second
research permit was issued to allow aerial monitoring of the
55
-------
emissions from the incinerator stacks and additional sea-
surface monitoring. Based on the results of the second research
permit. Shell was granted an interim permit to dispose of two
more shiploads of these wastes.
In its implementation of the ocean dumping permit program,
EPA has been impressed by the nature and extent of public
concern for the oceans and interest in how the program is
progressing. In comments received at public hearings, in
letters received in response to public notices, and in reaction
to newspaper reports, it is apparent that the public is deeply
concerned about pollution of the oceans and what is being done
about it.
56
-------
IX. THE FUTURE OF OCEAN DUMPING AS A MEANS OF DISPOSAL
The enactment of the Marine Protection, Research, and Sanc-
tuaries Act of 1972 reflected the public awareness of a need to
assess and control the cumulative effects of man's activities on
coastal and ocean resources, and the undesirable and possibly
irretrievable changes to ocean ecosystems that these activities
may have.
Prior to passage of the Act, regulatory activities and authorities
were scattered among different agencies and were not adequate to
handle the problems of ocean dumping. States did not exercise
control over ocean dumping and generally their authority extended
only within the three-mile territorial sea. The Army Corps of
Engineers' authority to regulate ocean dumping was also largely
confined to the territorial sea, but the Corps dredging activities,
in response to its responsibility to facilitate navigation, involved
it with ocean disposal beyond the three-mile limit. The Coast
Guard enforced several Federal laws regarding pollution but did
not have direct authority to regulate ocean dumping. The Atomic
Energy Commission (now the Nuclear Regulatory Commission)
licensed the disposal of radioactive materials.
In enacting the Ocean Dumping Act, the Congress vested the
responsibility for regulating the dumping of all materials except
dredged material in the Environmental Protection Agency;
regulating the ocean dumping of dredged material was assigned
to the Corps of Engineers using criteria promulgated by EPA in
consultation with the Corps. Because protection of the marine
environment was of immediate concern, the Act required that
criteria be developed and the regulatory program implemented
based on the then known impact of waste materials in the oceans.
At that time, however, there was a great dearth of knowledge
on the impact of wastes on the marine environment. This is
being rectified as rapidly as possible at the same time the permit
program is in operation, but EPA's efforts to meet its respon-
sibilities under the Act were undertaken with the realization that
modifications of various aspects of our programs would be re-
quired in the future.
In its first two years of regulatory authority over ocean dumping,
EPA has taken a strict, highly restrictive approach toward applying
the criteria embodied in the Act by requiring all dumpers to actively
seek alternatives to ocean dumping even when their wastes have
met the published EPA criteria for issuing permits. During these
two years EPA has brought all ocean dumping in the United States
under full regulatory control and has required many dumpers either
57
-------
to, stop dumping immediately or to phase out their dumping
activities within the next few years.
EPA has taken this approach because of the general lack of
specific knowledge about the impacts of waste materials on marine
ecosystems. As the results of research now underway become
available, it may be possible to become more selective in permitting
the disposal of some wastes by ocean dumping if it can be demon-
strated that the disposal will not cause unreasonable degradation of
the marine environment.
The general problem of pollution of the marine environment has
numerous components, of which pollution by ocean dumping is only
one. Other significant sources of pollution are ocean outfalls, dis-
charges from offshore platforms, and land runoff from rivers and
estuaries. Most forms of pollution from these sources are reg-
ulated under the Federal Water Pollution Control Act Amendments
of 1972 through the National Pollutant Discharge Elimination System,
and specifically Section 403(c) which requires the setting of ocean
discharge criteria for ocean outfalls. EPA applies the same strict
criteria to outfall disposal as it does to ocean dumping, in addition
to requiring at least secondary treatment for all municipal sewage.
In looking to the future, it can be expected that increase in
population and industrial growth in coastal areas, which historically
tend to grow more rapidly than inland areas, will result in greater
pressures for ocean disposal either by outfall or by dumping, in
addition to much larger quantities of effluents being discharged in
rivers and estuaries. All these sources of pollution of the marine
environment must be regulated and strictly controlled to limit
adverse impacts and to insure that the best environmental alternatives
are chosen.
58
-------
WH448
United States Environmental Protection Agency
Washington, D.C. 2O46O
Official Business
POSTA<» AND TOW PAID
BNVatONM ENTAL. MOTOCTION AOCMCY
EPA-335
Special Fourth-Class Rat*
Book
If yoor addreM i* incorrect, pleue change OB the above label;
tear off; and return to the above addietfc
If you do not deifae to continue receiving tU> technical report
terki, CHECK H£R£ Q ; tear off label, and return it to tbe
above addrcu. ,
------- |