OCEAN DUMPING IN THE
     UNITED STATES
       Sixth Annual Report
            of the
  Environmental Protection Agency

       on Administration
           of Title I
  r A
       Washington

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON. D.C.  20460

                            JUL 12 1978
                                                          THE ADMINISTRATOR
Honorable Walter F. Mondale
President of the Senate
Washington, D.C.  20510

Dear Mr.  President;

   Section 112 of the Marine Protection, Research, and Sanctuaries
Act of 1972, as amended, requires the Administrator of the Environ-
mental Protection Agency (EPA) to submit an annual report on the
administration of the ocean dumping permit program authorized
under Title I of the Act. The sixth annual report for this program
is transmitted with this letter.

   The ocean dumping permit program became effective  April 23,
1973,  and final regulations  and criteria were published October 15,
1973.   Revisions to those regulations and criteria were published on
January 11, 1977.  This report  covers activities during calendar year
1977.

   The dumping into ocean waters of all materials is regulated by
EPA permits except dredged materials,  for which the U. S. Army
Corps of Engineers issues permits. We believe that the permit
program has brought the previously unregulated practice  of ocean
dumping under strict control.

                             Since
Enclosure

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     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     WASHINGTON. D.C. 20460

                              1 2 1978
                                                        THE ADMINISTRATOR
Honorable Thomas P. O'NeUl, Jr.
Speaker of the House
  of Representatives
Washington, D.C.  20515

Dear Mr.  Speaker;

   Section 112 of the Marine Protection, Research, and Sanctuaries
Act of 1972, as amended, requires the Administrator of the Environ-
mental Protection Agency (EPA) to submit  an annual report on the
administration of the ocean dumping  permit program authorized
under Title I of the  Act.  The  sixth annual report for this program
is transmitted with this letter.

   The ocean dumping permit program became effective April 23,
1973, and final regulations and criteria were published October 15,
1973. Revisions  to those regulations and criteria were published on
January 11,  1977. This report covers activities  during calendar year
1977.

   The dumping into ocean waters of all materials  is regulated by
EPA permits except dredged materials, for which the U. S.  Army
Corps of Engineers issues permits.  We believe that the permit
program has brought the previously unregulated practice of ocean
dumping under strict control.

                             Si
Enclosure

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                     TABLE OF CONTENTS


                                                        Page

INTRODUCTION AND SUMMARY	    1

    Ocean Dumping Program Chronology for 1977	   3


MARINE PROTECTION, -RESEARCH,  AND SANCTUARIES ACT

    Program Authorized Under Title I	   6
    Amendment in 1977	   7
    Relationship Between RCRA and the MPRSA	  7

INTERNATIONAL OCEAN DUMPING CONVENTION

      Table I  Governments Which Have Ratified or
                  Acceded to the Convention	   11
      Table II Amounts of Wastes &. Other Materials
                  Authorized for Ocean Dumping by
                  Contracting Parties	   12

THE PERMIT PROGRAM

    Permitted Dumping in 1977	  13
    Revision of Regulations and Criteria .	  24

      Table III  Permittees on Implementation Plans	  16
      Table IV  Permit Activity, 1977	  17
      Table V  Total Amount of Dumping, 1973-1977	20
      Table VI   Summary of Permits Denied or
                   Phased Out, 1973-1977	22
      Table VII  Permits Phased Out or Denied by
                   Region II During  1977	  23

ENFORCEMENT .	   27

      Table  VIII Enforcement  Actions - 1977	   28

BASELINE AND MONITORING SURVEYS OF DUMP  SITES . .  30

  Chart Displaying Current Ocean Dumping Sites . ......  35

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                INTRODUCTION AND SUMMARY
This is the Environmental Protection Agency's (EPA) sixth annual
report to the Congress on the implementation of Title I of the Marine
Protection,  Research, and Sanctuaries Act of 1972,  as amended
(MPRSA).  The report covers the Agency's authorities and respon-
sibilities in carrying out the  ocean dumping program and reviews
those program activities conducted within EPA Headquarters, the
Regions, and the Office of Research and Development during the
calendar year 1977.
Three other agencies having responsibilities under the MPRSA,
the U.S. Army Corps of Engineers,  the U.S. Coast Guard,  and
the National Oceanic and Atmospheric Administration, will each
submit separate reports on their activities in implementing the
Act.  Therefore, this report does not contain a discussion of their
activities under the Act except as they impact the responsibilities
of EPA.
During 1977, the amount of ocean dumping declined by 12 percent
from the level of dumping in  1976.  Region II (New York) continues
to be the most active area, with approximately 7, 300, 000 tons of
materials dumped in and adjacent to the New York Bight and off
the coast of Puerto Rico under permits issued for municipal and
industrial wastes, construction debris, and incineration of wood
debris.  In the Permit Program section, Table V summarizes the
total amount of dumping during 1977 (by geographic area) and pre-
sents an annual comparison of amounts dumped under EPA permit
during preceding years.
A summary of information on ocean dumping permits issued by
Contracting Parties to the International Ocean Dumping Conven-
tion is included in the section discussing the deliberations of the
Convention.  Accomplishments are being made in establishing
agreements on major items of high priority of work in clarifying
the provisions and requirements of the Convention.
A joint EPA-U. S.  Air Force project on incineration at sea of
Herbicide Orange was successfully completed during August and
September 1977.  A brief description of the project is included in
the section on Incineration at Sea, and a detailed report is being
prepared for publication in the near future.

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                   OCEAN DUMPING PROGRAM
                     CHRONOLOGY FOR 1977
January  7



        11


February 8


March   4


         9
        10


April    7




        25



May     2


        19



        25
June
 31
and
  1
Court Hearing on City of Cam den N. J.
   Emergency Ocean Dumping  Permit--Camden
   agrees to move to 106-mile site

Final Revision of Ocean Dumping Regulations
   and Criteria published in Federal Register

Final EIS issued on Proposed Revisions to Ocean
   Dumping Criteria

Meeting of Interagency Ocean Dumping Coordinating
   Committee, Washington, D. C.

House Merchant Marine and Fisheries Committee
   Oversight Hearings, Washington, D. C.

U. S. Air Force request to reconvene Public Hearing
    on permit application for incineration at sea of
    Herbicide Orange

Public Hearing,  Region II,  municipal sludge Ocean
   Damping Permit, Camden, New Jersey

Public Hearing, Headquarters, U. S. Air Force
   application for  incineration at sea of Herbicide
   Orange, Washington, D. C. (Reconvened from
   1975)
                       *
Research Permit issued to U. S. Air Force for inciner-
   ation at  sea of Herbicide Orange  stocks located at
   Gulfport,  Mississippi

 Designation in Federal Register of incineration at sea
   site in the Pacific Ocean

 Completion of incineration at  sea of Shell Chemical
   Company organochlorine wastes under Special
   Permit on Board M/T Vulcanus  (Burn March-May)

 Public Hearing, Region II, on 14 municipal sludge,
   2  wood  incineration, 1 industrial Ocean Dumping
   Permit applications, New York City

 Public Hearing, Headquarters, to consider
   possible relocation of sewage sludge dump sites
   in Atlantic Ocean, Torns River,  New Jersey

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November  1    Public Hearing, Region II, on 8 industrial Ocean
                   Dumping Permits, Puerto Rico

           4    Signed into law - P. L. 95-153, extends authorization
                   for Marine Protection, Research, and Sanctuaries
                   Act,  and calls for ending the dumping into ocean
                   waters, after 1981, of sewage  sludge which "may
                   unreasonably degrade or endanger human health,
                   welfare, amenities, or the marine environment,
                   ecological systems, or economic potentialities11

          28    Publication in Federal Register of interim final
                   revisions to Ocean Dumping Regulations,
                   Part 223 (Contents of Permits), and Part 226
                   (Enforcement)

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Title II requires the National Oceanic and Atmospheric Administration
(NOAA) to conduct a comprehensive program of research and monitor-
ing regarding the effects of the dumping of material into ocean waters.
Title III gives NOAA the authority to establish marine sanctuaries.
Amendment in 1977

During 1977, PL 95-153 amended the MPRSA to require the cessation
of the ocean dumping of sewage sludge as soon as possible and in any
event no later than by December 31, 1981.  For the purposes  of this
amendment, the term "sewage sludge" means any solid, semisolid,  or
liquid waste generated by  a municipal wastewater treatment plant the
ocean dumping of which may unreasonably degrade or endanger human
health,  welfare, amenities, or the marine environment, ecological
systems, or economic potentialities. This makes the  1981 phase out
date statutory for sewage  sludge (as defined in the amendment) dumped
under interim permits as  incorporated in the final revision of the EPA
ocean dumping regulations.


Any wastes from a municipal wastewater treatment plant that  can meet
the EPA environmental impact criteria for ocean dumping are not pre-
cluded by the amendment.  However, at this time it is not feasible to
treat such wastes to the extent that they would no longer be classified
as sewage sludge according to the definition given in the amendment.
Therefore, this  amendment will bring about the termination of all
ocean dumping of sludges  from .municipal wastewater treatment  plant
discharges by the end of 1981.


This amendment was stimulated by congressional  concern that those
municipalities currently dumping sewage sludge in the ocean were not
moving rapidly enough toward implementing alternatives which would
permit them to stop  ocean dumping as soon  as possible and that  a statu-
tory requirement would provide  an additional incentive to accomplish this.


Relationship Between the  Resource Conservation
and Recovery Act of 1976  (RCRA) and the MPRSA

Implementation  of RCRA (Amendment of the Solid  Waste Disposal Act),
in combination with the Clean Air Act, the Clean Water Act (CWA) and
with the MPRSA, represents major  steps taken by EPA towards total
environmental protection,


RCRA includes the management  of hazardous wastes from the cradle
to the grave, i. e.,  from the  generator to the treatment facility, to the
storage facility, and to the disposal facility. Under this,  in theory,

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      INTERNATIONAL OCEAN DUMPING CONVENTION
The Convention on Prevention of Marine Pollution by Dumping of
Wastes and Other Matter (Ocean Dumping Convention) was negoti-
ated in London in November 1972, and came into force on August 30,
1975,  following receipt of the  requisite 15 ratifications or accessions.
A First Meeting of Contracting Parties was held in London on December
17-18, 1975, for the primary  purpose of designating an organization
to  serve  as the Secretariat. The Intergovernmental Maritime
Consultative Organization (IMCO) was so designated.
Recognizing the importance of this treaty and U. S.  contributions
to its deliberations,  the U. S. Department of State established the
Committee on Ocean Dumping,  a sub-committee of the Shipping
Coordinating Committee, to insure coordination between govern-
ment agencies and provide for public comment on U.S. positions
regarding implementation of the Convention, The Committee is
chaired by EPA, and membership is comprised of representatives
from 14 government agencies and 15 non-government organizations.
The Committee was first convened in March 1976.  During a meet-
ing in September 1976,  review and comments were made on the
proposed U. S. positions regarding the agenda items of the First
Consultative Meeting of Contracting  Parties.  The Committee is
advised on the deliberation and results of the Convention, and
continues to serve in an advisory capacity for future Consultative
Meetings.
The First Consultative Meeting of Contracting Parties met at IMCO
Headquarters in London on September 20-24,  1976.  Participation
included representatives from 14 of the 29 Contracting Parties,
22 observer States which had not yet ratified or acceded to the Con-
vention,  observers from eight intergovernmental organizations,  and
representation from one non-governmental organization.  The Meet-
ing achieved agreement on Rules of Procedure,  on Form and Manner
of Notification  (reports of ocean dumping permits) required by the
Convention, and the need to develop international guidelines to
regulate incineration at sea.  Areas of high priority established
for future work included definition of high level  radioactive waste,
procedures for settlement of disputes, and interpretation of
terms (e.g., trace contaminants) appearing in the Annexes of
the Convention.
An intersessional Consultation on Incineration at Sea took place in
London during March 1977.  Experts from six Contracting Parties,
including the U. S., met to consider the technical aspects of incinera-

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                       TABLE I
          Governments Which Have Ratified or Acceded
               to the Ocean Dumping Convention
                   as of September 1977
Afghanistan
Byelorussian SSR
Canada
Cape Verde
Chile
Cuba
Denmark
Dominican Republic
France
German Democratic Republic
Guatemala
Haiti
Hungary
Iceland
Jordan
Nigeria
Norway
Panama
Kenya
Libyan Arab Jamahiriya
Mexico
Monaco
Morocco
New Zealand
Philippines
Spain
Sweden
Tunisia
Ukrainian SSR
United Arab Emirates
United Kingdom
United States
USSR
Yugoslavia
Zaire

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                     THE PERMIT PROGRAM
Permitted Dumping During 1977

The Ocean Dumping Permit Program became effective on April 23,
1973; the final Ocean Dumping Regulations and Criteria were published
in October 1973.  Significant revisions to the Regulations and Criteria
were  finalized and published in January 1977.  Revisions to the Proce-
dural portions of the Ocean  Dumping Regulations (Parts 223 and 226)
were  published on November 28,  1977.
General Permits may be issued for dumping of small quantities of
material which will have a minimal adverse environmental impact
when dumped under prescribed conditions.  Examples include burial
at sea of human remains or ashes, transportation of target vessels
with the intent of sinking the vessels during ordnance testing, and
transportation and disposal of derelict vessels, particularly  when
they pose a threat to navigation.
Special Permits may be issued for the dumping of materials which
satisfy the Criteria, but only for a maximum duration of three years
for-each permit.  In 1977,  Special Permits were issued for incinera-
tion at sea of Herbicide Orange, for disposal of construction rubble
and demolition debris, and for the dumping of certain aqueous dye
production wastes and miscellaneous laboratory wastes.
Emergency Permits may be issued for disposal of materials which
pose an unacceptable risk relating to human health and for which there
is no other feasible solution.  No Emergency Permits were issued
during 1977.  Although several instances occurred which might have
warranted an Emergency Permit,  acceptable alternative means of
disposal were used in each case.
Interim Permits may be issued for a period not to exceed one year
until December 31, 1981, for dumping materials which are not in
compliance with the environmental impact criteria or for dumping
at a dump site designated only as interim approved.  However, no
Interim Permit will be issued for  dumping of wastes from a facility
which has not previously ocean dumped and, as of April 23, 1978,
where the permit does not include a schedule which would allow
implementation of an  alternate disposal method or compliance with
the criteria on or before December 31, 1981.   Most of the current
ocean dumping permits are Interim Permits,  mainly because most
dump sites are only interim sites  and because  some of the materials
                              13

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The continued reduction in overall ocean dumping during 1977 is the
result of the continuing EPA effort to require those permittees whose
wastes are unacceptable for ocean dumping to seek alternative means of
disposal as rapidly as possible.  During 1977, 20 permittees were
phased out of ocean dumping, increasing the number of permits denied
or phased out  since the inception of the program to a total of 168
(Table VI).  The largest number of these were in Region II,  where
7 industrial dumpers and 11 municipal dumpers were phased out
(Table VII).
                                 15

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                             TABLE IV

             PERMIT ACTIVITY - CALENDAR YEAR 1977
Permittee; Location
   Type Permit

Region I

Safety Products and
Engineering; West Quincy,
Mass,;  special

Region H

Bergen  Co.  Sew.  Auth.;
Little Ferry, N. J.;
interim

Joint Meeting of Essex and
Union Counties? Irvington,
N. J.; interim

Linden Roselle-Rahway
Valley Sew. Auth.; Linden,
N. 3.; interim.

Middlesex Co. Sew. Auth.;
Sayreville, N. J.  interim

Middletown Twp.  Sew. Auth,;
Belford, N. J.; interim

Passaic Valley Sew.  Comm.;
Newark, N. J.; interim

City of Glen Cove;
Glen Cove, N. Y.; interim

City of  Long Beach;
Long Beach, N.Y.; interim

Nassau Co. D. P.W.  (8 plants);
East Rockaway, N. Y.;
interim

West Chester Co.  D. E. F.;
Yonkers,  N,Y.; interim

West Long Beach Sew. Dist.;
Atlantic City, N. J.; interim

New York City; N.Y.;
interim

American Cyanamid;
Linden, N. J.; interim
 Allied Chemical;
 Elizabeth. N. J.; interim
Material
Dumped
alkali metals
and explosives
sewage sludge



sewage sludge



sewage sludge



sewage sludge


sewage sludge


sewage sludge


sewage sludge


sewage sludge


sewage sludge



sewage' sludge


sewage sludge
 wood from repair of
 harbor facilities

 manufacturing wastes,
 water treatment
 chemicals

 by-product HC1  from
 manufacturing process
Actual Quant.
Dumped (1977)
38, 800Ibs
860 Ibs
225,000 wet tons



86, 000 wet tons



227, 000 wet tons



305,000 wet tons


15,000 wet tons


729,000 wet tons


6,000 wet tons


7, 000 wet tons


378,000 wet tons



157,000 wet tons


600 wet tons
 1, 700 dry tons
 (incineration)

 143,000 wet tons
 32, 000 wet tons

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                           TABLE IV (CCXNT.)
Permittee; Location
   Type Permit

General Marine Transport
Corp. ; Bayonne, N. J. ; interim
  Domestic Septic Tank Wastes
  MontviHe
  Morris  Twp.
  Wanaque S. A.
  Warren Twp.
  West Milford
  Wood-Ridge
Corps of Engineer^;
New York City, N, Y, i
 PCI International;
 Arecibo, Puerto Rico;
 interim
   Bristol Alpha, Inc.
   Cyanamid Agric. de P. R.
   Merck Sharp  & Dohrae
   Pfizer-P. R.
   P.R. Olefins Co.
   Schering Corp.
   Upjohn Mfg. Co.
   Oxochem

 Region in

 City of Philadelphia;
 Philadelphia, Pa.; interim

 Region VI

 Shell Chemical Co.; Deer
 Park, Texas; special

 Shell Chemical Co.; Deer
 Park, Texas; special

 Ethyl Corp.; Baton
  Route,  La.; interim

  Headquarters

  U. S. Air Force
  Washington, D. C.;
  research and special
Material
Dumped

sewage  sludge
and septic tank wastes
driftwood, timbers
 and pilings from
 waterfroiJt.jitrujjteres

 waste from manufacture
 of Pharmaceuticals,
 chemicals
 sewage sludge
  aerobically treated
  biosolids

  organochlorine wastes
  sodium-calcium
  sludge
  Herbicide Orange
 Actual Quant.
jDomped (1977)

 4H, 000 wet tons
 13,400 dry tons
 (incineration)


  314, 000 wet tons
                           594, 444 wet tons
   60, 192 wet tons
   17, 643 metric tons
   (incineration)

       860 tons
   121 112 wet tons
    (incineration)

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TABLE V (CONT.)
WASTE TYPE

Industrial Waste
Sewage Sludge
Construction and
Demolition Debris
Solid Waste
Explosives
Incinerated
(Wood)
Incinerated
(Chemicals)

TOTAL
TOTALS OF A. B, AND C .
1973
5,050,800
4. 898, 900
973, 700
240
0
10, 800
0

10,934,440
1974 i
4, 579. 700
5,010,000
770, 400
200
0
15,800
12,300

10,388,400
1975
3,441,900
5,039,600
395,900
0
0
6,200
4, 100

8,887, 700
1976
2,733,500
5, 270,900
314,600
o
0
8,700
0

8,327,700
1977
1,843,800
5.134,000
379,000
<100

15, 100
29, 700

7,401,600

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                               TABLE YE
                  OCEAN DUMPING PERMCTS1 PHASED'OUT/
                OR DENIED BY EPA REGION ENDURING 1977
         Company
    J.  T, Baker
    IMC Chem. Gr.
    Keuffel & Esser
    Oxochem Enterprises
    S.  B. Penick
    Lemming/Pacquin  •
    Whippany Paper Board Co
    Montville Twp. MUA
    W.  MilfordSTP
    Warren Twp. STP
    Avon-by-the-Sea STP
    Belmar STP
    Fairfield Boro STP
    Matawan STP
    Spring Lake Heights STP
    Wynnewood S. U.  Co.
**  Jersey City S. A.
**  Mayaguez Water Trnnt.
       Plant, Inc.
    Location
Phillipsburg, N. J.
Newark, N. J.
Rockaway, N, J.
Penuelas,  P. R.
Montville, N. J.
Parsippany,  N.J.
Whippany, N. J.
Montville, N.J.
W.  Milford.  N.J.
Warren, N. J.
Avon-fay-the-Sea, N. J.
Belmar, N. J.
Fairfield.  N. J.
Matawan,  N. J.
Spring Lake Heights, N. J.
Freehold, N.J.
Jersey City, N. J.

Mayaguez, P. R.
Date Phased Out
   or Denied
July  1977
March 1977
February 1977
August 1977
December 1977
December 1977
May  1977
December 1977
December 1977
February 1977
June 1977
June 1977
February 1977
July  1977
July  1977
February 1977
November 1977

November 1977
    ** withdrawn application

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To effectively implement the new criteria, new procedures dealing
with the solid phases of wastes and dredged material had to be
developed and the existing bioassay procedures had to be improved
in order to provide better measures of the chronic toxic effects and
bioaccunralation of certain constituents.  The revised Ocean Dumping
Regulations and Criteria state that an implementation manual describ-
ing the applicability of specific evaluative approaches and procedures
would be developed jointly by EPA and the  COE.


In July 1977, EPA and the COE published the manual "Ecological
Evaluation of Proposed Discharge of Dredged Material Into Ocean
Waters"--a multidisciplinary effort of both agencies to develop
procedurally sound, routinely implementable guidance and procedures
with which to evaluate the potential ecological effects of dumping of
dredged material.  The document is not intended to establish standards
or rigid criteria and should not be interpreted in such a manner.  It
attempts to provide a balance between the technical state-of-the-art
and routinely implementable guidance for using the procedures speci-
fied  in the Ocean Dumping Criteria, and is intended to encourage
continuity and cooperation between COE Districts and EPA Regions
in evaluative programs for Section 103 permit activities.


Additionally, a revised manual covering procedures for other
materials will be published in time to be used during the 1978 per-
mit cycle.   Both manuals present procedures resulting from recent
research by EPA and COE scientists and represent the first attempt
to apply benthic bioassays to an ocean pollution regulatory program.
The  bioassays contained in these manuals are to be run on the
wastes and the dredged materials themselves, not on the individual
constituents they contain.  Thus, the results of these tests will
show an integrated effect of the material as discharged, and will
provide a more sensitive and realistic assessment of the actual
ecological impact of the materials as dumped. The application
of criteria based on these procedures will,  in the long run, provide
a higher degree of protection for marine ecosystems than has been
possible in the past.


Research on all types of marine bioassays is continuing, and it is
anticipated that these manuals will be revised as more research is
completed and more information is derived from operational
activities.
                              25

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                     ENFORCEMENT

Surveillance and enforcement activities to prevent unlawful
transportation of materials for dumping and assure compliance
with ocean dumping permit conditions are the responsibility of
the U. S. Coast Guard.
The Ocean Dumping Regulations require permittees to give
authorities advance notification prior to commencing any dumping
operations. The Coast Guard conducts surveillance of the oper-
ations by several methods, including vessel or aircraft escort or
interception of dumper vessels,  in-port boarding and inspection,
shipriders on  board to observe dumping operations, and vessel
traffic system (VTS) radar.  Operational testing of a recently
developed electronic recording device,  the Ocean Dumping Sur-
veillance System (ODSS),  is expected to run until May 1978.
Future plans call for the installation on board dumping vessels
of operational systems commencing in 1978.
During 1977 the Coast Guard received 5, 116 notifications from
permittees for intended ocean dumping--330 for mixed industrial
wastes and 4, 786 for other permitted wastes.   A total of 1, 291
surveillance  missions were conducted--238 on dumps of industrial
waste and 1, 053 on dumps of other wastes,  representing respec-
tively a 72 percent and 22 percent Coast Guard surveillance coverage
for the two categories of wastes.  The missions were accomplished
by the following methods: 190 by vessels, 927 by aircraft, 156 by
shipriders,  17 by  VTS radar, and 1 by ODSS during testing.
In addition to Coast Guard surveillance,  alleged violations are
also detected by EPA and occasionally reported to EPA by other
organizations and private citizens.  All alleged violations of ocean
dumping are reported to the appropriate EPA Regional Offices.
In calendar year 1977, the Coast Guard referred to EPA Regional
Offices 35  cases that involved 226 alleged violations which included,
among others,  126 for dumping at an improper dispersal rate, and
77 for failure to provide proper notification.  The Regional Office
follows up  on all reports and investigates each case.   Letters of
warning are sent in many cases for failure to notify in advance of
dumping.   In cases where other violations are substantiated, notices
are issued and procedures taken under EPA enforcement regulations.
Table VIII identifies enforcement actions taken by EPA during 1977
and the disposition of each case.  Also included are several cases
for which action had been pending from a previous year and final
disposition occurred in 1977.
                               27

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ORDER
NO.
77-4
77-5/11



77-12
77-13
RESPONDENT'S
NAME
International
Liquors, Inc.
General Marine



Not issued
New York City
Dept. Water
Resources
REFERRAL
FROM
USCG
USCG




USCG
TYPE OF
VIOLATION
Dumping without
permit
Dumping at a
faster rate and
over a shorter
distance than
permitted

Failure to main-
tain facilities
in good working
NOTICE OF
VIOLATION
3/15/77
S/22/77&
5/11/77




8/17/77
DISPOSITION
Final Order-1
Reprimand
Pendin)




Pendin
                                                                                                            DISPOSAL
                                                                                                              SITE

                                                                                                          Virgin Islands
                                                                                                          Sewage sludge
                                                                                                          Sewage sludge
                                                  order
10
             77-14    Westchester Co.    USCG
                      & McAllister
                      Bros.

             77-15    A&S Trans.  Co.,    USCG
                      Ocean Disposal
                      Co., & McAllister
                      Bros.
Dumped outside
authorised
dump site

Dumped outside
authorized
dump site
                             8/18/77       Final Order-1/30/78
                                           Charges withdrawn


                             8/18/77       Final Order-1/31/78
                                           Charges withdrawn
                       Sewage sludge
                       Sewage sludge
             Region
                      City of Philadelphia EPA
             Region VI
                      Shell Oil Co.
             Region IX.
                      Bethlehem Steel
                      Corp, Crowley
                      Maritime Corp,
                      tug Seawolf
           Failure to adhere
           compliance sche-
           dule and reporting
           requirements
Permittee  Dumping outside
           site
 USCG     Dumping outside
           site
                   11/17/76
                   3/25/77
                   3/29/77
                                                                                   Pending-Adm. Law
                                                                                   Judge recommended
                                                                                   $225,000 penalty
                                                                                  Notice and Final
                                                                                  Order issued
                                                                                  3/25/77; no
                                                                                  penalty assessed
$7,000 penalty paid
7/15/77
                                                       Philadelphia
                                                       Galveston
                                                       Dredged Material
                                                       site

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as needed.   Assessments of available data on the dumpsites will be
completed during 1978,  and surveys will be conducted as necessary.
The surveys conducted under this contract will supplement those
surveys being conducted by NOAA and EPA Regional staffs.
A brief synopsis follows of each baseline survey presently being
conducted.
Sewage Sludge Dump Site in the New York Bight

Sewage sludge from the New York-New Jersey metropolitan area is
currently being dumped at a site approximately twelve miles from
shore. While no impact on the shores has yet been detected in EPA
and NOAA studies from sludge dumped at this site,  improved sewage
treatment in the New York-New Jersey metropolitan area will result
in greater volumes of sludge to be disposed of during the next  few
years. Much of this sludge may have to be ocean dumped at this site
as an interim measure until an alternative form of ultimate disposal
is selected and implemented.
In early 1974, EPA requested NOAA to recommend other areas in the
New York Bight for study as alternate sludge dumping sites.  NOAA
recommended two areas, one north and one south of the Hudson
Canyon.  EPA has completed studies, by contract,  of the north area
located about 60 miles from shore.  The  first survey was conducted
during September and October 1974; the second during January and
February 1975; and the third survey during July and August 1975.
EPA also supported NOAA studies on other parts of the New York
Bight and used the results of these studies, as well as its own, to
prepare an EIS on ocean dumping of sewage sludge in the New York
Bight. The Draft EIS was made available for public  comment in
February 1976.  The conclusions reached in the Draft EIS were that
dumping should continue at the existing site, that a comprehensive
monitoring program should be maintained for the existing site, and
that the alternate site should be  designated for use when and if the
monitoring program indicates that the  existing site can no longer
safely accommodate sewage sludge.  Publication of this EIS in final
form  was delayed pending a decision on relocating all sludge dumping
sites.  Now that a decision on this issue has been reached, steps
are being taken to implement the conclusions reached in the EIS.
For example, in August 1976,  Region II included the development and
implementation of a permittee monitoring program as a condition in
all new sludge permits.  This permittee monitoring program was
                              31

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Mixed Industrial Wastes Dump Site,  East of Cape Henlopen,
Delaware.  ("106" site)             '••   •••-.•., .•'-' -/"~

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 May, New Jersey. The site is off
the continental shelf at depths ranging from 1, 550 meters (m.) in the
northwest corner of the site to 2, 750 m, in the relatively flat
southeast corner. The bottom is generally characterized by a rugged
topography. A major topographic feature of the region, the Hudson
Canyon,  is to the north, northeast, and east of the dump site.
This site was used in 1977 by 12 different permittees located in New
Jersey, Delaware and Pennsylvania for the disposal of industrial
chemicals and by the City of Camden for the  disposal of sewage
sludge.
Typical waste materials include water solutions of inorganic salts
with trace amounts of organic materials, liquid wastes from manu-
facture of non-persistent organophosphate pesticides, residual sludges
and liquid wastes from the manufacture of Pharmaceuticals and similar
materials resulting from diverse manufacturing processes.  Contain-
erized radioactive wastes were dumped in a location just south of
the present  site years ago prior to enactment of the MPRSA, but the
dumping ceased under a self-imposed moratorium by the then Atomic
Energy Commission.


In May 1974, NOAA-began a series of baseline surveys of the 106 dump
site in cooperation with EPA, the Virginia Institute of Marine Sciences,
the Woods Hole Oceanographic Institution, the Lamont-Doherty Geological
Observatory of Columbia University, and the Smithsonian Institution.


Additional cruises were conducted in 1975,  1976,  and 1977.  Some
of these cruises made use of the manned submersible ALVIN,  and
data were also collected during some cruises at the radioactive waste
dumping area south of the dump site.


The hydrography of the dump site 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.  Circula-
tion patterns are affected by mixing across frontal zones.  Currents
run predominantly southward along the coast,  while the Gulf Stream
runs generally northeastward.
                             33

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    SITE
1.  Current N.Y.
   Sludge Site
2.  Galveston Site
3.  "106" Site
4,  Philadelphia
   Sludge Site
5.  DuPont Site
6.  N.Y. Acid Site
                                                                  OCEAN DUMPING SITES
                                                                         OF THE
                                                                    UNITED STATES
                                                            FOR MUNICIPAL AND INDUSTRIAL
                                                          WASTES AND CONSTRUCTION DEBRIS
                                                          CONSTRUCTION DEBRIS, WRECKS  A
                                                                       SEWAGE SLUDGE,  <>
                                                                     INOUSTRIALWASTES  •

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                 INCINERATION AT SEA
Destruction of combustible wastes by incineration at sea has
become recognized as a viable alternative to some methods of
land-based incineration and to the direct dumping of certain
materials into the marine environment.  This disposal technique
employs vessels that have been specially designed and equipped
with on-board incinerators.  The liquid waste to be incinerated is
pumped into a series of cargo tanks on the vessel and transported
to a designated ocean disposal site where, under carefully con-
trolled conditions, the waste is fed into the on-board incinerators
and burned at temperatures exceeding 1250°C.
The Motor Tanker (M T) Vulcanus, owned by Ocean Combustion
Services, B. V. ,  of The Netherlands, is one vessel as described.
For two years, prior to coming to the U. S. in September 1974, the
ship had been incinerating chemical wastes in the North Sea for
companies located in Europe.  The high-temperature incinerators on
board the Vulcanus are designed to oxidize upwards  of 99. 9 percent of
organochlorine wastes.  The resulting emissions primarily consist of
hydrogen chloride,  carbon dioxide and water, which are discharged
directly into the atmosphere without scrubbing.
During 1974 EPA determined that the Marine Protection,  Research,
and Sanctuaries Act would apply to incineration at sea, thereby requir-
ing a permit under the Act.  Shell Chemical Company requested a per-
mit to incinerate at sea 16, 800 Metric Tons (MT) of organochlorine
wastes.  EPA granted a Research Permit on October 10,  1974, for
the destruction of 4,200 MT of the wastes.
This first U. S, -sanctioned incineration at sea project took place
on board the M/T Vulcanus during October 20-28, 1974.  The desig-
nated disposal site was in the Gulf of Mexico, about 241 kilometers
(130 nautical miles) from the nearest land.  Specific conditions of
the permit required substantial monitoring to determine the feasi-
bility of this disposal technique and the impact of the resulting
emissions  on the marine environment.  Review and  analysis of the
large amount of data gathered during the incineration operations
concluded that the conditions and criteria of the permit had been
met and there had been no significant adverse impact on the
environment.
                            37

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Detailed information on the project and recommendations con-
cerning crew safety, communications and operations coordination
are contained in the EPA report, "At Sea Incineration of Organ-
chlorine Wastes Onboard the M/T Vulcanus, " published in
December 1977.
In January 1975, the U.S. Air Force applied for a permit to
incinerate at sea two stockpiles (2. 3 million gallons) of Herbicide
Orange which were being stored at Gulfport, Mississippi, and on
Johnston Island, a small Pacific atoll 800 miles west of Hawaii.
Public hearings on the permit application were held on April 25
and 28, 1975. As a result of the information presented, EPA
requested the Air  Force to explore the feasibility of a proposed
alternative to incineration--a method of reprocessing the herbicide
into an acceptable commercial product.  Final action on the permit
application was to be delayed until results of the feasibility study
were reviewed.
In March 1977, the Air Force presented a report on the repro-
cessing alternative and concluded that it was not a feasible alter-
native because more technology is needed to develop methods
to destroy the residual dioxin that result  from the reprocessing
method. The Air Force then requested that EPA reconvene the
hearings to further consider their permit application for
incineration at sea.
At the third hearing (April 7, 1977) the following conclusions and
conditions were decided:
     1.  Issue a Research Permit for an initial incineration of 4, 200
         metric tons (one shipload) of Herbicide Orange at an EPA
         designated site in the Pacific Ocean 120 miles west of
         Johnston Island.

     2.  Require detailed monitoring of the initial research burn,
         the dedrumming/transfer activities,  and temporary storage
         of the drums,

     3.  Provide for EPA review and analysis of the data obtained
         during the initial burn and make the data available to the
         public.
                              39

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Third burn began                             Aug. 24, 1977

Total stocks of Herbicide                     Sept. 3, 1977
Orange incinerated

Diesel fuel rinse burnj                        Sept. 8, 1977
project completed
The scope of activities for this effort included design and
preparation of the stack sampling and monitoring equipment,
preparation of a comprehensive safety plan, development of a
sampling and analysis protocol, acquisition of samples and
monitoring of stack emissions during incinerator operation,
as well as analyses of these samples followed by evaluation of
the results.  These details and plans were developed and
carried out through joint efforts of EPA, USAF, USCG and the
Military Sealift Command.
Total elapsed time for the three burns was approximately 714
hours, during which 11, Oil MT of the wastes were burned,
giving an average rate of 15. 4 MT per hour.  The incinerator
temperatures were  consistently uniform and comparable; the
average flame temperature was 1500 C.  Monitoring indicated
that combustion efficiencies and destruction efficisncies of the
herbicide components were in excess of 99. 99 percent, that
there were no adverse impacts on the personnel or the environ-
ment, and that  requirements of the EPA permits were met.
An EPA report describing the project in detail is being
prepared and will be published in 1978.

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Section 1008 of the RCRA provides for the development of guide-
lines that "describe levels of performance, including appropriate
methods and degrees of control that provide at a minimum for.. .
protection of public health and  welfare...."  Guidelines have been
initially planned to cover landfilling, landspreading,  and surface
impoundments for all solid wastes,  including municipal sludge.
As part of the construction grants program authorized by Title II of
the CWA, technical guidance on municipal wastewater treatment
sludge management has been developed and published to assist in
implementation of the program.  A technical bulletin, "Municipal
Sludge; Environmental Factors, " has been issued.  This technical
bulletin was developed to provide guidance to  State and Regional
construction grant personnel and to present information on sludge
management options to designers, municipal engineers and others
involved with wastewater treatment.  Guidance on costs and heavy
metal effects on plants and animals from agricultural application
of sludge has also been published.  Additional technical reports
supplementing the bulletin are planned.
Following from and in accordance with the regulations developed
under Section 405(d) of the CWA for the giveaway or sale of
sludge,  a home use bulletin will be published for wide distribution
to homeowners and other small consumers.   However, it is impor-
tant to point out that the  rulemaking process is neither a simple
nor an independent one.  The development of effective regulations
and guidelines, for example, requires a strong research,  develop-
ment and demonstration  base,  and the implementation of regulations
generally requires some technical and/or financial  assistance.
Guidelines and regulations issued under both the CWA and the
RCRA relating to land application and landfilling will go a long way
towards closing the gap that has existed in the disposal media for
sludge.  Further rulemaking under the CWA (e.g.,  covering the
giveaway and sale of sludge) will fill any remaining holes in sludge
utilization  and  disposal regulatory policy,  thereby helping to assure
to the fullest extent that both the environment and public health are
protected from harm1!!! and potentially harmful effects of unaccept-
able municipal sludge  management practices.
Of equal (and great) importance are efforts under the CWA to
require pretreatment of industrial wastes that enter publicly owned
wastewater treatment plants.  Implementation of these regulations
will render a high percentage of wastewater treatment sludges
acceptable for resource conservation and recovery programs.
                              43

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December 31, 1981.  Final phase out dates vary for each permittee
based upon the individual permit implementation schedule.  Each of
these permittees is, on a strict implementation schedule and closely
monitored by the appropriate Region.  All permittees are afforded
the opportunity to comply  with this condition using 201 Construction
Grant funding, and most have chosen this path.  Examples of some
of the technology being considered in the Facility Plans  (Step 1 Grant)
or currently being implemented are;
    Camden               )
    Middletown Township  )
    Northeast Monmouth   )
    Linden - Ro s elle        )
    Nassau County         )

    Bergen County         )
    Joint Meeting of Essex )
      and Union Counties   )
    Rahway Valley         )
    Wayne Township       )
    Lincoln Park          )
    Pequannock Township  )
    Pompton  Plains        )
    Oakland               )
composting
composting and use as landfill
cover as an interim solution;
co-recovery with solid wastes
as a long-term solution
incineration
    Middlesex County


    Glen Cove

    New York City
    Westchester County
multiple hearth incineration or
starved air combustion

co-incineration with solid wastes

composting or landfilling of
digested dewatered sludge as
an interim solution; utilization
of other technology, (pyrolysis,
co-recovery, etc. ) or shipment
out of the  city area or composting
as a long-term solution.

use of existing excess capacity
in solid waste incinerators and
composting of remainder

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violations of the ambient air quality standards,  and new facilities must
meet EPA standards as defined by New Source Performance Standards
for Sludge Incinerators (40 CFR 60. 15),

An extremely important consideration is the energy requirement for
sludge incineration. Without sufficient dewatering to allow self-
sustaining combustion,  a considerable amount of auxiliary fossil
fuel or electricity is needed to dry and incinerate the sludge. This
need accounts in part for the high cost of the process, which is
likely to increase  further as energy prices rise.  However,  it has
been demonstrated that municipal solid waste can be utilized to  pro-
vide the necessary energy (co-incineration).
2.  Starved-Air Combustion (Pyrolysis)

Starved-air combustion, sometimes referred to as pyrolysis,  is
similar to incineration in that it partially decomposes the sludge to
an ash and a gas in the presence of heat.  In contrast, this method
of sludge  destruction is performed in a low-oxygen or reducing
atmosphere.  If the sludge is dry enough, starved-air combustion
is a self-sustaining reaction which requires less input of energy and
produces  a gas that has low BTU value.
A pilot plant research program with a modified multiple hearth,
operating in a starved-air mode, was evaluated on representative
sewage  sludges from the New York-New Jersey metropolitan area.
The conclusion was that the technology is a feasible option to sludge
management.  Full scale  demonstration projects are now needed to
support the findings of the pilot project.
Processes to recover energy from sludge either by incineration
or starved-air combustion (with or without municipal solid waste)
are now under  consideration in a number of communities.  (In
addition, several European plants have been operational for many
years.)  These methods offer the advantage of recovering energy
resources  while at the same time reducing sludge volume.

3.  Surface Land Application

Application of liquid or dewatered sludge directly to the land is a
recycling method of disposal frequently used as a means of ferti-
lizing and renewing soil for growing crops and for reclaiming strip
mines and other disturbed land areas.  The potential for adverse
impact  from sludge landspreading practices can be minimized
through stabilization and proper site run-off management, pretreat-
ment of industrial wastewaters, sludge application rate,  soil pH, and
system monitoring.

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It is important to point out that the groundwater impacts from sludge
landfilling practices are not dissimilar to those that may 
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the sea.  The objective Is' to identify /toxic material whose disposal
might result  in the trophic or physical transport of pollutants beyond
the dump site.  Substantial interspecific differences were found
between five  test species.  A bivalve mollusk was found to be the
least sensitive  species tested and an amphipod crustacean the most
sensitive.  This was carried out as part of the  EPA/COE methods
manual for implementation of Section 103.
    Analyses of Water and Sediment at the Duwamish Waterways
    Disposal Site

Dredged sediments were deposited at a controlled experimental
dumpsite.  Results were obtained by monitoring physical and
chemical parameters in the water column and sediments were
evaluated to gain insight  regarding the effects of dredged material
disposal to open marine waters.  Long-term sampling was also
accomplished for water quality, sediment size distribution,  and
concentrations of interstitial chemical components.  This research
was performed as part of the COE Dredged  Materials Research
Project.
    Influence of Sewage Sludge and Dredged Material Disposal on
    Trace Metal Assimilation by Organisms         ——

This research effort assessed the sediment water exchange rates of
metals and nutrients in clean and polluted sediments and studied the
influence of bioturbation on the exchange rates.   Methods to measure
these rates  at disposal sites  were investigated.   Initial results, from
measurements of sediments, interstitial, and over-lying water reveal
that organic leaching rates may control the rate at which metal species
become available.  In highly polluted areas metals tend to be retained
as sulfides, whereas sulfates would exist in less polluted areas where
higher oxygen levels prevail. This work is now completed and a
report is in preparation.


    Determination of Organism Response to Burial By Dredged
    Material

A bioassay for evaluating the effects of dumping dredged materials will
be developed. A "microcosm" of benthic invertebrates is established
in a container with sediment from its habitat.  The purpose is  to deter-
mine the survival of the component species following burial under
various depths of introduced material.  Tests will be made with
(1) natural sediment, (2) sediment of different particle size, and
(3) polluted sediment.  Results of these experiments will be cor-
related with data from past and ongoing dredged material studies.
                              51

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advance knowledge of the behavior of toxic metals at the critical
fresh water/salt water interface in an urbanized estuarine system..
This project is now complete and a final report is in preparation.
    Environmental Monitoring Using Molluscan Shell-Growth and
    Life History Data

The project focuses on the development of a manual of techniques
describing methods for extracting molluscan life history data from
shell structures or death assemblages.  Demonstration of shell
growth techniques as an indicator of environmental stress has been
made at the Brenton Reef,  R. I.,  dredged material site using the
bivalve, Arctica islandica.  Population statistics of several short-
lived species will be examined at the New Haven,  Conn., dredged
material site.  The techniques and illustrations will substantially
aid our ability to assess  long-term impact on marine benthic popu-
lations exposed to contaminated sediments.  Technique development
is complete and field application is underway.
    Analysis of Statistical Methods Used to Determine Effects
    of Pollutants on Aquatic Populations

The final phase of this project will be devoted to analysis and com
parison of 4-5 years of field data in two bay  systems of northern
Florida.  Spatial and temporal parameters will be assessed in
several ways to determine the impact of single  sources of pollu-
tion or otherwise unaffected off-shore areas. This study will pro-
vide information on the reaction of coastal systems when pollution
abatement has been executed.
    Biological Analysis of Primary Productivity and Related
    Processes in New York Harbor as Reflective of Changing
    Water Q^ ality

The objectives of this four year study of New York Harbor and adja-
cent waters are:  (1) to provide information relevant to the kinds of
treatment necessary for municipal waste discharge into coastal waters
and how the various treatments might influence water quality, including
how changes in water quality may lead to massive algal blooms (noxious
and/or toxic) in these waters;  (2) to determine whether the quality of
waters in New York Harbor is  being affected or would be affected by
materials flowing into the area from the current offshore  sludge dump-
ing sites or from proposed alternate sites and how the toxicity of these
materials to the primary producers is reflective of changing water
quality;  (3) to construct a dynamic and predictive model system to
be used in the economic, sociological, and scientific planning for
the future development of water resources in this area.


          . im— 2&3-8BO/83            5 3

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