SECOND ANNUAL REPORT,;
BY THE U.S. ENVIRONMENTAL
PROTECTION AGENCY
ON
ADMINISTRATION OF THE OCEAN
DUMPING PERMIT PROGRAM
UNDER
The Marine Protection, Research, and
Sanctuaries Act of 1972, as Amended
(33 U. S.C. 1401)
Washington, D.C.
September 1974
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Table of Contents •
Page
I. Introduction and Executive Summary 2
II. Statutory Authorities 10
III. General Program Approach 12
IV. Present Operational Mechanisms and Procedures 19
V. Ocean Dumping Permit Program Status 23
VI. Some Additional Plans for EPA Programs Pursuant
to Title 1, Marine Protection, Research and
Sanctuaries Act, as amended 32
Appendices
1. A Comparison of Similarities and Differences in
the Marine Protection, Research, and Sanctuaries
Act, as amended, and the Federal Water Pollution
Control Act, as amended .. 33
2. Ocean Dumping Permits Not Granted or Being
Phased Out ' 37
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I. INTRODUCTION AND EXECUTIVE SUMMARY
In 1969 and 1970 considerable public concern was aroused by a
number of incidents involving the ocean disposal of nerve gas and
other warfare agents. This interest led to the [-Reparation of a report
by the Couns-il on Environmental Quality (CEQ) which addressed the
magnitude and nature of the entire ocean dumping problem and pro-
posed methods, both technological and legislative,- -to- deal • with it-.-—
At that time, prior to passage of the Marine Protection, Research
and Sanctuaries Act of 1972, responsibility for the control of ocean
dumping from certain ports was largely vested in/ti^e U.S. Army
Corps of Engineers (CE), and to a much lesser extent in the Atomic
Energy Commission (AEC) and the U.S. Coast Guard. The respon-
sibilities of the Federal Water Pollution Control Administration,
though substantial, were geared to continuous, discharges and to
a different and narrower geographic area.
CEQ's recommendations were to enact new legislation to:
- establish a permit system for ocean dumping based on envi-
ronmental effects;
-- broaden the geographic coverage; and
-- vest responsibility in an agency oriented toward environmen-
tal considerations.
These recommendations were embodied in the Marine Protection,
Research and Sanctuaries Act. The Federal Water Pollution Control
Act (FWPCA) Amendments of 1972 also regulates the disposal of mat-
erial into the marine environment by requiring the promulgation of
criteria to prevent degradation of the marine environment (Section
403) and their required application in the issuance of permits for
outfall disposal. The language of the criteria as presented in the
two laws is slightly different, as is their arrangement. The basic
thrust intended by the Congress is clear, however. Appendix 1 com-
pares the similarities and differences in the two laws insofar as ocean
disposal and ocean dumping are concerned.
During this same period international negotiations for the develop-
ment of an international treaty to regulate the dumping of wastes in
the marine environment were being conducted. In December 1972, the
United States signed the Convention on the Prevention of Marine Pol-
lution by Dumping of Wastes and Other Matter, and the Senate gave
its consent to ratification of the Convention in August, 1973. There
were some minor inconsistencies between the Treaty, commonly
called the International Ocean Dumping Convention, and the domestic
legislation which were rectified by the passage of PL 93-254 on
March 22, 1974.
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In its passage, of these laws'and in ratification of the Treaty, the
Congress made the national commitment for the protection of the
ocean, as well as inland and near-coastal waters.
It was apparent that the Congress took the view that protection of
the marine environment was of immediate concern in requiring that
criteria be developed based on the presently known impact of waste
materials on the oceans. At that time, however, only 10 of the 200
dumping sites in use had ever been studied in any respect, and most
of the other considerable ocean research had been directed toward
primarily theoretical oceanographic problems and phenomena. As a
consequence of this, there is a great dearth of knowledge on the im-
pact of wastes, a condition which must be rectified at the same time
the permit progrm is in operation. The Environmental Protection
Agency's (EPA) efforts to meet its responsibilities under the Act
are therefore undertaken with the realization that modifications of
the various program aspects can be expected in the future.
The Marine Protection, Research and Sanctuaries Act, as amended
prohibits the dumping of high-level radioactive wastes and all bio-
logical, chemical, and radiological warfare agents into the oceans.
The dumping of other wastes except dredged materials is to be strictly
regulated by the Environmental Protection Agency. The goal has been
the regulation of* all ocean dumping in such a manner as to prevent
any permanent damage to the marine environment at any dump site
and to allow only temporary minor perturbations during actual
dumping operation.
The general approach was to establish interim procedures and
criteria for the issuance or denial of permits on a general basis and
then to promulgate final regulations and criteria as rapidly as cir-
cumstances permitted. These were promulgated October 15, 1973.
The long-range strategy for the program envisions sequential
steps based on the achievement of intermediate operational goals.
This strategy is summarized in Exhibit A. Briefly, the steps include
the following: .
First, efforts were aimed at the development of procedures for
the issuance or denial of ocean dumping permits. EPA published in-
terim procedures on April 5, 1973. These included, as an interim
measure, a shortened period for public notice and hearings. The
final regulations, published October 15, 1973, were based on initial
operating experience with the program and on public comment on the
interim regulations. Some additional modifications will be made in
the future as additional operating experience is gained.
Second, EPA has published criteria which established the basis
upon which permits are issued or denied. These include quantitative
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EXHIBIT A
OCEAN DUMPIKG PROGRAM SCHEDULE
.CONTROL LEVEL
I
CONTROL L"EVEL
CONTROL LEVEL
III
LEVEL
IV
CONTROL LEVEL
V
Beginning Date
Procedures for Incjlr.g or
Drnring Permits
Criteria for Evaluating
Permit Applicsticns
Spring 1973
Ihterirr.; Shortened Time
for Public Notice
interim; Laboratory
M'-thods Acceptable to
Rrgior.s
Fall 1973
Final Regulations {§
Winter 1975
Final General Criteria;
Interim Laboratory
Methods Manual in Use
Criteria Made Specific for
Different Waste*: Final Lab-
oratory Methods Manual in
UBC
Summer 1977
Summer 1983
Final Criteria and Lab-
oratory Methods
7^
Evaluation and Designation
of Disposal Sites
Interim Designation of
Sites Alreajjy in Use
^'•rpin Trend Assess- •
nicnt and Uascline
.Surveys: Interim Sites
in Use
Initial Site Designations
Made Based on Environ-
mental Impact Statements
Site Designations Changed
as Required Da^cd on Up-£
dated ELV»
Ir.iplTn-nuiion of P!.in» b>
Curr;prrs to Meet Criteria
or Halt Ocean Dumping
All Permittees Examine
Alte rnati ves
Interim Permittees
Devclnp nnd Implement
Req'iired Pl.itis; Do Re-
search on their Waste's
Imp.ir.t on N'arlne
Envi ronment
All Permittees Using Dcst
Practicable Treatment of
Wastes Dumped Under
Permit
J/e»t A variable
Applied to All Wastes Oct-a.n
Ournprd ' >
Surveillance And
Enfo rcemenl
Surveillance and
Enforcement Procedures
Fully Operational
til^^Z^itf^ZXL^^
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criteria concerning allowable concentrations of certain materials and
analytical tests from which the probable impact of the waste materi-
als on the environment may be determined.
General requirements for all wastes areb.asedonthe best available
scientific knowledge at the time of publication ;;';r!rhe criteria allow only
a 50 percent increase over normal background concentrations of mer-
cury and cadmium in the part of the dumpsite" immediately affected by
the dumping and an average concentration in the""-mixing zone'"of'"no"
more than one percent of the waste concentration known to be toxic
to sensitive marine organisms.
The ultimate goal in developing criteria for the evaluation of ocean
dumping permits is to establish specific criteria for some wastes and
adequate general criteria for others. The needed research strategy
has been developed in consultation with the National Oceanic and
Atmospheric Administration (NOAA), the Corps of Engineers, the
Coast Guard, the Navy, the National Science Foundation, and EPA.
Exhibit B summarizes the milestones of this strategy.
The third step in the long-range strategy for the ocean dumping
program is the designation of dumping sites. As part of the publica-
tion of initial regulations and criteria the sites then in use for ocean
dumping were approved on an interim basis. These designations will
"continue until each site has been adequately surveyed and a determina-
tion made as to whether its use should be allowed or terminated.
Environmentally acceptable sites for disposal will be announced in
the Federal Register and will be supported by environmental impact
statements. Site designations are to be completed as rapidly as pos-
sible along with annual up-dates on all other previously surveyed sites.
At the inception of the program a number of municipalities and
industries were dumping wastes which were toxic or otherwise un-
acceptable for ocean disposal. The phasing out of these activities
is being implemented on a case-by-case basis. Lack of immediately
available alternatives has necessitated this phased approach.
Surveillance of dumping and enforcement of permit conditions
during actual dumping operations are being accomplished through the
efforts of the Coast Guard. 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, crim-
inal proceedings. The Coast Guard has reported some 30 apparent
violations, four formal enforcement proceedings have become neces-
sary. In other instances, the "violations" resulted from very minor
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navigational errors, misunderstandings on the terms of the permit,
or the fact that the dumpers were operating under previously existing
Corps of Engineers permits.
Interagency coordination is being achieved by an interagenc}' Com-
mittee composed of EPA, NOAA, the Coast Guard, CEQ, and the
Corps of Engineers. This Committee's purpose is to provide overall
program coordination. Programs have been initiated by the agencies
with research capabilities which will contribute to the objectives of
the ocean disposal research program. Both NOAA and EPA are work-
ing toward the development of baseline and trend assessment surveys
on a continuing basis. The Corps of Engineers has underway a five-
year dredged material research program which will provide EPA
with the baseline data necessary to evaluate dredged material dis-
posal sites.
The needs of the permit program for continuing information on
the health of the marine environment are only part of the total nation-
al need for data on the oceans. EPA and other agencies are also
actively participating in the development of a national marine monitor-
ing plan through an Interagency Committee on Marine Environmental
Prediction (ICMAREP) subgroup, the Subcommittee on Marine Envi-
ronmental Baselines and Monitoring (SC/MBM).
Despite the lack of precise scientific data concerning the impact
of most pollutants on the ocean environment, the permit program is
moving ahead. All ocean dumping is now closely controlled. This
means that only those dumping activities which meet environmentally
protective criteria or which are a part of an implementation schedule
leading toward compliance with such criteria are now permitted.
Most signifcantly, the option of uncontrolled dumping is no longer
available. Many materials which were once discarded to the detriment
of the oceans are now being reclaimed for new beneficial uses. At
the same time we are gathering scientific information and data with
respect to the interaction of pollutants and the ocean environment.
The permit program has been underway for a year. In that year
criteria have been developed for the evaluation of permit applications,
procedural regulations have.been prepared on an interim basis, some
110 ocean disposal sites have been identified, about 160 permit appli-
cations have been considered, and 55 permits have been issued.
About 70 additional permits have been denied, withdrawn, or placed
on compliance schedules to end or sharply reduce the amount of waste
being dumped. The remainder are pending. Tonnages being disposed
of by ocean dumping are summarized in Exhibit C.
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Exhibit B
KEY RESEARCH MILESTONES FOR DEVELOPING
CRITERIA FOR THE EVALUATION OF
OCEAN DUMPING PERMITS
Winter 1974
Summer 1974
Fall 1974
Summer 1975
Summer 1975
Winter 1975
Draft Interim Analytical Methods Manual
for the Ocean Disposal Permit Program
distributed to the Regions
Conduct Workshop to Assess Status of
Marine Bioassay Techniques
Publish Report on Improved Marine Bioassay
Techniques
- Revised Draft Interim Analytical Methods
Manual for the Ocean Disposal Permit
Program Incorporating Sampling Proced-
ures Prepared by NOAA.
Recommendations Available from
Office of Research and Development on
Revision of Criteria.
Issuance of Final Methods Manual.
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Ironically, 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 wa.stes from, both municipal and industrial waste streams.
Therefore, EPA's implementation of the marine protection program
called for in the legislation is designed to take into consideration the
entire ecosystem. A basic object, as the Congress obviously intended,
is to find and use the least environmentally damaging site and method of
disposing of each waste whether it involves land, air, or water. In
some cases, barging of wastes for final disposal in the ocean pro-
vides, and must continue to provide, both the least damaging site
and method.
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Exhibit C
OCEAN DISPOSAL: TYPES AND AMOUNTS, 1973
(In tons, approx. )
Waste type
Industrial waste
Sewage sludge
Construction and
demolition debris
Solid waste
Explosives
Atlantic
3,997,100^
5,429,400 -
1,161,000
0
0
Gulf
1,408,000
0
0
0
0
Pacific
0
0
0
240
0
Total
5,405,100
5,429,400
1,161,000
240
0
Total
10,587,500
1,408,000
240 11,995,740
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II. STATUTORY AUTHORITIES.
The Marine Protection, Research, and Sanctuaries Act, as
amended, commonly called the Ocean Dumping Act, absolutely pro-
hibits the dumping of high-lev^! radioactive-wastes and all biolog-
ical, chemical and radiological warfare a^e'tts 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 the Environmental Protection Agency"
(EPA) to balance the following factors in coming to a determination
whether to issue or deny a pemit: .
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 Sec-
tions 402 and 403 of the Federal Water Pollution Control Act, as
amended 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 maybe permitted, and designate critical areas where dump-
ing is prohibited. EPA must also give public notice and allow oppor-
tunity for public hearing before any permit is issued.
Dredged material may be dumped 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 econom-
ically feasible, and
2) EPA makes the determination that such disposal will not have
an unacceptable adverse effect on the environment.
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Surveillance of dumping operations to ensure that permit condi-
tions 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 II of the Act requires the National Oceanic and Atmospheric
Administration (NOAA) to support the permit program by initiating a
comprehensive program of research and monitoring to determine the
overall effects of man's activities on the marine environment. Title
III gives to NOAA authority to establish marine sanctuaries.
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III. GENERAL PROGRAM APPROACH.
The Act required full implementation of the ocean dumping per-
mit program six months after enactment. Permitting criteria were
developed utilizing existing and somewhat inadequate scientific know-
ledge and technical expertise in ocean dumping management, and all
ocean dumping came under strict regulation by the statutory effec-
tive date (April 23, 1973).
Interim procedures and criteria were established for issuance
or denial of permits on a general basis and final regulations and cri-
teria were promulgated as rapidly as circumstances permitted with
anticipation that major modifications would be desirable as experience
was gained and scientific knowledge expanded. The long-range strat-
egy for the program includes five sequential levels of control based
upon projected dates for the achievement of intermediate operation-
al goals. These are summarized in Exhibit 1 and are discussed here
in terms of the five operational activities shown in that Exhibit.
1. Procedures for the Issuance or Denial of Ocean Dumping Permits.
Administrative mechanisms for receiving and reviewing permit
applications, for conducting public hearings, and for actions taken
in regard to applications are needed to provide for equitable handling
of applications. Such procedures must provide a balance between the
expeditious processing of applications and the need for adequate inter-
nal and external review by all interested parties.
Interim procedures for issuing or denying permits were promul-
gated on April 5, 1973. These included, as an interim measure, a
shortened period for public notice and hearing. The final regula-
tions were published October 15, 1973, and were based on initial
operating experience with the program and on public comment on the
interim regulations. As in the technical aspects of the program,
additional modifications will be made in the future, although the reg-
ulations are substantively final in their present form.
2. Criteria for the Evaluation of Permit Applications.
Underlying these procedures, however, are the criteria on which
permitting, administrative procedure, and enforcement are based.
There must be published criteria which establish the basis upon which
permits will be issued or denied. These must include quantitative
criteria concerning allowable concentrations of certain materials
and analytical tests or other procedures by which the probable impact
of the waste materials on the environment may be determined.
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EXHIBIT 1
OCEAN DUMPING PROGRAM SCHEDULE
. CONTROL LEVEL
I
CONTROL LEVEL
II
CONTROL LEVEL
m
CONTROL LEVEL
IV
CONTROL LEVEL
V
Beginning Date
Proceflures for Issuing or
Denying Penult* i
Criteria for Evaluating
Permit Applications
Evaluation an-J Designation
of Li«po5»l Sites
Implementation of Plant by
Dumpor* to Meet Criteria
or Melt Ocean Dumping
Surveillance and
Enforcement
Spring 1973 .
Interim; Shortened Time ,
for Public Notice
Interim: Laboratory
Method* Acceptable to •
Regions
Interim Designation of
Sites Already In Use
All Permitteee Examine
Alternatives
Surveillance and
Ki nf o rccnif* nt Procedures JPr
Fully Operational
Fall ]973
Final General Criteria;
Interim Laboratory
Methods Manual In Use
Begin Trend Assess-
ment and Baseline
Surveys; Interim Sites
In Use
.Interim Permittees
Develop ftnH Implement
Required Plans; Do Re- gft
search on their Waste's
Impact on Marine
Environment
*
Winter 1975
*
Criteria Made Specific for
Different Wastes; Final Lap-
oratory Methods Manual in
Use
Initial Site Designations
Made Based on Environ-
mental Impact Statement*
V
Hj|fflHI!^B^BiVB^Bi^il9^BffiStflclp
— W^OI^^Mi^^B^MWIBMM^^r
•
Summer 1977
Final Criteria and Lab- fin
oratory Methods
Site Designations Changed
as Required Dated on Up- S
dated ElS'e
All Permittees Using Best
Practicable Treatment of
Wastes Dumped Under
Permit
Summer 1983
• >
- ?
'•>
/
>
^^flfffSSSSSSUS^SS^il^'fiifi
r
Best Available Technology
Applied to Alt Waste* Ocn
Dumped .
__\
7
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vC"
When the initial efforts were being made to develop criteria under
which disposal of wastes to the marine environment could be per -
mitted, knowledge was too incomplete regarding the impact of spe-
cific wastes on marine ecosystems to establish a regulatory base of.
quantitative criteria for each- type of waster or even for sufficiently
general definitive para.neters of impact. Liftle is known about ambi-
ent concentrations of other than major constituents of seawater.or the
natural variability of these constituents in coastal or oceanic _waters.
Another area of concern is the toxicity of wastes to specific marine
organisms, both on an acute and on a chronic basis. Rates of bio -
accumulation for some materials for some organisms are known,
but there is almost no .information available on the ambient levels
permissible for bioccumulative toxic materials.
As a result of the general inability to predict the effects of wastes
on the marine environment, general criteria were developed to cover
any reasonable conceivable situations involving the impacts of the dis-
position of wastes into the marine environment. Also, in devel-
oping such criteria it was necessary to recognize the fact that there
were little actual data on the ocean itself and that at least part of the
basis for the criteria must rest upon analogy to conditions in the
freshwater environment.
For the criteria to serve a reasonable basis for the issuance or
denial of permits for ocean disposal, they must meet these require-
ments:
1. They must be fully responsive to the statutes governing regu-
lation of ocean dumping and other waste disposal to the marine envi-
ronment.
2. They must be quantitative to the greatest degree possible with-
in the present state of knowledge.
3. They must be enforceable.
4. They must be consistent with present scientific knowledge and
theory. For each type of waste regulated a rationale was developed
in response to Section 102(a)(B, C, D, E, & F) that would set limits for
waste disposal which would assure that the waste could be dumped
safely into the marine environment without damage to the marine envi-
ronment, or to human health, welfare, social, economic, esthetic or
recreational values. Allowable concentrations of pollutants specified
in the legislation are:
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Mercury and its Compounds
Cadmium and its Compounds
An increase of no more than 50 percent above normal ambient
oceanic values is permitted in the mixing zone. That is, if the ambient
concentration of mercury is four parts per million, no more than
six parts per million is allowed to be present in the mixing zone
for more than four hours after completion of the dump.
Organohalogens
The waste may contain no more than 1 percent of the 96-hour TLm
(that concentration which kills one-half of all organisms being tested
within 96 hours) for any organohalogen; in the mixing zone, then,
no more than 1/10, 000 of the TLm value will be permitted.
Oils and Greases
The upper limit is that amount which will give a visible sheen
when mixed in a ratio of 1/100 with undisturbed water.
General Toxicity of Mixed Wastes
The upper limit is 1 percent of the TLm or other acute toxic level in
the mixing zone. The 1 per cent application factor is generally regarded
as a safe limit to use when specific toxicity values are not known.
Other specific requirements for other wastes are stipulated in the
published regulations including arsenic, lead, copper, zinc, vana-
dium, organosilicones, inorganic processing wastes such as cyanides
and fluorides, petro and organic chemicals such as aliphatic solvents
and phenols, and biocides, as well as many other potentially harmful
substances.
Within this administrative and technical framework, then, the
program is.moving forward with deliberate speed.
Interim criteria were published May 16, 1973, modified as a result
of public comment, and were republished as final criteria October
15, 1973. These are general requirements for all wastes and are
based on the best available scientific knowledge at the time of pub-
lication. The results of research now underway by EPA, NOAA and
others should provide a data base upon which to revise these cri-
teria. It is also necessary to develop a series of standardized proce-
dures and techniques to ensure that all wastes are tested to known
degrees of accuracy.
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A research strategy to accomplish this has been developed in
consulatation with EPA, NOAA, "the Corps of Engineers, the Coast
Guard, the Navy, and the National Science Foundation. The ultimate
goal in developing criteria for the evaluation of ocean dumping permits
is to establish specific criteria for some wastes and adequate gen-
eral criteria for others. Key milestones for achieving this goal are
as follows:
Winter 1974
Summer 1974
Fall 1974
Summer 1975
Summer 1975
Winter 1975
- Draft Interim Analytical Methods
Manual for the Ocean Disposal
Permit Program (distributed to
EPA Regions).
Conduct Workshop to Assess
Status of Marine Bioassay
Techniques
- Publish Report on Improved
Marine Bioassay Techniques
- Revised Draft Interim Analyti-
cal Methods Manual for the
Ocean Disposal Permit Pro-
gram Available Incorporating
Sampling Procedures Prepared
by NOAA.
- Recommendations Avail-
able from Office of Research and
Development on revision of
criteria.
- Issuance of Final Methods
Manual
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3. Designation of Dumping Sites."
Administrative' procedures for the designation of dumping sites
must be promulgated and the technical criteria for approval and dis-
approval must be defined. Specific requirements for baseline surveys
must be established and the mechanism for accomplishing such sur-
veys must be developed and implemented.
In the absence of reasonably complete knowledge concerning the
effect on the marine ecosystem of many wastes, sites in use for ocean
dumping were approved on an interim basis. This interim designation
ordinarily will continue until each site has been adequately surveyed
and a determination made as to whether to continue its use. Exception
may be made where wastes are considered to have minimal impact
and the opportunity exists for moving the site seaward beyond the con-
tinental shelf (as noted in the Act). Regulations for the designation
and management of ocean dumping sites are being developed and will
include the requirements for baseline and trend assessment surveys.
An interagency agreement concerning such surveys is being developed
with NOAA. EPA is also mounting supplementary surveys.
As studies progress environmentally acceptable sites will be ap-
proved through promulgation in the Federal .Register. Each desig-
nation will be supported by an environmentalimpact statement. Envi-
ronmental impact statements for »sites for the disposal of unpolluted
dredged material will be based on one-year monitoring programs of
typical sites now being conducted by the Corps of Engineers. The
schedule for accomplishment of.site designations is as follows:
Spring 1975 - First site designation environ-
mental impact statement pre-
pared (two interim dump sites
in Region III).
Summer 1975 - First group of site designations
completed.
Winter 1975 - Second group of site desig-
nations completed.
Summer 1976 - Third group of site desig-
nations completed plus annual
updates on all othe site
designations.
As well as providing the necessary technical base for the ocean
dumping activity, the program of baseline and trend assessment sur-
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veys, plus monitoring requirements imposed on dumpers, will form
part of an overall marine monitoring program by Federal agencies
with program missions in the marine environment. An interagency
plan for the coordination of activities and type of participation by
each agency is now in draft form and will soon be circulated among
the participating agencies for formal approval.
4. Surveillance and Enforcement.
An effective mechanism for surveillance of dumping operations is
required to ensure that permit conditions are met and that illegal
dumping is difficult to do without being caught. Violations of permit
conditions and illegal dumping reported to EPA must be subject to
vigorous enforcement action through the assessment of civil penalties
and, where necessary, by instituting criminal proceedings.
The Coast Guard is informed routinely of each dumping operation
and conducts surveillance to the extent that their resources allow.
Four formal enforcement actions have been taken based on some
thirty Coast Guard notifications to EPA regions of apparent violations.
In other instances, the "violations" resulted from very minor navi-
gational errors, misunderstandings on the terms of the permit, or
the fact that the dumpers were operating under previously existing
Corps of Engineers permits.
While some minor modifications of procedures may be made in
the future, no substantive changes seem to be necessary at present.
The Coast Guard is also exploring the use of automatic surveillance
devices as well as dumpsite marking techniques.
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IV. PRESENT OPERATIONAL MECHANISMS AND PRQCEDJRES
Types of wastes proposed for disposal in the ocean vary over
a very wide spectrum necessitating a variety of types of permits. Ex-
hibit 2 briefly describes the types of permits now available.
The authority to i^sue or deny speci^l-;-and interim permits,
set permit conditions, and modify or revoke them, has been delegated
to the Regional Administrators of EPA's ten regions. The authority
to issue or deny emergency permits, general permits;- and research ~
permits his been retained by the Administrator. In addition, EPA
Headquarters is responsible for overall coordination of the program
and the promulgation of all regulations, including.d.-'sposal site desig-
nations. Environmental assessments will be prepared in regional
offices, and released by the Administrator as part of the disposal
site designation procedure.
The following coordination mechanisms have been established:
1. An interagency committee for overall program coordination, .
consisting of EPA, NOAA, the Corps of Engineers, and the Coast
Guard. In practice most coordination is done on a bilateral basis,
and the entire committee meets only when there are substantive issues
affecting more than one program.
2. An intra-agency coordinating committee. The membership
of this committee is the same that made up the working group which
developed the regulations and criteria. Overall programmatic issues
other than regulations are frequently resolved -at the periodic meet-
ings.
3. General marine monitoring plans are coordinated through
the Interagency Committee on Marine Environmental Prediction and
its Subcommittee on Marine Environmental Baselines and Monitoring,
which is chaired by EPA. This Subcommittee meets on an intermittent
basis and is developing a national marine monitoring plan which in-
volves all Federal agencies with missions in the marine environment.
4. A special interagency committee on ocean dumping research
has been formed among EPA, NOAA, the Coast Guard, the Corps of
Engineers, the Navy, and the National Science Foundation (NSF) to
coordinate research activities. This group has participated in devel-
oping the program's research strategy.
The, major present operational activity of the program is in the
procedures for the processing of permit applications. This activity
is as follows:
-19 -
-------
Permit Type
Special*
Interim*
Emergency*
Research*
General
EXHIBIT 2
TYPES OF OCEAN DUMPING PERMITS
Restrictions and Use ;____
-Material must meet "limiting permissible
concentration" criteria for no adverse
impact.
-Ocean dumping must be most environ-
mentally acceptable alternative.
-Need to dump must exist.
*£.
-Materials exceed."limiting permissible
concentration" or "trace contaminant"
criteria.
-Dumper must develop and implement
acceptable schedule to improve waste
quality to meet the criteria, or
eliminate discharge entirely.
-Individual cases where an emergency
is demonstrated to exist posing an
unacceptable risk to human health.
-Cases which admit of no other
feasible solution.
-Requires State Department
coordination.
-Materials not prohibited by law or
regulation dumped for purposes of
investigation or research into the
impact of pollutants on the marine
environment.
-Materials of non-toxic nature in
small quantities.
Time Limit
3 years
1 year
Single use
18 months
Indefinite
*May require a public hearing.
- 20 -
-------
Permit Type Restrictions and Use Time Limit
Dredged
Materials -Materials removed from water bodies by Case-by-case
the Corps of Engineers in the course of
carrying out assigned functions, and
<•••- missions.' ''"•'••-• ,,..
-Must be reviewed by and receive con- ,.,_.^m
currence from the EPA Regional
Administrator from whose region the
waste is transported for disposal. .
- 21 -
-------
1.- After receipt of a completed application, the EPA regional
office makes a technical evaluation of the application, which includes
evaluation of the following factors:
a. Alternatives to dumping based on the review of the re-
gional staff.
b. Impact of the waste on the marine environment based on
the published criteria.
c. Need for the dumping.
d. Social and economic consequences of ocean dumping and
the alternative methods of disposal.
.- 2. Based on this evaluation a tentative determination to issue or
deny the permit is made and public notice is given of the tentative
determination.
3. A public hearing is held at public request or at the discretion
of the Regional Administrator.
4. The Regional Administrator issues or denies the permit.
Procedures for the implementation of the monitoring program,
including baseline and trend assessment surveys, are now being de-
veloped. These procedures in their present form assign management
of ocean disposal sites to EPA Regional Administrators and make
them responsible for the preparation of environmental assessments
(based on baseline and trend assessment surveys) on each site desig-
nation. The Environmental Impact Statements (EIS) themselves will
be prepared by EPA headquarters (by contract) and released as part
of the site designation procedure.
- 22 -
-------
V. OCEAN DUMPING PERMIT PROGRAM STATUS.
Final regulations and criteria for the issuance of permits were
published October 15, 1973. All permits issued under the interim
regulations published in April, 1973, were terminated as of
April 15, 1974, and all permits now in force were issued under the
final regulations and criteria. These and other key dates are noted
in Exhibit 3.
Except for minor or one-time dumps, examples of which are
shown with related material in Exhibit 4, all dumping of municipal
sewage sludge originates in the New York and Philadelphia metropol-
itan areas. The total volume of these muncipal sewage sludges is
almost equal to the volume of all other materials dumped. All dump-
ers of sewage sludge are operating under interim permits while devel-
oping and implementing plans to make their waste harmless or to
cease ocean dumping. Exhibit 5 summarizes the volumes of both
municipal and industrial wastes dumped in 1973 and compares them
with the volumes dumped in 1968.
- 23 -
-------
Exhibit 3
KEY DATES IN THE OCEAN DUMPING PROGRAM
October 23, 1972
April 23, 1973
March 22, 1974
* * * •
April 5, 1973
May 16, 1973
October 18, 1973
October 15, 1973
April 15, 1974
*
- Passage of PL 92-532
- Effective Date of Act
First Permits Issued
- Amendments to PL 92-532 Pass
jV ^ j1^ jV jj; jV jj* jV
- Interim Regulations Published
- Interim Criteria Published
- First Annual Report Transmitte
- Final Regulations & Criteria
Published
- Termination of All Permits
Issued Under Interim Regulatio
- 24 -
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EXHIBIT 4
EXAMPLES OF MINOR OR ONE TIME
Permittee
1. U.S. Army Corps of Engineers
2. Safety Projects, Inc.
3 Maiden Street
West Quincy, Massachusetts
3. ASS Transportation Company
75 Jacobus Avenue
Kearny, New Jersey
(for Stamford, Connecticut)
4. Safety Projects, Inc.
3 Maiden Street
West Quincy, Massachusetts
5. Fairhaven Marine, Inc.
P. O. Box 188
Fairhaven, Massachutts
6. Pine State By-Products, Inc.
Front Street
South Portland, Maine
7. Pfizer Chemical
Groton, Connecticut
8. McKie
South Boston, Massachusetts
Date of
Issuance Type of Waste
07-15-73 Derelict wooden barge
' "Comet" ; /
06-27-73 10,000 Ibs. sodium
300 Ibs. lithium
300 Ibs. potassium',
10-12-73 Primary sewage sludge
Amount of Waste
250'x40'xl2'
9,400 tons
Location of Dumping Duration
42°25.5V, 70°35'W One-timt
dump ,
42°25.5'N, 70°35'W One-time
dump
110-mile toxic waste One-time
dumping giound, dump
Region II
11-20-73 Miscellaneous laboratory " 5,500 gal./yr. 42°25.5'N, 70°35'W 11-15-74
reagents & chemical waste,
contaminated laboratory
equipment , , • . . i '
Pending ^ Derelict wooden ship
•v "Conquest"
114 tons
One-time
dump
04-04-74 Water from washing down 7,000 gal./day , 43°32'45"N, 69°55'W Ekf- rati
plant containing 1/2% 2.55 mil.gal./yr. ;
fish & poultry by-products
Pending Mycelium
04-27-74 Steel filings
1,200 tons/wk.
3,400 tons
42°25.5'N, 70°35'W 05-\j-~4
to
UI
-------
Permittee
Date of
Issuance Type of Waste
Amount of Waste Location of Dumping Duratic -.
9. Plantation of Mdnhegan Island Pending Table scraps, bottles, , etc. 800 #/day
June-September
10. U.S. Army Corps of Engineers Land
424 Trapelo Road alter-
Waltham, Massachusetts native
found
Derelict ship
Effortless I & II
11. Stamford, Connecticut
Pending Primary sewage sludge
12. Harbor Development Commission Pending Wooden barge
New Bedford, Massachusetts
7 mil.gal./yr.
500 tons
Sewer sludge ground Asking . or
one yea
One-tin--^
dump
I
to
-------
OCEAN DISPOSAL; TYPES AND AMOUNTS, 1968* AND 1973**
(IN TONS, APPROX.)
WASTE TYPE
Industrial Waste
Sewage Sludge
Construction
and Demolition
Debris
Solid Waste
Explosives
TOTAL
ATLANTIC
1968 1973
3,013,200 3,997,100
4,477,000 5,429,400
574,000 1,161,000
0 0
15,200 0
8,079,400 10,587,500
i
GULF
1968 1973
696,000 1,408,000
0 0
0 0
0 ' 0
0 0
696,000 1,408,000
PAC
1968
981,300
0
0
26,000
0
1,007,300
IFIC
1973
0
0
0
240
0
240
n
n
n
n
| |
M
M
II
if
ii
1 1
j|
j i
n
M
n
n
n
n
ii
n
ii
n
n
n
1 1
TOTAL
1968 1973
,690,500 5,405
,477,000 5,429
574,000 1,161
26,000
15,200
9,782,700 11,995
,100
,400
,000
240
0
,740
* 1968 Source - Council on Environmental Quality, Ocean Dumping - A National Policy, October, 1970.
** 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).
-------
Some 44 million cubic yards of dredged material were dumped
into the ocean during 1973 under authority of the Corps of Engineers.
Of this volume, only 2, 800, 000 cubic yards were dumped under permit
(almost all from New York and Philadelphia)- the remainder was
dumped by the Corps of Engineers itself under -conditions not requir-
ing EPA permitting. Exhibit 6 summarizes dredged material vol-
umes dumped in 1973.
Of the total of 163 permit applications received, 72 represented
wastes, primarily industrial, of a nature unacceptable for ocean dump -
ping. Appendix 2 lists, these applications and permits according to the
disposition made.
Eleven ocean dumping sites are now in active use for municipal
and industrial wastes; four are beyond the continental shelf. Site
survejrs are being conducted on three sites, and additional surveys
will be initiated in the first quarter of FY 75. These surveys are
designed to serve 'a two-fold purpose. The first is advancement of
knowledge of the effects of disposal in the oceans of a variety of
wastes which should result in improvement of criteria for ocean
dumping; the second is formation of the basis for environmental
impact statements to be prepared for each dumping site designated
on other than an interim basis.
These s-tu'dfes are being supplemented by EPA research activi-
ties, including' conducting investigations into ecological processes and
effects of ocean dumping.
principal activity, in the New York Bight region, is designed
to study any changes in benthic community structure occurring as a
result of digested sewage sludge contamination and the movement of
sludge particles dumped from barges. Two mathematical models
have been developed for this last purpose; one is a barge discharge
dispersion model that predicts the movement of particulates through
the water column, and the other is a circulation model for the New
York Bight that can be used to predict pollutant concentration over
time. Both models are being field validated as part of the New York
Bight study. EPA regional and research staff are also studying and
evaluating two dump sites, one industrial and one municipal, off
Delaware Bay.
Other efforts are experiments designed to assess and measure
contaminants (heavy metals, PCB's and hard pesticides) leaching
from spoils and sludges under simulated field conditions, using ap-
propriate analytical and bioassay techniques. Along with simulation
and mathematical model studies, afield study is being performed with
the object of coordinating and integrating laboratory studies with field
measurements.
- 28 -
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EXHIBIT 6
,0
I
DREDGED MATERIAL DUMPED IN OCEAN'- 1973
Corps of Engrs. Permits Total
(Cu. Yds.) (Cu. Yds.) (Cu.Yds.)
New England Division 1,611,000 453,000 2,064,000
North Atlantic Division
New York District 9,764,000 2,054,000 11,818,000
Philadelphia District 416,000 - 416,000
Norfolk District 35,000 - 35,000
South Atlantic Division
Jacksonville District 2,875,000 - 2,875,000
Savannah District 1,230,000 - 1,230,000
Wilmington District 2,501,000 - 2,501,000
Charleston District 1,159,000 - 1,159,000
Lower Mississippi Valley Division
New Orleans District - - - •
Southwestern Division
Galveston District 10,781,000 - , 10,781,000
North Pacific Division
Portland District 7,122,000 - 7,122,000
Seattle District 457,000 - 457,000
Alaska District 7,000 - 7,000
South Pacific Division
Los Angeles District 3,500,000 226,000 3,726,000
Pacific Ocean Division - 17,000 '17,000
41,458,000 2,750,000 44,208,000
- 29 -
-------
An interim analytical methods manual for the analysis of wastes
and marine environmental samples has been completed. This manual
is being used by EPA coastal regions in the operation of the ocean
disposal permit program while further research is being carried out
to develop and certify analytical methods specific to ocean dumping
problems.
In addition. Coast Guard Research and Development is working
on a positive recording navigation system which may alleviate a num-
ber of problems incurred in the ocean dumping surveillance program.
These are principally related to navigation, i.e., dumping at night
and lack of navigational equipment aboard transporting vessels. To
date, the Coast Guard has seen no need to promulgate regulations
on ocean disposal under the Act; however, they may do so in the
future if necessary to resolve this navigational equipment problem
and to implement adoption of a more positive navigation and surveil-
lance system.
The Coast Guard's enforcement program is keyed to close sur-
veillance of the disposal of toxic materials with spot-checks of non-
toxic material dumps. Surveillance methods include escort or inter-
ception of dumping vessels at the dump site by vessels, observation
of dumping operations by aircraft and harbor radar installations, the
use of ship riders to ascertain position and dumping rate, and the
spot-checking of ships' logs. From April 1973 to March 1974, there
were 422ocean disposal surveillance missions; 31 apparent violations
were referred to EPA. These were all investigated; four could not
be resolved and formal enforcement actions were instituted.
All four of these enforcement actions were initiated in the New
York region for the assessment of civil penalties as provided for by
Section 105(a)of the Act. The alleged violations ranged from a failure
to submit a plan for the segregation of industrial and municipal wastes
and the dumping of material without a permit to short dumping--
failure to dispose of material in the designated dump site.
In the first two notices of violation issued, a penalty amount was
proposed in an attempt to reflect the seriousness of the violation.
However, experience has indicated that this procedure is restrictive
and the proposal of actual dollar amounts has been omitted from the
most recent notices. As of June 30, 1974, no penalties had actually
been assessed; the most advanced proceeding was awaiting the find-
ings of fact and recommendation of the hearing officer. In each case,
within the notice of violation, allegations have been discussed with
the alleged violator and possible settlement prior to the hearing has
been unsuccessfully invited.
- 30 -
-------
VI. SOME ADDITIONAL PLANS FOR EPA PROGRAMS PURSUANT
TO TTTEE 1, THE~MATTlNE PROTECTION, RESEARCH, AND
SANCTUARIES "ACT AS AM EN D E D
The'outlook for EPA programs in response to Title I, of the Act
rests on the degree of success of three on-going program components:
1) the knowledge of present conditions gained from baseline"surveys,
2) the research program in identification of specific effects of certain
pollutants, and 3) continuing development of methods of sampling and
laboratory analysis specific to the marine environ..lent.
The baseline surveys will identify the normal biota and food chain
mechanisms in prospective dumping site areas and allow investiga-
tions of the effects on species normal to the area of wastes to be
dumped. The surveys will also allow closer determination of the
direction and certification of movement and ultimate rate of waste
dumped.
Some preliminary^literature searches indicate that certain sub-
stances harmful to freshwater biota may actually be helpful to marine
species, particularly in deep water "desert" areas. This aspect of
identification of specific effects of certain pollutants will be investi-
gated along with testing of substances known to be harmful. If proven
correct, EPA will encourage the dumping of such materials into the
ocean rather than allowing disposal to surface waters which may be
adversely affected, or to land or deep wells where future water supply
may be impacted.
Further development of sampling and laboratory analysis tech-
niques is probably the most immediate need in determination of the
effects of ocean dumping. Many pollutant-related methodologies are
borrowed from freshwater techniques which may or may not be direct-
ly applicable to wastes mixed with waters naturally containing high
concentrations (some 35 parts per thousand) of dissolved salts, metals,
and other materials. Although a number of techniques presently in
use allow for analytical interference by such substances, many others
must be adapted or completely changed to be useful.
Another sphere of investigation which lies somewhat further in
the future is that into possible synergism (i.e., when a combination
of two or more substances results in an increase in toxicity or other
effects) and antagonism (i. e., when a combination of two or more sub-
stances results in a decrease in toxicity or other effects) of pollutants
with natural ocean waters.
- 31 -
-------
NOAA and EPA have cooperated on one site survey and NOAA is
planning to absorb a large amount .of the baseline survey activity,
beginning in FY '76. NOAA has also reoriented its program on
Marine Eco-System Analysis (MESA) in the New York Bight area
to concentrate on ocean dumping problems.
32
-------
APPENDIX 1
SIMILARITIES AND DIFFERENCES IN
A'-COMPARISON OF THE MARINE PROTECTION,
RESEARCH, AND SANCTUARIES ACT, 'AS AMENDED,
("MPRSA") AND THE FEDERAL WATER POLLUTION"
CONTROL ACT, AS AMENDED ("FWPCA")
Geographical Coverage
Section 403(a) of FWPCA states that no permit for a discharge
into the territorial sea, the waters of the continguous zone, or the
oceans shall be issued unless in compliance with guidelines estab-
lished under Section 403(c).
"Oceans," as defined in Section 502(10)'of FWPCA means any
portion of the high seas beyond the contiguous zone.
MPRSA, Section 3(b), defines "ocean waters" as those waters
of the open seas lying seaward of the base line from which the terri-
torial sea is measured, as provided for in the Convention ontheTerri-
torial Sea and the Contiguous Zone.
Sections 502(8) and (9) of FWPCA define "territorial sea" and
"contiguous zone" in a manner consistent with the Convention on the
Territorial Sea and the Contiguous Zone.
Therefore, the criteria established under MPRSA and those re-
quired under Section 403(c) of FWPCA cover the same geographical
area: all open waters outside the baseline from which the territorial
sea is measured not including such areas as Puget Sound, San
Francisco Bay, Galveston Bay, Tampa Bay, Chesapeake Bay, Dela-
ware Bay, and Long Island Sound, for example.
Where any question arises, the official U.S. designation of the
territorial sea given on charts supplied by the Geographer of the
State Department is used.
- 33 -
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Requirements for CrKsria
Section 403(c) of FWPCA requires that the Administrator pro-
mulgate guidelines for determining the degradation of the waters of
the territorial seas, the contiguous zone, and. the oceans, which shall
include: •'•";:.
(A) The effect of disposal of pollutants on human health or wel-
fare, including but not limited to plankton, fish,"shellfish, wildlife,
shorelines, and beaches;
(B) The effect of disposal of pollutants on marine-life including the
transfer, concentration, and dispersal of pollutants or their by-prod-
ucts through biological, physical, and chemical processes; changes
in marine ecosystem diversity, productivity, and stability; and spe-
cies and community population changes; -
(C) The effect of disposal of pollutants on esthetic, recreation,
and economic values;
(D) The effect of the disposal at varying rates, of particular vol-
umes and concentrations of pollutants;
(E) The persistence and permanence of the effects of disposal of
pollutants;
(F) Other possible locations and. methods of disposal or recycling
of pollutants including land-based alternatives; and
(G) The effect on alternate uses of the oceans, such as mineral
exploitation and scientific study.
Section 102(a)of MPRSA states that the Administrator shall estab-
lish and apply criteria for reviewing and evaluating ocean dumping
permit applications, and in establishing such criteria he shall con-
sider, but not be limited to, the following:
(A) The need for the proposed dumping;
(B) The effect of such dumping on human health and welfare, in-
cluding economic, esthetic, and recreational values;
(C) The effect of such dumping on fisheries resources, plankton,
fish, shellfish, wildlife, shorelines and beaches; ""
(D) The effect of such dumping on marine ecosystems, particu-
larly with respect to:
- 34 -
-------
(i) The transfer, concentration, and dispersion of s'Sch
material and its by-products through biological, physical, and chem-
ical processes; .;.
(ii) Potential changes in marine ecosystem diversity,
productivity, and stability; and
.fr
(iii) Species and community population'dynamics.
(E) The persistence and permanence of the effects of the
dumping;
s (F) The effect of dumping particular volumes and concentrations
o'f such materials;
. • 6
(G) Appropriate locations and methods of disposal or recycling,
including land-based alternatives and the probable impact of requir-
ing use -of such alternate locations or methods upon considerations
affecting the public interest;
(H) The effect on alternate uses of oceans, such as scientific
study, fishing, and other resource exploitation, and non-living re-
source exploitation;
(I) In designating recommended sites, the Administrator shall
utilize wherever feasible locations beyond the edge of the continental
shelf.
Conclusions
The language of the two sets of general criteria is slightly differ-
ent, the items are arranged differently, and there is some overlap in
content, but the basic thrust and intent is clear. For example, refer-
encing the capital letters of the two sets of criteria:
!_. FWPCA (F); MPRSA (A, G)
,. There is the intent to consider all other methods of disposal or
recycling before issuance of a permit to dump or otherwise discharge
wastes into the ocean.
2. FWPCA (A, C); MPRSA (B, C)
There is the intent to consider the effects of the dumping or other
discharge on human health, welfare, social, and economic values,
including direct effects such as esthetics and recreational values and
indirect effects such as those affecting the usability of the marine
environment for the production and utilization of living marine re-
sources.
- 35 -
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2- FWPCA (B); MPRSA (D)
There is the intent to consider overall acute and chronic effects
of wastes on the entire marine ecosystem, specifically including the
transfer, dispersal, or concentration of waste materials through bio-
logical, chemical, or physical processes.
£. FWPCA (D); MPRSA (E)'
• Both Acts explicitly state that consideration must be given to the
persistence and permanence of the effects of the waste disposal.
5_. FWPCA (E); MPRSA (F)
Both laws state that consideration must be given to the effects
of dumping or otherwise disposing of particular volumes or concen-
trations of material.
6_. FWPCA (G); MPRSA (H)
Both laws require that consideration be given to alternate uses of
the ocean such as scientific study and resource exploitation.
7_. MPRSA (I)
The feasibility of utilizing disposal sites beyond the continental
shelf is a consideration only in MPRSA.
Thus, it is clear that both laws require the same careful consider-
ations be made whether ocean disposal occurs by dumping from a
barge or by disposal through an outfall.
- 36 -
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APPENDIX 2
OCEAN DUMPING PERMITS NOT GRANTED OR BEING PHASED OUT
1. Previous Reported Dumpers Phased Out:
Company
'• Location
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
'28.
29.
30.
31.
32.
33.
34.
Benjamin Moore & Co.
Chester Packing Co., Inc.
Childers Products Co.
Clairol, Inc.
Debell & Richardson
Dow Chemical Service
Drake Bakeries
Drew ^Chemical
Electro-Nucleonics, Inc.
Engelhard Industries
Fedders Corp.
Ford Motor Co.
Gamlen Chemical Co.
Heinzelmen & Sons
B. Horstmann Co.
I.C.I. America, Inc.
International Paper
Ivers -Lee Co.
Koppers Co., Inc.
'• Lehn & Fink, Co.
L & M Trucking Corp.
Makar Trucking Co.
National Can Corp.
NL Industries, Inc.
Norton & Sons, Inc.
New York Twist Drill
Mfg. Corp.
The Parker Co.
G. Redner, Inc.
Sandoz -Wander, Inc.
Three Star Anodizing Corp.
Universal Oil Products
Safety Projects, Inc.
Sun Oil Co.
Du Pont Co.
Newark, N.J. 07105
Chester ,-N.Y. 10918
Bristol, Penna. 19007
Stamford, Conn.
Enfield, Conn.
Stoneham, Mass.
Wayne, N.J. 07470
Boonton, N.J. 07005
Fairfield, N.J. 07006
Newark, N.J. 07105
Edison, N.J. 08817
Mahwah, N.J. 07430
Elmwood Park. N.J. 07407
Carlstadt, N.J. 07072
East Hanover, N.J. 07936
Bayonne, N.J.
Whippanjs N.J.
W. CaldwelVN.J. 07006
Kearny, N.J.
Belle Mead, N.J. 08502
Kenilworth, N.J. 07033
Mendham, N.J.
Piscataway, N.J.
Pedricktown, N.J. 08067
Bayonne, N.J. 07002
Ramsey, N.J. 07446
Wayne, N.J. 07470
Wanaque, N.J.
East Hanover, N.J. 07936
Beacon, N.Y. 12508
East Rutherford, N.J. 07073
West Quincy, Mass.
Marcus Hook, Penna.
La Place, La.
- 37 -
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Appendix 2 (page 2)
2.
Dumpers With Alternate Methods of Disposal Implemented
Per EPA Requirements: , .. •-
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
'Company
Location
General Color Co.
J.M. Huber Corp.
Lily-Tulip
The National Lockwaslier Co.
Howmedica, Inc.
Celanese Coatings Co.
American Cyanamid Co.
Green Village Packing Co.
The Mennen Co.
Weyerhaeuser Co.
Wilson Products Co.
American Cyanamid Co.
Kimberly-Clark Corp.
St. Regis Paper Co.
Hercules, Inc.
Dow Chemical
Newark, 'N.JV 07114 ——~~
Edison, N.J. 08817
Holmdel, N.J. 07733
North Bra.ich, N.J. 08876
Rutherford, N.J. 07070
Belvidere, N.J. 07823
Pearl River, N. Y. 10965
Green Village, N.J. 07935
Morristown, N.J. 07960
Closter, N.J. 07624
Neshanic, N.J. 08853
Bound Brook, N.J. 08805
Spotswood, N.J. 08804
West Nyack, N. Y. 10994
Kenvil, N.J. 07847
Mt. Holly, N.J. 08060
- 38 -
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Appendix 2 (page 3)
3. Permits/Applications Denied or Withdrawn Per EPA Requirements:
1.
2.
3.
4.
5.
6.
7.
8.
Company
Biocraft Corp.
BASF Wyandotte Corp.
The Clorox Co.
The Ansul Co.
Pratt & Whitney
Consolidated Edison Co.
Alcholac, Inc.
Everlon Fabrics Corp.
Location
Waldwicj, N. J.
So. Kearny, N.J. 07032
Jersey City, N.J. 07305
Marinette, Wise.
East Hartford, Conn. 06108
New York, N.Y. 10003
Ossing, N.Y. 10562
Closter, N.J. 07624
- 39 -
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Appendix 2 (page 4)
4. Dumpers Required to End Ocean Disposal By or Before June, 1975:
Company
Location
1.
2.'
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
Bell Telephone Laboratories
Blue Ridge-Winkler Textiles
The Nestle Co., Inc.
U.S. Radium Corp.
Tenco Division of the
Coca-Cola Co.
Warner-Lambert Co.
Mycalex Corp.
Worthington Biochemical Corp.
Howmet Corp.
Gaess Environmental Service
Corp., Chem-Trol Div. of
SAC Services, Inc.
Sherwin Williams Co.
Chevron Oil Co.
Du Pont Co.
Whippany, N.J. 07981
Bangor, Penna. 18102
Freehold, N.J. 07728
Hackettstown, N.J. 07840
Morris Plains, N.J. 07950
Morris Plans, N.J. 07950
Clifton, N.J. 07011
Freehold, N.J. 07728
Dover, N.J. 07801
Passaic, N.J. 07055
Newark, N.J. 07101
Perth Amboy, N.J. 08861
LaPorte, Texas
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