Permitting 



As noted above, the nine municipal sludge dumpers have no 

 current EPA permits to ocean dispose sludge. Since the 1981 

 court decision discussed under "Historical Perspective", all nine 

 of the sludge dumpers have been operating under court orders. In 

 July 1986 EPA notified the nine sludge dumpers that, in order to 

 continue to utilize the DMSDS, they must submit permit 

 applications consistent with the criteria specified in MPRSA. 

 MPRSA specified that ocean dumping permits may not be issued 

 unless the applicant can demonstrate that there are no 

 alternative land-based disposal methods available that are 

 technically feasible, economically reasonable, and likely to have 

 less adverse impacts on the total environment and human health 

 than ocean disposal. EPA requested that these applications be 

 submitted by January 1987. 



EPA received applications from three New York sludge 

 generators in January 1987. The six New Jersey authorities, 

 however, requested an additional six months to submit their 

 applications. In August 1987, one application was submitted on 

 behalf of all six New Jersey dumpers. In November 1987, EPA 

 completed its review of the permit applications and determined 

 that all of the applications were incomplete because they did not 

 contain a current or viable analysis of land-based alternative 

 disposal methods and technologies. EPA sent letters to the 

 applicants informing them that additional information was 

 required in order for the applications to be considered complete. 

 The applicants submitted additional information on incineration, 

 landfilling and/or composting in January 1988. EPA has completed 

 its review of this additional information, but must engage in 

 further negotiations with the applicants to conclude 

 compliance/enforcement agreements to end the ocean dumping of 

 municipal sludge in compliance with the Ocean Dumping Ban Act. 

 These matters must be resolved before EPA can make its final 

 determination regarding permit issuance. 



Site Management 



EPA has site management responsibilities at all ocean 

 disposal sites. As part of these responsibilities, EPA has 

 developed a monitoring plan for the DMSDS with the objective of 

 assessing actual and potential impacts of sludge disposal on the 

 marine environment, both at the site and in adjacent areas. Data 

 collected is being used to make decisions regarding both the 

 issuance of permits in compliance with the Ocean Dumping Ban Act 

 and the design of future monitoring programs. 



44 



