pollutants, though the permit applications often listed all of the characteristics of 

 wastewater discharges including toxic substances. While the 1972 Act did require 

 toxic substance standards to be developed and implemented through the NPDES 

 system, this plan never came to fruition for reasons related to the complexity of set- 

 ting toxic standards and industry resistance (Blumm, 1980). The Clean Water Act 

 has intensified the emphasis of the statute on toxic substance standards. Instead of 

 adopting widely applicable toxic effluent standards, implementation of regulations 

 concerning these substances in waste process streams will take place through tech- 

 nology-based standards for NPDES discharges, pretreatment standards for dis- 

 charges through publicly owned waste treatment plants (where toxic substances 

 prove to be incompatible with plant operation), and specific standards for new 

 sources (Blumm, 1980). It is not clear that this essentially complex system will be suc- 

 cessful in substantially reducing the load of toxic substances entering the waterways 

 of the New York region and thereby entering the New York Bight. 



Nonpoint Sources of Contaminants 



Although the many existing statutes of environmental law control the placement 

 of waste materials in all media including the oceans, the atmosphere, the land and 

 underground water tables, and the release of contaminants from specific point 

 sources such as industrial plants to the atmosphere and the water and land environ- 

 ment, a multitude of nonpoint sources of contaminants to the environment still exist 

 that are not adequately regulated. In a coastal ecosystem such as the New York 

 Bight, these nonpoint sources are limited to atmospheric fallout and precipitation, 

 erosion of and runoff from the land, together with the many minor events of uncon- 

 trolled and undocumented disposal of wastes by the public or small businesses, and 

 discharges from the many vessels utilizing the New York Bight. The quantity of con- 

 taminants introduced to the ocean by these nonpoint sources can in some instances 

 be quite large. Duce et al. ( 1976), for example, have estimated that up to 1 3 percent 

 of the lead, 8 percent of the zinc, 5 percent of the iron, and 1 to 2 percent of the cad- 

 mium entering the New York Bight may do so by way of the atmosphere through 

 particulate fallout and rainfall. Kneip et al. ( 198 I ) have similarly estimated that the 

 contribution of PCBs through atmospheric fallout to the New York Bight is signifi- 

 cant compared to other sources. 



The most important nonpoint source of contaminants to the estuarine and ocean 

 system appears to be the runoff of storm water, washing contaminant-laden material 

 off the streets and the land. Street and land runoff contain diverse contaminants such 

 as agricultural chemicals, hydrocarbons from crankcase and other waste oils, and 

 synthetic organics including PCBs and trace metals from a multitude of diverse 

 sources. In urban areas such as the New York-New Jersey region, where sewer sys- 

 tems and storm drain systems are combined, much of the material from nonpoint 

 sources entering the water environment does so through combined sewer overflows 

 during periods of rainfall, as discussed in more detail below. 



Although the nonpoint sources of contaminants entering the New York Bight are 

 at present small compared to the direct sources, they will constitute a growing pro- 

 portion of the total contaminant load as the concentrations or loadings of toxic con- 

 taminants in direct sources are brought under control by the various environmental 

 statutes. For at least some contaminants, it is certain to prove necessary or desirable 

 to reduce contaminant loadings to levels that will require control of the nonpoint 

 sources. This is particularly likely for petroleum hydrocarbons. At present, the ex- 

 isting environmental statutes do not adequately address the need or the means to 

 reduce such nonpoint sources and the technological problems that exist with devel- 

 oping such legislation and control practices are difficult. The lack of regulations to 

 control nonpoint sources of contaminants is a potentially serious environmental 

 problem. The development of such regulations and technologies whereby the regula- 

 tions can be implemented should be a matter of priority. 



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