744 
Answer. In general, monitoring responsibilities are divided along the following 
lines: permittees and EPA have site-specific monitoring responsibilities; EPA is re- 
sponsible for monitoring data related to dumpsite designation and management; and 
NOAA is concerned with ecosystem response and trend analysis, and other broad 
issues related to ocean pollution and to the continuing health of the oceans. 
EPA administers a program of compliance monitoring conducted by dumpers in 
accordance with permit provisions. This effort is oriented toward specific wastes, 
concentrations, locations, water quality, and other factors associated with KPA’s site 
management responsibilities. Sewage sludge disposal permittees at the 12 mile site 
are monitoring their disposal activities in a cooperative manner, pooling their re- 
sources proportional to the amount of wastes dumped in the Bight. In addition, 
Region II USEPA (NY) also monitors beach areas in the summer months to assure 
bathers of safe swimming. 
A second category of monitoring is required for several reasons: (1) to assist EPA 
in decisions on whether use of given dumpsites should be continued or discontinued, 
and under what circumstances, and (2) to meet NOAA’s concerns on waste interac- 
tions, and the ability of ecosystems to accept wastes under varying conditions. These 
joint needs can often be met by common data. For example, cooperative NOAA/ 
EPA programs such as the Northeast Monitoring Program, have been developed. 
In addition, the Coast Guard conducts permittee compliance monitoring, using 
shipriders and flyovers, in support of the ocean dumping program. 
Question. Is there general agreement between the Federal agencies on the moni- 
toring activities that are necessary for ocean dumping? 
How would you define “monitoring” in terms of what activities would be carried 
out and in what ocean areas for purpose of collecting a fee? 
Answer. The Federal agencies do generally agree on what monitoring activities 
are necessary for ocean dumping. The Agency and NOAA have engaged in several 
joint projects, among them the Northeast Monitoring Program mentioned earlier. 
Monitoring consists of three general types of activities: compliance monitoring, to 
ensure that the terms and conditions of a permit are being met; site-specific moni- 
toring to identify the impacts of ocean dumping and to ensure that it is not having 
undesirable or unanticipated impacts in or around the site being used; and general 
environmental monitoring, to monitor the health of the marine environment and 
the impacts of marine pollution from all sources. An ocean dumping user fee should 
recover the costs for the first two types of monitoring, but not for the latter type. 
Question. What would be the ideal budget for an adequate monitoring program 
and what would be the objectives of such a program? 
An “adequate” monitoring program and the “ideal” budget for it can only be de- 
fined in relation to the specific dumping activities being monitored. The types and 
amounts of wastes being dumped, and the sities being used, will determine the 
kinds of monitoring needed and the costs for such monitoring. For example, the 
ocean dumping of municipal sludge and other wastes with solid components should 
be monitored to detect whether there is settling of the solids and to determine what 
impacts, if any, may occur. Such monitoring would not be appropriate for liquid 
chemical wastes, and may not be feasible or appropriate at deepwater sites off the 
outer continental shelf. Any type of monitoring is significantly more expensive at 
deepwater sites than at nearshore, shallower sites. 
Based on the dumping currently ongoing, EPA expects to spend approximately 
$1,250,000 on monitoring activities in fiscal year 1983. This is in addition to the 
monitoring activities carried out by permittees and other Federal agencies. For the 
type and amount of dumping involved, this is an adequate budget for an adequate 
monitoring program. 
Question. Is it reasonable to expect your Agency to be able to accurately estimate 
the costs to be incurred for your monitoring activities sufficiently in advance in 
order to assess the fees to user? 
Answer. There will be no problem in estimating the costs of monitoring and other 
program operation activities provided the fee is assessed on a yearly basis. These 
estimates would be made as part of the budget process, with or without the user fee, 
and could be fairly well estimated within about six months before the beginning of a 
fiscal year as both permittees and the Agency have a fairly good idea as to the ex- 
pected volume to be disposed of in any year. 
Question. Isn’t it true that EPA required daily reports from the 102 permittees 
concerning their monitoring activities? 
It is my understanding that these reports sometimes fall far behind in being deliv- 
ered to EPA—sometimes by several months. Why didn’t you demand this informa- 
tion from the permittees in a more timely manner? 
