Plastic Pellets in
the Aquatic Environment:
Sources and Recommendations
United States
Environmental Protection Agency Office of Water (WH-556F) EPA 842/B-92/010 Dec92
5.0 Controlling Pellet Resources
[Table
of contents | Executive Summary
| Sections 1
· 2 · 3
·
4 · 5
· Glossary | Tables
| References ]
The Environmental Protection Agency (EPA) is concerned about the presence of
pellets in the aquatic environment for several reasons: (1) pellets are
ubiquitous; (2) pellets have been found in considerable quantities in coastal
areas of the United States; and (3) laboratory studies and field observations
suggest that ingested pellets may harm or kill aquatic wildlife, including
several endangered or threatened species. These issues were detailed in Section
3.0 of this report.
Pellets are released to the environment as a result of plastics industry
activities, and major transport pathways to the environment were highlighted
during the site visits to several industry companies (Section 4.0). During the
site visits, Company officials stated that during normal operations, most of the
released pellets can be captured easily by existing pellet containment systems.
However, under severe weather conditions (heavy rainfall) many of the pellets
may escape even the best pellet containment systems. Unfortunately, once plastic
pellets are released into the environment they cannot be easily recovered,
therefore, the most realistic mitigation measure available is the prevention of
discharges.
EPA believes that immediate industry action is needed to prevent pellet
releases to the environment. Effective prevention of pellet releases requires
both the implementation of appropriate voluntary control measures as well as a
regulatory framework. Section 5.1 presents recommendations to the plastics
industry for preventing and controlling pellets releases to the environment. The
current regulatory framework and steps being taken by the industry to control
pellet releases are included in Section 5.2.
5.1 Recommendations to the Plastics Industry
The following recommendations for preventing and controlling pellets releases to
the environment were developed based on the site visit observations (described
in Section 4.0), knowledge of plastics industry operations, a literature review,
industry recommendations (SPI, 1991), and Department of Transportation (DOT)
Cargo Security Advisory Standards (49 CFR Part 101). Concurrent with this study,
the Society of the Plastics Industry, Inc. (SPI) has also developed
recommendations for controlling pellet releases; these recommendations have been
incorporated into the following discussion. The specific recommendations are
organized according to eight general areas: industry management; education and
training; equipment and facilities; routine operations; maintenance and
housekeeping; packaging; shipping; and recycling and waste disposal. Table 10 is
a summary of the recommendations and indicates the sectors to which to each
recommendation applies.
Table 10. Summary of Recommendations to the Plastics Industry According to Industry Sector.
Tran/
Recommendation Prod Pack Proc
Management
Adopt and implement SPI's Pellet Retention Environmental Code. ● ● ●
Conduct self evaluations to identify problem areas. ● ● ●
Encourage information sharing between companies. ● ● ●
Continuing developing educational materials. ● ● ●
Education and Training
Educate key officials and company managers regarding the fate and ● ● ●
effects and the economic disadvantages of pellet loss.
Educate company employees regarding environmental hazards and ● ● ●
employee responsibility for corrective actions.
Train pellet handlers to operate equipment, particularly fork lifts, ● ● ●
in a manner that minimizes the potential for pellet loss.
Train longshoremen and other cargo handlers regarding proper pellet ●
handling procedures.
Equipment and Facilities
Install a containment system to capture storm water runoff. ● ● ●
Improve dry cleanup procedures. ● ● ●
Install connecting hoses equipped with valves that will close ● ● ●
automatically when the connection is broken.
Direct the water flow from rail hopper cars and bulk trucks through ●
a screen to capture the pellets rather than spilling them onto the
ground.
Seal expansion joints in concrete floors with a flexible material. ● ● ●
Install alarms in the pellet conveying system. ● ● ●
Pave all pellet handling areas, including loading docks and rail ● ● ●
sidings.
Place screening in storm drains. ● ● ●
Place control devices where they can be serviced without ● ● ●
losing pellets.
Equip bag-handling stations with vacuum hoses to facilitate ● ● ●
spill cleanup.
Use tarps or containment devices to collect pellets as they ● ● ●
are spilled.
Install grating at doorways for wiping feet. ● ● ●
Modify loading systems so that transfer lines can be completely ● ●
emptied, with any residual resin being contained when
loading ceases.
Routine Operations
Place portable screens underneath connection points when making ● ● ●
and breaking all connections.
Place permanent screens along the exterior edge of the loading docks. ●
Completely empty transport and storage vessels before disconnecting ● ●
from the conveying system.
Supervise longshoremen and other cargo handlers during cargo loading ●
and unloading to ensure proper pellet containment.
Inspect cargo immediately upon receipt and note the condition of ● ●
shipping containers and parcels on the carrier's receipt.
Inspect seals on rail hopper cars before unloading. ● ●
Check outlet tubes for pellets before moving rail hopper cars ● ●
or trucks.
Secure outlet caps and seals before moving full or empty rail ● ● ●
hopper cars and trucks.
Insist on handling procedures that minimize punctures and ● ● ●
pellet spillage.
Do not sweep pellets off loading docks and into the water. ●
Repair punctured bags immediately ● ● ●
Maintenance and Housekeeping
Improve daily and routine housekeeping and spill response procedures. ● ● ●
Develop SOPs for containing and cleaning up spills. ● ● ●
Conduct routine inspections for the presence of loose pellets on the ● ● ●
facility grounds, including parking lots, drainage areas,
driveways, etc.
Packaging
Design puncture-resistant shipping containers. ● ●
Use reinforced bags and line containers with puncture-resistant ● ●
material.
Minimize the use of valved bags, or seal valved bags immediately ● ●
after filling.
Use sea containers instead of break bulk packaging. ● ●
Improve palleting methods. ● ●
Tape leaks or replace leaking bags immediately. ● ● ●
Inspect pellet packaging before offloading. ● ●
Shipping Vehicles
Use containers for cargo shipping rather than individual pallets. ● ●
Identify the person responsible for sealing the ports on rail hopper ● ●
cars and bulk trucks, and document sealing.
Close and secure the rail hopper car valve with strong wire or ● ● ●
aircraft cable in addition to the normal sealing mechanism.
Visually confirm that each compartment and tube of shipping vehicles ● ●
is empty.
Inspect interiors of trailers and sea containers for defects that ● ●
may puncture pellet packaging.
Consider vandalism exposure when selecting leased track sites. ● ●
Avoid on-deck pellet stowage. ●
Do not jettison pellets or containers of pellets. ●
Seal empty rail hopper cars and bulk trucks before returning them ● ●
to shipper.
Recycling and Waste Disposal
Store waste pellets in properly labeled containers. ● ● ●
Inspect and confirm proper handling and storage procedures if an ● ● ●
outside vendor is used for waste removal.
Recycle or resell waste pellets. ● ● ●
Check broken and discarded packaging for residual pellets. ● ● ●
Prod: Producers.
Tran: Transporters.
Pack: Contract packagers.
Proc: Processors.
● : checked
source: http://www.epa.gov/owowwtr1/OCPD/PLASTIC/10-recs.html 14apr03
5.1.1 Industry Management
Poor communication between industry management and management of related
industries hampers the identification and elimination of pellet release
pathways. Despite the SPI efforts to educate the industry, some company managers
did not understand the pellet problem and the need to control pellet releases.
Information is rarely shared between companies in regard to pellet spillage, the
condition of shipped packages, and the receipt of unsealed rail hopper cars.
The following are recommendations for controlling the release of pellets into
the aquatic environment through improving industry management practices.
- Adopt and implement SPI's 1991 Pellet Retention Environmental Code
and 1992 Processor's Pledge. The code and pledge are presented
and discussed in greater detail in Section 5.2.3.
- Conduct self evaluations to identify problem areas. The checklists
developed by SPI (1991) should be used by each sector (Appendix).
- Encourage information-sharing between companies. The information
transfer should include pellet containment system successes, identification
of problem areas (e.g., the manufacturer should notify a processor if the
rail hopper cars return with valves open and unsealed), and other industry
successes and failures in pellet containment. This communication should
extend between companies of the same sector (manufacturer to manufacturer,
etc.) and between companies of different sectors (manufacturer to packager,
processor to manufacturer, etc). Good examples of information transfer are
the Dow Chemical and Paxon Polymers videotapes of their containment systems.
- Continue developing educational materials, advertising in trade
journals, conducting presentations at professional meetings, sending
mailings, and producing videotapes for distribution throughout the industry.
5.1.2 Education and Training
The least expensive and the most effective first step to controlling the release
of pellets into the aquatic environment is through education. Many industry
officials believe that pellet releases result more from improper employee
attitudes than from equipment failure. This would indicate that employee
education is critical to the success of any corrective action. Recommendations
are to
- Educate key officials and company managers regarding the fate and
effects of plastic pellets and the economic disadvantages of pellet loss.
Despite SPI's efforts, some company officials remain unaware of the
environmental impacts of pellets, and, therefore, industry-wide education
and education and training within each company is needed. Stress the
economic considerations of controlling pellet releases, the economic
benefits of recovering and recycling lost pellets, and the economic
disadvantages (loss of feedstock, loss of recycling revenues) and regulatory
penalties [National Pollutant Discharge Elimination System (NPDES) permit
violations] for releasing pellets. Also, use modern teamwork practices to
solve problems, and build a consensus and commitment to the task (SPI,
1991).
- Educate company employees regarding the environmental hazards of
pellets and employee responsibility in instituting corrective actions.
If employees feel involved or responsible they may provide simple and useful
solutions to eliminating pellet release pathways. This can be accomplished
through (1) conduct of employee awareness programs to educate personnel of
the need to prevent pellet loss. This could include posting SPI educational
material (described in Section 5.2.3), throughout the facilities,
particularly in areas where pellets are frequently spilled. A short
presentation (i.e., lunchtime seminar) and forum for discussion should be
initiated with the employees; (2) establishing boundaries of responsibility
for spill response and cleanup (SPI, 1991). For example, designate one or
more persons per shift who will be responsible for ensuring prompt and
thorough spill cleanup within a specified work area, or for monitoring and
managing a pellet retention program; and (3) initiating a system of rewards
for creative solutions for pellet containment and exemplary performance in
preventing pellet loss to the environment.
- Train pellet handlers to operate equipment, particularly forklifts, in
a manner that minimizes the potential for pellet loss. For example,
train the forklift operators to exercise greater caution when handling
pallets of pellets, such as ensuring that the tines of the forklift are
properly aligned before contacting the pallet.
- Train longshoremen and other cargo handlers regarding proper pellet
handling procedures (49 CFR Part 101). CMC (1988) also recommended that
these workers be trained in the handling all cargo wastes.
5.1.3 Equipment and Facilities
Many companies have few cooling-, waste-, and storm-water containment systems
for controlling the release of pellets from the facility, or methods for
immediately controlling spilled pellets. Recommendations for controlling pellet
releases to the aquatic environment by improving existing equipment and
facilities are presented below.
- Install a containment system to capture storm-water runoff from
pellet-handling facilities. The design of these systems must take into
account worst case storm-water discharges; SPI (1991) recommends a system
capable of handling "50- to 100-year high" conditions. Within the
containment system, install baffles, skirts, booms, surface skimmers, and
vacuum systems to accumulate and remove pellets (SPI, 1991). Two possible
containment systems could be installed: (1) an area-specific containment
systems in each pellet handling area. Area-specific containment systems
would be the primary pellet containment systems and the facility-wide system
would serve as a backup; or (2) a facility-wide containment systems, such as
the systems used at Companies F and G (detailed in Section 4.2.2). These
systems are effective in controlling pellet releases from facilities
covering a large area and handling large volumes of pellets.
- Improve dry cleanup procedures, particularly in areas subject to
storm-water runoff. By allowing pellets to be entrained in storm-water
runoff, the pellets are further contaminated by compounds in the storm water
(SPI, 1991).
- Install connecting hoses equipped with valves that will close
automatically when the connection is broken. Hoses of this type are
commonly available.
- Direct the cleaning water flow from rail hopper cars and bulk trucks
through a screen to capture the pellets directly rather than allowing the
pellets to spill onto the ground. This simple control measure would
immediately capture the pellets at the release point, rather than relying on
elaborate passive control systems to recapture the pellets downstream.
- Seal expansion joints in concrete floors with a flexible material to
eliminate the pellet-collecting contour. Pellets that accumulate in
these joints are difficult to recover by broom sweeping, and may have to be
recovered either manually or by vacuuming. Sealing the joints would
facilitate cleaning and would not interfere with the expansion and
contraction of the concrete.
- Install alarms in the pellet conveying system that will alert operators
to a breach of the system. Increase the capacity of air conveying
systems to prevent clogging, and install a bag house or filter bag assembly
in the transfer lines to minimize surges in unloading lines that cause
pellets to be vented into the environment (SPI, 1991).
- Pave all pellet handling areas, including loading docks and rail
sidings. Pellets accumulate between paving stones and gravel making
pellet recovery difficult if not impossible.
- Place screening in storm drains. The mesh of the screening should
be smaller than the smallest pellet handled at the facility. Regularly clean
the storm drain screens to prevent drain clogging and overflow.
- Place control devices, such as bag houses and cyclones, where they can
be serviced without losing pellets. If these devices are placed atop
silos or bins, pellets accumulate on top of the bins or silos and are washed
down by rainfall or blown by wind (SPI, 1991).
- Equip bag-handling stations with vacuum hoses to facilitate spill
cleanup.
- Use tarps or containment devices to collect pellets as they are
spilled. This facilitates cleanup, minimizes contamination of the
pellets (so that they can be recycled), and permits quick pellet recovery by
containing them (SPI, 1991).
- Install grating at doorways for wiping feet. During the site
visits, pellets were observed in areas of the facilities where only foot
traffic could have transported the pellets.
- Modify loading systems so that transfer lines can be completely
emptied, with any residual pellets being contained when loading ceases (SPI,
1991). Use stainless steel elbows on all transfer lines, and cycle the
outlet valves while the air is flowing through the rail hopper car or bulk
truck during pellet unloading.
5.1.4 Routine Operations
Whenever pellets are handled there is the potential for pellet spillage, and
implementing a few simple practices would decrease the potential for spillage
during routine operations. Recommendations for controlling pellet releases to
the aquatic environment by modifying and improving routine operations are
presented below.
- Place portable screens underneath connection points when making and
breaking all connections. The screens should be placed under the valve
before the connection is made, and remain in place during pellet transfer
and valve disconnection. These screens are inexpensive, easily-moved, and
are an effective method for containing pellets at the discharge point. For
example, the screens used by Company B consisted of a frame made of 2- 4-in.
cut lumber that was covered on one side by wire screening (Section 4.3.2).
Additional suggestions include (1) use screens when conducting quality
control (QC) checks, breaking into conveying systems, etc., (2) conduct
sampling only in areas protected by containment procedures (SPI, 1991), and
(3) use wide-mouth containers or polybags for collecting pellet samples.
These containers have wide openings that facilitate filling (SPI, 1991).
- Place permanent screens along the exterior edge of the loading docks.
These screens will capture pellets leaking from punctured containers and
incompletely sealed bag valves, and those pellets tracked onto the loading
dock from other areas of the facility. The screen mesh should be smaller
than the diameter of the smallest pellets handled at the facility.
- Completely empty transport and storage vessels before disconnecting
from the conveying system. This would minimize the possibility of
overfilling a vessel and reduce leakage while making or breaking
connections.
- Supervise longshoremen and other cargo handlers during cargo loading
and unloading to ensure proper pellet containment (49 CFR Part 101).
- Inspect cargo immediately upon receipt, and note the condition of
shipping containers and parcels on the carrier's receipt (49 CFR Part 101).
- Inspect seals on rail hopper cars before unloading. Allow only
authorized persons to remove the shipping seals (49 CFR Part 101). This
ensures that only persons properly trained to prevent or contain pellet
spills will break the seals. Document broken seals and the notify the
shipper of the seal condition.
- Check outlet tubes for pellets before moving railcars or trucks.
Visually inspect the connection ports of both the tube and the
pneumatic-system hose. Purge lines before unhooking them and lift hoses to
assist purging process (SPI, 1991).
- Secure outlet caps and seals before moving full or empty rail hopper
cars and trucks.
- Insist on warehouse and other handling procedures that minimize bag and
box punctures and pellet spillage (SPI, 1991).
- Do not sweep pellets off of loading docks into the water (SPI, 1991).
- Repair punctured bags immediately (SPI, 1991).
5.1.5 Maintenance and Housekeeping
If pellets are not quickly recovered after they are spilled, they will be
dispersed and will likely be released into the environment. Therefore,
improvements to standard maintenance and housekeeping practices are recommended
for controlling pellet releases. These recommendations include the following.
- Improve daily and routine housekeeping and spill response procedures
both inside and outside the facility. Insist on prompt spill cleanup and
make spill cleanup the responsibility of the person(s) causing the spill.
Pellets left for someone else to clean up will quickly disperse and recovery
of all pellets will be difficult if not impossible. Spilled pellets also
poses a safety hazard to the employees.
- Invest more time in routine housekeeping. The more often loose
pellets are collected, the less likely the pellets are to be released into
the environment.
- Initiate vacuuming procedures to collect and contain spilled pellets.
Pellets are lightweight and broom sweeping may disperse some of the pellets
rather than gather them.
- Develop standard operating procedures (SOPs) for containing and
cleaning up spills (SPI, 1991).
- Conduct routine inspections for the presence of loose pellets on the
facility grounds including parking lots, drainage areas, driveways, etc.
Pellets entrained in storm-water runoff from any area will impact compliance
with NPDES permits (see Section
5.2.1).
5.1.6 Packaging
Damaged packaging is a major source of pellet loss to the environment; this fact
was evident throughout the site visits. Therefore, several recommendations can
be made to prevent pellet loss through leaky packaging.
- Design puncture-resistant shipping containers.
- Use reinforced bags, such as woven polypropylene bags, and line larger
containers with puncture-resistant material.
- Minimize the use of valved bags or seal valved bags immediately after
filling.
- Use sea containers instead of break bulk packaging.
Pellets in sea
containers cannot be released during shipment.
- Improve palleting methods. Move and stack bags immediately after
filling to avoid seepage from valves, and stack bags on pallet in tight,
interlocking patters. Shrink- or stretch-wrap pallet to stabilize stacks and
help contain lost pellets. Use corrugated cardboard caps on the top and on
the bottom of pallets to minimize puncturing or tearing bags and to contain
loose pellets. Finally, block and brace outbound loads to avoid broken bags
in transit (SPI, 1991).
- Tape leaks or replace leaking bags immediately (SPI, 1991).
- Inspect pellet packaging, particularly pellets bagged in unreinforced
paper or cardboard packages/gaylords, before offloading.
This will
prevent pellet release through the gap between the vehicle and the loading
dock.
5.1.7 Shipping Vehicles
Changes to current shipping practices and vehicles can decrease the likelihood
of pellet releases to the aquatic environment. Therefore, several
recommendations can be made to the shipping industry and users of the shipping
industry.
- Use containers for cargo shipping rather than individual pallets.
The shipping containers will contain spilled pellets and will prevent them
from dispersing among other cargo, onto the docks, on the deck of vessels,
etc.
- Identify the person responsible for sealing the ports on rail hopper
cars and bulk trucks and have the person document the completion of the seal
(49 CFR Part 101). This will establish the responsibility for correctly
sealing the car and a method for tracking the point at which a seal is
broken and pellets are released.
- Close and secure the rail hopper car valve with strong wire or aircraft
cable in addition to the normal sealing mechanism. This redundancy
increases the time and effort that a vandal must expend to break the seal
and release the pellets. Close hatches and reapply cable seals after
inspecting or sampling the pellets. Insist on strict procedures that require
outlet caps to be properly closed before rail hopper cars are moved, and
request customers to do the same when returning empty cars (SPI, 1991).
- Document the condition of bags and cargo containers and rail hopper car
seals, and promptly notify the manufacturer of problems (e.g., damaged
packages, broken valve seals) (49 CFR Part 101).
- Visually confirm that each compartment and tube of shipping vehicles is
empty (SPI, 1991). In addition, sweep, blow, vacuum, or rinse the
exterior surfaces of loaded rail hopper cars to remove loose pellets before
cars leave the containment area. Direct pellet flow into a screened bin or
into the containment system. Also, air lance into containers to remove
residual pellets in rail hopper cars and trucks (SPI, 1991).
- Inspect interiors of trailers and sea containers for damaged walls,
defective floors, or other defects that may puncture pellet packaging.
Cover defects with corrugated cardboard or, if necessary, insist on a
replacement vehicle, sweep or vacuum any loose pellets in trucks or sea
containers, and contain and dispose of any pellets from previous shipments
properly when cleaning ship holds or sea containers after break-bulk
shipments (SPI, 1991).
- Consider vandalism exposure when selecting leased track sites.
Establish security procedures as needed (SPI, 1991). Advise companies to
report problems to the delivering railroad as well as to the shipper, and
utilize security personnel.
- Avoid on-deck pellet stowage (SPI, 1991). Stow other products on
top and place resin containers in ship wells.
- Do not jettison pellets or containers of pellets.
- Seal empty rail hopper cars and bulk trucks before returning to the
shipper. This will prevent loss of residual pellets.
5.1.8 Recycling and Waste Disposal
Many companies either do not recycle waste pellets, or recycle the pellets only
sporadically. Minimizing the loss of recyclable pellets into the municipal waste
streams could decrease the likelihood of their eventual release into the aquatic
environment. Therefore, several recommendations can be made in regard to pellet
recycling and the disposal of waste pellets.
- Store waste pellets in properly labeled containers. Do not permit
loose pellets to accumulate on the ground or on floors (SPI, 1991). Install
a minimum of one pellet-specific waste container in each pellet-handling
area; separate containers should be used for recyclable and nonrecyclable
pellets.
- Inspect and confirm proper handling and storage procedures if an
outside vendor is used for waste removal. Insist on
no-loss-to-the-environment procedures (SPI, 1991).
- Recycle or resell waste pellets. Use incineration and controlled
landfilling only when recycling or resale are inappropriate. Consider using
waste pellets in a fuel blending program (SPI, 1991). Properly handle
"heels," and ensure that they are collected and recycled, resold,
or disposed of properly. The preferred pellet disposal method is by
recycling, followed by reuse, incineration by approved methods, or deposit
in a controlled landfill (SPI, 1991).
- Check broken and discarded packaging for residual pellets.
5.2 Existing Control Measures
Several measures exist for preventing and controlling the release of pellets to
the aquatic environment. An extensive regulatory framework is available that
consists of international treaties and Federal legislation; several Federal
agencies have developed policies and programs in response to plastic
debris-related regulations. Industry has also adopted policies and implemented
programs geared toward controlling the release of plastics and, consequently,
pellets into the environment. Descriptions of these regulations, programs, and
policies are presented below.
5.2.1 Legal Framework
Several legal authorities, such as international conventions and Federal
regulations, have been developed for controlling the release of plastic
materials into the aquatic environment. This reviews some of the legal
authorities for controlling the disposal of plastic wastes from vessels into
navigable waters (water-based sources) and the disposal of plastic debris from
land-based sources, such as industry and sanitary and storm-sewer systems.
Water-Based Sources
The United States is a signatory to Annex V of the Protocol of 1978
Relating to the International Convention for the Prevention of Pollution from
Ships (MARPOL Protocol of 1973/78) (hereafter referred to as MARPOL
Annex V). Under the terms of the Convention, MARPOL Annex V became effective on
December 31, 1988. The treaty prohibits the at-sea disposal of all plastic
wastes generated during normal shipboard operations.
MARPOL Annex V cannot be used as a mechanism for controlling land-based
releases of pellets into the environment because the treaty applies only to
releases at sea and is not applicable to land-based sources. In addition, MARPOL
Annex V applies only to vessels of signatory nations; vessels from nonsignatory
nations are not bound by the treaty's restrictions, but signatory nations are
obligated to provide facilities for the reception of plastic wastes at ports
(Anon., 1988b).
The Marine Plastic Pollution Research and Control Act, Public Law
100-220 (MPPRCA) implements the provisions of MARPOL Annex V by
amending the Act to Prevent Pollution From Ships as amended in 1901 (ITF, 1988).
MPPRCA also implements several other pieces of legislation introduced in the
Congress in 1986 and 1987 (CMC, 1988).0
The MPPRCA specifically prohibits the disposal of plastics at-sea by
U.S.-registered vessels in any waters, and foreign-registered vessels in
navigable waters (i.e., bays, sounds, other inland waterways, and coastal
waters) and the exclusive economic zone (waters to 200 miles offshore) of the
United States (ITF, 1988; CMC, 1988). The law assigns the responsibility of
developing regulations for implementing the MPPRCA, implementing and enforcing
the regulations, and establishing civil penalties for violations to the United
States Coast Guard (USCG).
Several requirements of the MPPRCA that are applicable to pellet releases
include
- Public Outreach - The National Oceanographic and Atmospheric
Administration (NOAA) and EPA are required to develop and conduct public
outreach programs for educating the public about the problems associated
with the disposal of plastic and other debris into the aquatic environment.
- Waste-Reception Facilities - All ports and terminals that receive
oceangoing vessels of ò400 gross tons or >500,000 lb of commercial
fishing products in a calendar year must have adequate waste-handling and
waste-reception facilities for collecting shipboard wastes. Pellets spilled
on loading docks, ships' decks, and in cargo holds may be considered
shipboard wastes (A.T. Kearney, 1991).
- Waste Management Plan - All U.S. vessels must develop and implement
shipboard waste management plans that address the provisions of MARPOL Annex
V. The USCG is authorized to prosecute any vessel, foreign or domestic, that
disposes of plastics within 200 miles of the U.S. coast (CMC, 1988).
Another Federal law that may apply to water-based releases of pellets into
the environment is the Marine Protection, Research, and Sanctuaries Act
of 1972 (MPRSA), which is commonly referred to as the Ocean Dumping
Act. Under the MPRSA, no U.S. vessel may transport any material, including
plastic, for the purpose of dumping the material into the ocean unless the
vessel has a permit to dump from EPA; EPA does not grant permits for the dumping
of plastics into the ocean and regulations implementing the MPRSA also prohibit
such dumping.
In addition to Federal laws and international treaties to which the United
States is a signatory, states and local governments may regulate the disposal of
wastes from vessels in waters under their jurisdiction. Bean (1987) suggested
that state and local strategies should focus on shore-based or dockside
controls, including at-sea waste-storage requirements and provisions for
adequate waste-disposal facilities at ports.
Land-Based Sources
The discharge of pellets from outfalls or other land-based point sources into
coastal or inland waters is subject to regulation under Section 402 of the Clean
Water Act (Bean, 1987). Prior to November 16, 1990,
permit guidelines for the plastics industries controlled only the pH of the
effluent and did not limit the discharge of solid or suspended particles (Bean,
1987). On November 16, 1990, EPA published the final revisions to the NPDES
regulations for storm-water discharges. Section 122 of Title 40 [40 CFR
122.26(b)(12)] defines materials considered to be significant in storm-water
discharges and plastic pellets are specifically named as significant materials.
Therefore, pellets can be subject to regulation under the NPDES permit
guidelines.
The new storm-water discharge regulations require selected industries to
obtain NPDES permits for all storm sewers that carry storm water from industrial
sites into public waterways (Bain and Mummert, 1991). Applicable industrial
discharges include storm-water runoff from industrial plant yards, immediate
access roads and railroad sidings, drainage ponds, material handling sites,
refuse sites, wastewater sites, equipment handling/main-tenance areas, residual
treatment areas, and loading/unloading areas (40 CFR 122.26) (Bain and Mummert,
1991). Areas excluded from NPDES permitting include lands separate from those
above mentioned areas, such as employee parking lots where runoff from the lots
does not mix with runoff from areas of industrial activity (Bain and Mummert,
1991).
Other Federal laws that may apply to land-based releases of pellets into the
environment include
- Rivers and Harbors Act of 1899 (Refuse Act) - Although the Refuse
Act of 1899 has been superseded by the NPDES permit program of the Clean
Water Act, it does contain a prohibition against the unpermitted deposit of
"material of any kind" that is likely to be transported into
navigable waters, other than what would be carried by sewers (CMC, 1988).
According to CMC (1988), it is possible that the Refuse Act of 1899
"could be used to prosecute against, for example, an industrial source
of large quantities of plastic pellets or a landfill operated in such a way
that refuse could be washed into rivers."
- Toxic Substances Control Act (TSCA) of 1976 - Under TSCA, EPA has
the authority to require the testing of new and existing chemical substances
entering the environment, and, subsequently, the authority to regulate these
substances (EPA, 1990a). EPA (1990a) stated that a serious impact of
plastics disposal in water bodies is the injury to and death of marine
animals that mistake plastics for food. However, EPA has historically
applied its authority to substances more acutely toxic than plastic
materials, and the focus is on the toxicity of the chemicals and not on the
effects of the products in which the chemicals are used (EPA, 1990a).
- Resource Conservation and Recovery Act of 1976 (RCRA) - RCRA
defines hazardous waste as "a solid waste . . . which because of its .
. . physical [or] chemical . . . characteristics may . . . pose a
substantial present or potential hazard to . . . the environment when
improperly treated, stored, transported, or disposed of." Based on this
definition, Bean (1987) considers plastic trash (e.g., pellets in the solid
waste stream) to be hazardous waste. Because the focus of the EPA's RCRA
program focuses on chemical toxicity and generators that produce this type
of waste in the course of manufacturing other products, EPA does not
regulate pollution by plastic trash under the authority of the RCRA (Bean,
1987).
Additional strategies to reduce plastic marine pollution from land-based
sources should be aimed at state and local governments (Bean, 1987). To date, no
states have enacted laws restricting pellet releases, although several states
have enacted laws limiting the use of plastic products such as beverage yokes
(Bean, 1987) or requiring the use of degradable material in lobster/crab traps
and pots (ITF, 1988). Bean (1990) encouraged the development of recyclable or
degradable plastics as the solution to plastics pollution (and the growing
contribution of plastic to the solid-waste stream), and recommended solid-waste
disposal laws of general applicability in lieu of a major shift to degradable or
recyclable plastics or nonplastic alternatives.
5.2.2 Government Programs and Policy
The MPPRCA (described in detail in Section 5.2.1) requires that EPA, NOAA, and
the Secretary of Transportation jointly develop marine debris public education
programs. To date, in addition to the present study, EPA has sponsored several
activities that directly address the issue of pellets in the environment
(Redford, 1990), including
- Preparing the 1990 Report to the Congress, Methods to Manage and
Control Plastic Wastes (EPA, 1990a)
- Revising NPDES permit requirements for storm-water discharges (40 CFR 122)
- Developing a strategy for enforcing provisions of the Clean Water Act in
regard to combined sewer overflow (CSO) discharges
- Initiating studies of CSOs as sources of aquatic debris, including pellets
(EPA, 1992b)
- Initiating field investigations of floating debris in harbors of the
United States (EPA, 1990b, 1992a; Trulli et al., 1990; Redford et
al., 1992)
- Initiating a pilot program for monitoring the presence of pellets on U.S.
beaches. This program is being conducted in conjunction with the National
Park Service.
The National Ocean Pollution Planning Act of 1978 required
that NOAA prepare 5-year plans for researching and monitoring ocean pollution,
including the problems of entanglement and ingestion of debris by marine
organisms. In 1987, NOAA convened a workshop to establish the National marine
pollution research priorities. Marine debris was among the top five research
priorities and the identification of the pellet sources and effects on the
environment were specifically named. The proceedings of the workshop were used
to develop the Federal Plan for Ocean Pollution Research, Development, and
Monitoring for Fiscal Years 1988-1992.
Under the sponsorship of NOAA and the National Marine Fisheries Service
(NMFS), the Shipping Industry Marine Debris Education Plan was developed to
educate all commercial vessel operators and crew of the MARPOL Annex V
provisions and to encourage voluntary compliance with those provisions (Wallace,
1990). Components of the plan that directly involve pellet releases include
- Case studies of current levels of awareness of MARPOL Annex V provisions;
the emphasis is on positive-action cases (i.e., those companies that have
changed their plastics handling and disposal practices). Model
waste-minimization plans are also outlined.
- MARPOL Annex V Education Kit containing legal and environmental issues
pertaining to the disposal of debris from ships
- Liaison with international shipping trade associations as vehicles for
disseminating debris-related information (as opposed to contacting each
individual shipping company) and placing public service announcements in
trade publications to reach all plastics industries.
The Department of Transportation (DOT) does not consider plastic pellets to
be acutely hazardous (acutely hazardous substances include explosives, toxic
chemicals, etc.) and, therefore, have not developed regulations for transporting
pellets or remediating pellet spills from rail hopper cars (Mr. Fred Pritchard,
DOT, personal communication, November 1991, Washington, DC). However, DOT has
developed Cargo Security Advisory Standards (49 CFR Part 101) for securing cargo
transport. These standards were developed based on concerns over the security
(prevention of vandalism and theft) of expensive or controlled products (e.g.,
appliances, alcohol, firearms); engineering/performance resins may be considered
in this cargo classification (F. Pritchard, ibid.). Although the Cargo Security
Advisory Standards carry no enforcement powers and are intended only to be
recommendations, they provide several good suggestions for controlling pellet
releases from rail hopper cars in railroad yards and along the railroad
right-of-way. Applicable recommendations have been incorporated into Section
5.1.
5.2.3 Industry Programs and Initiatives
In response to the implementation of MARPOL Annex V regulations and increasing
evidence of the harmful effects of plastics in the aquatic environment, the
plastics industry and merchant shipping industry have initiated programs and
developed policies aimed at controlling the release of plastics, including
pellets, into the oceans and waterways.
Plastics Industry Programs
In addition to the voluntary cooperation of SPI and the seven companies visited
in the present study (Section 4.0), SPI has initiated other activities designed
to inform and educate the plastics industries in regard to the effects of
released pellets on the environment.
To alert pellet producers of the hazards of pellet releases into the
environment, SPI hosted a briefing for pellet producers in September, 1986.
Discussions prompted by a Center for Marine Conservation (CMC) presentation on
marine debris, as well as presentations of industry pellet reclamation
activities, eventually led to a public service campaign (discussed below). In
September 1987, the SPI Board of Directors issued an official policy statement
in regard to marine debris and the plastics industry's pledge to solve the
problem. In regard to pellets specifically, the statement clearly stated that
SPI was dedicated to eliminating conditions under which pellets are released by
manufacturers and transporters (Bruner, 1990).
In 1987, SPI, NOAA, and CMC jointly initiated a campaign to educate the
industry about the hazards of plastics to wildlife. The campaign focused on all
types of plastic debris and their respective target audiences. Pellets, whose
target audience was the major pellet producers and processors, was one of five
target points of the campaign (SPI, 1990). SPI prepared a Marine Debris Briefing
and Education Kit for the campaign, which included posters, stickers, brochures,
written information, and pellet-related materials carrying the caption Please
Don't Feed the Birds including a photograph of a single pellet (see Figure
31 below). The kit was designed so that individual companies could initiate
internal information campaigns and educate employees about the environmental
hazards posed by pellets. Several recommendations were discussed for controlling
pellet releases during manufacture, shipping, and handling. SPI distributed
these kits to 1500 SPI-member companies and frequently published portions of the
kits in trade magazines. In 1988, the kit was also presented to the
international community; SPI President Larry Thomas distributed copies to the
International Association of Plastics Directors. By the end of 1989, more than
1000 column-inches of advertisement space (25 appearances in 10 publications) or
news coverage had been devoted to the entire campaign (Bruner, 1990; SPI, 1990).
These kits continue to be distributed upon request, and the pellet photograph
appeared in trade magazines through 1990.
[ Fig. 31 not available at time of
access ]
EPA studies between 1988 and 1992 (EPA, 1990b, 1992a,b,c) found that pellet
releases continue to be an environmental problem. In response to these findings
SPI founded a Resin Pellet Task Force to investigate the problem. In November
1990, following the findings of the Resin Pellet Task Force, SPI initiated a
second campaign entitled Operation Clean Sweep, targeted at the
plastics industry and its customers (see Figure 32 below). The 1991 Pellet
Retention Environmental Code (see Figure 33 below) and the 1992 Processor's
Pledge (see Figure 34 below) are an integral part of this campaign. SPI
hasasked its member resin-producing companies to sign the Pellet Retention
Environmental Code and, thereby, commit to "the total containment of
plastic pellets throughout their lifespan and to [operate] in full compliance
with environmental laws and regulations impacting on pellet containment"
(SPI, 1991). By the end of August 1991, nearly two-thirds of the companies had
signed and agreed to the code, and the remaining companies were considering the
matter (Mr. Ronald Bruner, SPI, personal communication, August 28, 1991,
Washington, DC.). The Processor's Pledge was developed and introduced
to SPI's processor members in the summer of 1992 in an effort to make that
segment of the industry more aware of the importance of preventing pellet loss. Operation
Clean Sweep was introduced to the plastics industry at the National
Plastics Trade Show in July 1991, in Chicago, Illinois. The campaign was also
discussed with representatives of plastics industries from over 25 countries at
the International Association of Plastics Directors in June 1991. SPI is
considering development of multilingual copies of the campaign materials for
distribution.
[Fig 32 not available when accessed]
[Fig 33 not available when accessed]
[Fig 34 not available when accessed]
Initiatives by Individual Companies
Several companies have initiated programs to control the release of plastic
pellets into the environment. Good examples of effective control measures were
observed at pellet producer Companies F and G (Section 4.2.2) and contract
packager Company B (Section 4.3.2).
Merchant Shipping Initiatives
CMC (1988) reported that the American Institute of Merchant Shipping (AIMS), a
national trade association for many U.S.-flagged merchant vessels, has given
testimony to the Congress in support of the provisions of MARPOL Annex V. AIMS
supports mandatory training of merchant seamen regarding plastic pollution
prevention and achievement of compliance with MARPOL Annex V standards.
5.3 Recommendations to Regulators
A logical resource for identifying problem areas within a facility are the
Federal, state, and local inspectors that routinely visit the three sectors.
This does not mean that these inspectors should be empowered to fine or
otherwise penalize the facility operators. Instead, the inspectors could take
the opportunity to point out pellet containment and release problems during
their routine inspections.
Therefore, the following recommendations have been developed for regulators.
- Educate local, state, and Federal inspectors. These inspectors
generally have greater access to the facilities than do any other regulatory
official. Although the inspectors have no regulatory authority over pellet
containment, the fact that a regulatory official identifies a potential
problem may encourage better containment practices.
- Establish guidelines for sealing the ports on rail hopper cars, bulk
trucks, and other shipping vehicles. The DOT Cargo Security Advisory
Guidelines, published in 49 CFR Part 101, include several recommendations
that have been incorporated into this report.
- Encourage shipping companies to notify the shipper and receiver when
broken or damaged seals are observed. Although pellets are not
considered by DOT to be hazardous materials, spillage by vandalism should be
reported to the shipper, particularly if no preventive measures have been
taken (e.g., rail hopper car valve not sealed or inadequately sealed).
5.4 Summary of Recommendations
Existing Federal regulations, such as the MPPRCA, provide a basis for requiring
controls over the release of all plastic materials, including pellets, into the
aquatic environment. Provisions of the recently finalized storm- water discharge
rules specifically target pellets in storm-water discharge. All facilities are
advised that they need to be mindful of pellet contamination of storm water and
the need to comply with any applicable terms of their permit regarding pellets.
However, penalties alone cannot control the release of pellets; the penalties
can only encourage companies to implement control measures. Ultimately,
controlling pellet releases into the environment is the responsibility of the
plastics industry, and effective controls should be continued and enhanced
through voluntary industry programs.
Controlling pellet releases can begin with proper training and education of
plastics industry managers and employees and by increasing awareness of the
hazards posed by pellets and of the economic incentives for controlling
releases. Capital investments in containment systems may be necessary to control
releases at facilities that handle large volumes of pellets, but inexpensive
control measures, such as portable screens or tarps, may be adequate for
controlling releases at small-volume companies. All facilities could improve
routine housekeeping measures by increasing the frequency of sweeping and
including the use of vacuums to recover spilled pellets.
In conclusion, several mechanisms for controlling pellet releases are
currently available, and most of the mechanisms, such as education, portable
screens, and improved housekeeping, would be inexpensive to implement. Facility-wide
containment systems have been shown to be effective pellet control mechanisms,
but these systems may not be necessary at smaller facilities or at facilities
that effectively control pellet spills where they occur.
source: http://www.epa.gov/owowwtr1/OCPD/PLASTIC/sect5-.html
14apr03
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