In The

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This study was conducted by the EPA Oceans and Coastal Protection Division. The Project Manager was
Mr.  David Redford, Chief of the Ocean Dumping and  Marine Debris Section (Washington, DC).
Technical support was provided by Battelle Ocean Sciences under Contract No. 68-C8-0105. The Society
of the Plastics Industry, Inc. graciously provided time for Ms. Maureen Healey, Assistant Director for
Federal  Affairs, to arrange site visits and industry reviews of this report.

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 List of Tables	 iii

 List of Figures	•	 iv

 List of Abbreviations	 vi

 EXECUTIVE SUMMARY		  1

 1.0  STUDY BACKGROUND AND OBJECTIVES	  7
     1.1  Study Objectives	  8
     1.2  Acknowledgment	  9

 2.0  PELLET CHARACTERIZATION	11
     2.1  Pellet Additives	..,,,.,	 13
     2.2  Pellet Behavior in the Aquatic Environment	17

 3.0  THE PELLET PROBLEM	.'	19
     3.1  Geographical Distribution	 . 19
     3.2  Sources Identified in the Literature	28
          3.2.1   EPA's Harbor Studies Program	28
          3,2.2   EPA's CSO        Program	 29
     3.3  Fate and Impacts	 30
          3,3.1   Birds	30
          3.3.2   Turtles	36
          3,3,3   Other	36
          3.3.4   Esthetic and Economic	 37

 4.0  PELLET          TO THE ENVIRONMENT	39
     4.1  Organization of the Plastics Industry	39
     4.2  Pellet Producers   	42
          4.2.1   Producer Equipment and Operations  	42
          4.2.2   Site Visit Observations	45
          4.2.3   Sources of Pellet Releases from Producers	52
     4,3  Pellet  Transporters and Packagers	53
          4.3.1   Equipment and Operations	,	53
          4.3.2   Site Visit Observations	57
         4.3.3   Sources of Pellet Releases from Transporters/Packagers	..'.... 66
     4.4 Pellet Processors		i	.67
         4.4.1   Equipment and Operations	 ;	67
         4,4.2   Site Visit Observations	69
         4.4.3   Sources of Pellet Releases from Processors	75
     4.5 Summary  of Identified Sources	.76
Plastic Pellets in the Aquatic Environment: Sources and Recommendations

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                                CONTENTS (continued)

5.0  CONTROLLING PELLET RELEASES . . ;	79
     5.1  Recommendations to the Plastics Industry	..'.,...	, .,	 79
         5.1.1  Industry Management	 79
         5.1.2  Education and Training	83
         5.1.3  'Equipment and Facilities	84
         5.1.4  Routine Operations	85
         5.1.5  Maintenance and Housekeeping	•	86
         5.1.6	87
         5.1.7	; 87
         5.1.8  Recycling and Waste Disposal   	-.	88
     5.2  Existing Control Measures	89
         5.2.1  Legal Framework	89
         5.2.2  Government Programs and Policy	91
         5.2.3  Industry Programs and .Initiatives	 , . . 93
     5.3  Recommendations to Regulators	96
     5.4  Summary of Recommendations	97

6.0  GLOSSARY	'	  101
7.0  REFERENCES	  103

Appendix:  SPI Checklists for Identifying Pellet Release Points and Containment Measures ....  A-l
                                 Plastic Pellets In the Aquatic Environment: Sources and Recommendations

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                                      LIST OF TABLES




 1.   Annual U.S. Resin Sales	12



 2.   Characteristics^nd Uses of Plastics Additives	14




 3.   Polymer Densities	16




 4.   Effects of Two Additives to the Densities of Selected Commodity Resins	17




 5.   Pellet Observations and Suspected Pellet Sources	20




 6.   Pellets Found During EPA Aquatic Debris Programs	24



 7.   Pellets Collected Daily at Sewage Treatment Facilities in Philadelphia and Boston	29




 8.   Pellet Ingestions and Potential Effects	32



 9.   Comparisons of Most Commonly Used Pellet Bags	 55



 10.  Summary of Recommendations to the Plastics Industry According to Industry Sector	80
Plastic Pellets in the Aquatic Environment: Sources and Recommendations                                   ill

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                                         OF FIGURES

 1.     Examples of Different Pellet Sizes, Shapes, and Colors	,	.11

 2.     Pellets Found during an EPA Harbor Studies Program Survey in Houston, Texas  	23

 3.     Plastic Powder Found during an EPA Harbor Studies Program Survey in Houston, Texas  , 26

 4.     Flattened Polyethylene Pellet and a Virgin Polyethylene Pellet	  27

 5.     Pellets Ingested by a Seablrd	.•. 30

 6.     Pellet Flow through Plastics Industry Sectors	 . 40
       (a)    Pellet Producers/Extruders	^.	"... 40
       (b)    Pellet Transporters/Packagers	41,54
       (c)    Pellet Processors	41,67

 7.     Example of a Pneumatic Conveying System in a Pellet Blending Operation	..44

 8.     Basic Design of the Company F Pellet Containment System	46

 9.     Facility Drainage System Outfall into the Company F Containment System  	47

 10.    Upstream View of the First Fixed Skimmer in the Company F Containment System  ..... 48

 11.    Pellets in the First Fixed Skimmer Containment Area at Company F	48

 12.    Portable Boom and Manual Pellet Recovery from the Company F Containment System ... 50

 13.    Pellet Spill Caused by Vandalism to Rail Hopper Car Valves	56

 14.    Company B Environmental Inspection Checklist	60

 15.    Storm-Water Drain in Railroad Siding at Company C	61

 16.    Loose Pellets beneath a Bagging Machine at Company C	62

 17.    Pellets Spilled at a Company C Loading Dock		62

 18.    Pellete in Storm Water outside a Company C Loading Dock	63

 19.    Storm-Water Interceptor near Company C	64

20.    Pellet Accumulation .(and Other Aquatic Debris) in
       Storm-Water Interceptor near Company C	64
IV                                   Plastic Pellets in the Aquatic Environment: Sources and Recommendations

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                                LISt OF FIGURES (continued)

 21.    Pellet Accumulation in Storm-Water Interceptor near Company C  	65

 22.    Pellets along High-Water Line in Storm-Water Interceptor near Company C	65

 23.    Primary Bulk-Storage Hoppers (Silos) at Company A	6S

 24.    A Pneumatic Transfer Tube Used to Transfer Plastic Pellets from Bulk Trucks to Bulk
        Storage Hoppers at Company A  	69

 25.    Pellets on the Ground in the Area of the Bulk-Storage Hoppers at Company A	70

 26.    Pellets Caught in Fence Guard and on the Floor
        Beneath the Internal Storage Hoppers at Company A 	71

 27.    Plastic Pellets and Scrap on Top of an Injection Molding Machine at Company A  	71

 28.    Pellets Accumulated in an Expansion Joint in the Company A Printing Shop	72

 29.    Pellets Accumulated in the Catchment Basin under the Overhead Doors at Company A  ... 72

 30.    Company A Driveway Where All Storm Water is Transported to the City Street	73

 31.    A Poster Distributed during the 1987 SPI Marine Debris Campaign	94

 32.    Advertisement for the 1991 SPI Operation Clean Sweep Campaign  	95

 33.    1991 SPI Pellet Retention Environmental Code   .	,	98

 34.     1992 SPI Processor's Pledge	99
Plastic Pellets in the Aquatic Environment: Sources and Recommendations

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                                 LIST OF'ABBREVIATIONS
 ABS       acrylonitrile/butadiene/styrene
 AIMS      American Institute of Merchant Shipping
 CMC   ,   Center for Marine Conservation
 CSO      . combined sewer overflow
 DOT      Department of Transportation
 EPA       Environmental Protection Agency
 FDA       Food and Drug Administration
 HDPE    . high-density polyethylene
 ITF        Interagency Task Force on Persistant Marine Debris
 LDPE      low-density polyethylene
 MARPOL  International Convention for the Prevention of Pollution by Ships
 MPPRCA   Marine Plastic Pollution Research and Control Act of 1987
 MPRSA    Marine Protection, Research, and Sanctuaries Act of 1972
 NPDES    National Pollutant Discharge Elimination System
 NOAA     National Oeeanographie and Atmospheric Administration
 OCPD     EPA Oceans and Coastal Protection Division
 OWOW   EPA Office of Wetlands, Oceans, and Watersheds
 PBT       polybutylene terephthalate
 PCB       polychlorinated biphenyl
 PE        polyethylene
 PET       polyethylene terephthalate
 PP        polypropylene
 PS        polystyrene
 PVC       polyvinyl chloride
 QC        quality control
 RCRA     Resource Conservation and Recovery Act
 SAN       styrene/acrylonitrile
 SB        styrene-butadiene
 SMA      styrene-maleic  anhydride
 SOP       standard operating procedure
 SPI        Society of the Plastics Industry, Inc.  .
 TiO2       titanium dioxide
 TSCA      Toxic Substances Control Act
 TSS        total suspended solids
 UL        Underwriters Laboratory
 USCG      United States Coast  Guard
vt
Plastic Pellets in the Aquatic Environment: Sources and Recommendations

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                                  EXECUTIVE SUMMARY
 The U.S.  Environmental  Protection Agency
 (EPA) is concerned  about  the  amounts and
 types of debris in  our oceans and on our
 beaches.    This debris can  have  economic,
 esthetic,  and  ecological  Impacts and can come
 from both land- and sea-based sdurces.  One
 debris        that  has become  of particular
 concern to EPA Is the plastic pellet,

 EPA's Oceans and Coastal Protection Division
 (OCPD)  of the  Office of Wetlands, Oceans,
 and Watersheds  (OWOW)  Initiated the study
 described In this report to make a comprehen-
 sive assessment  of the sources,  fate, and ef-
 fects of pellets In the aquatic environment, and
 to  determine what  can be done to control and
 prevent their release to the environment.  The
 goals of the study were to

     *   Summarize  what Is  known  about the
        presence  and  Impacts  of pellets In the
        aquatic environment,
     *   Wentify and evaluate how  pellets  es-
        cape into the environment, and
     •   Recommend ways to control or prevent
        future' pellet releases.

 This study promotes EPA's national policy on
 pollution  prevention,   which is  based on the
 Pollution  Prevention Act of  1990 

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 THE ENVIEONMENTAL PROBLEM;
 SOURCES, FATB, AND
 Historically,  several sources of pellets  la the
 aquatic  environment  have  been  suggested,
 including-                     and
 wastewater.         by the         industry,
 spilage       trucks, railears,  and ships, la-
 proper use of pellets,  and       disposal and
 sewer discharges by cities.  The findings of me
 EPA Harbor         Program  and' Combined
 Sewer Overflow (CSO) Studies Program con-
 cluded, that significant land-based pellet sources
 exist,  'and the plastics  industry  is a  likely
 source of-the releases,

               by the plastics industry flow
 into the aquatic environment by  two routes.

    •  CSO  and  storm-water discharges —
       Spilled pellets may be carried by rain-
       water  into storm-water drains,  which
       in  turn transport  the water into the
       municipal  wastewater  treatment sys-
       tems.   The             be       dis-
       charged into the aquatic environment
       through  storm-water             or,
       where the         and  storm,  sewers
       are combined,  through  CSO discharg-
       es.,
    *  Direct spills into the aquatic .environ-
       ment; .— Pellets     be spilled directly
       into waterways,      as during cargo
       handling           at ports or during
       cargo transport at sea.

The presence of pellets in U.S.        waters
was      reported to  the early  1970s,  and
pellets have since been reported in most  of the
World's oceans.  More recently,  EPA studies
of aquatic  debris  (EPA Harbor Studies Pro-
gram)  revealed widespread distribution  of
plastic        to P.S.  harbors         on the
Atlantic,  Pacific, and Gulf coasts, and
             the       common items      to
 most of the harbors.  Pellets were found to 13
 out of 14 harbors sampled.  The greatest num-
 ber of       was found in the Houston
 Channel  at  Houston,  Texas,  where  over
 250,000 pellets were collected to one sample
 alone.  Notably, Houston has one of the great-
 est concentrations of        industry
 to the United States,

 During its  CSO         Program, H»A also
 found         in the  municipal
 treatment systems of Philadelphia  and Boston.
 For example, pellets comprised' over one-half
 of  the manmade debris collected at one Phila-
 delphia, Pennsylvania,  storm-water discharge.
 Pellets  were      found  to         collected
 from four                  plants;       on
 the study  findings, EPA has .estimated
 over 20,000       per day     be       to
 the sewage        by one Philadelphia plant.
 The pellets are removed from the sewage dur-
 ing sewage treatment.  The presence of pellets
 to the plant shows that the pellets  are released
 from land-based sources, and could be released
 to  the  aquatic environment during treatment
 plant shutdowns or through CSOs and storm-
 water          during rainy periods.

 The persistence of a pellet to the aquatic envi-
 ronment may be measured to years, depending
 on  the resto type,  the types  and amounts of
 additives, and  the reactions of the resins and
 additives  to  environmental  processes   (e.g.,
 weathering, sunlight, wave  action).   Once to
 the environment,       may be transported by
 storm-water runoff, rivers, and water
 to      far away from the source.

 There are  several,  documented          de-
 scribing, pellet and other plastic togestion by
 wildlife, most notably  by  seabirds  and sea
 turtles; however, impacts or biological effects
 of the pellets have not been clearly defined or
'demonstrated  conclusively  in  most  wildlife.
                       morS frequently
 any  other  animal,  and  approximately  one-
 guarter of  all          species are known to
                                     Plastic Pellets in the Aquatic Environment: Sources and Recommendations

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                              by         are
           to                     of
 (I.e., the      fed as
 and reduce the feelings of tonga.  Ultimately,
 this             in^a          In        re-
        and the ability to survive         etwi-
           conditions,                    on
 sea turtles,  fish, and other aquatic life
 been less frequently reported and studied.
 Although .pellets      not be  is
            as otiher       of debris,      as
          and medieal-         the
         and                  in Ae environ-
      are        for1 notice.   One  investigator
      so far as to        that, if high
 of                to be           on
                   people may be
 on plastic-sand beaches        of natural-sand
 beaches.
 TOE
   , •  Pellet  producers,  which         the
       polymers,  form  the peleta, and
       the         to                     or
       processors.
    »  Pellet  transporters/contract
       agera,  which  are
       handlers.     Transporters  cany -bulk
                          the
       via alears, bulk trucks, and  freight
      .        .
       bulk                smaller
       (e.g.,         and             boxes),
       which are shipped to processors,
    «  Pellet  processors,  which  mold  Ae
              into user products.

To           how        are          to  the
environment from      of      three
SPI           for       industry       to -be
visited by the               Seven
(two               two
           and       processors) were  visited"
during this, study.
 The  Society  of the Plastics Industries, tec.
 (SPI), worked with EPA  to-develop aa
 standing of -operattefls within Ae         in-
 dustry and identify potential         of pellet
       to  the                SPI is the  major
                         of the        tadus-1
 try.   Its                       of more than
 2,000           that are responsible for ap-
 proximately 75* of the $100 billion
 of         and                 in the
        These           supply raw
 (e.g., pellets)," manufacture         and
products,  and                   and manufecr
                and                  by the
                ,  This
     4be voluntary              ad!
of SPI  and                  in  fee
industry.

For  the           of  the study,,  the
industry     divided into      major

for     of the      industry sectors described
above.  Most  of .the        pathways
common.to  all three  sectors, with only -a few
      unique  to one or two            The
pathways may be           into
                         are t

    *  Poor communication           indus-
       try                         manage-
              and               of
                  (e.g«,  *WppIng Industry).
       Not  all company managers have recog-
             tite               and the
       to         pellet                 spill-
       age                  as the
       of          and' Ae        'of
Plastic Pellets in the Aquatic Environment: Sources tod ReeonsfnendAtkscui

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 rail  hopper  cars,  is
           only occasionally.
 Lade  of employee              and
 Inadequate  training,             ire
 generally unaware of the environmen-
 tal         of         and
              - for
•          to   tiie  environment.    For
 example, one major       pathway  is
                               by im-
 proper            of

 alow pellets to  escape into  the  envi-
 ronment          they  are unaware of
 Ae       of pellets.
                                  and
 apparatuses.   Most            have
 few or no cooling-, waste-, or storm-
                             Including
                  in      for .control-
 ling pellet         to the
        that are        IB
 may   be  discharged   Into  municipal
       and sanitary       or into natu-
 ral
                               When-
 ever  pellets  are handled, there- is the
 potential  for  pellet.spillage.   Manual
               is       likely to
 in                     by
 conveying           (i.e.,
        that  move pellets by  using air
 flowing through sealed pipes).  How-
 ever,  if  pneumatic-         are  not
         maintained;and closed,
 may'      Aroigb "openinp In  the
                may be
 during the          of  damaged,  un-
 repaired
                           practices.
 If        are not Quickly         up
      they, are spiled,  they  may be
          and eventually
 (he              -Pellets may' be
       throughout interior tnd
      of a facility via       and dott-
        ing,  vehicle  tires,  wind,  and storm-
              runoff,
        Easily          or
        Paper  and  cardboard  packaging  is
                        during          and
                     to          be
        to be
        molding            tJaaagBcf or laky
        packaging is a  major source of pellet
        toss to the              valved,
                        not           .close,
        thereby  allowing pellets to
        fte opening.
        Improper iWppIng practices.   Im-
        properly        rail         car valves,
        poorly
        awl                             pnc-
                           large           of
              to the environment
       _ Lack  of  recycling.
        do not       to recycle spilled
        and,                  the
        other facility trash.

                                    a
for           the        of
including plastic pellets,  tote the        envi-
ronment.   The                 National Pol-
       Discharge             System permit
program            [40 CFR
                 and              to
significant  penalties  to a company or sewage
         plant          if        are
in                            to  violation of
their permit.  Although               will not
completely        the        of
can eacour^ge companies to implement control
measures.  Ultimately, controlling         of
              into the                    is
die responsibility of the        Industry.
                               Phstic Peltete in the Aquatic Environment: Sources and Rseomniaidationi

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 In response to the early findings of this pellet
 study and other EPA  studies conducted since
 1988, SPI founded a Resin Pellet Task Force
 to investigate the  pellet  problem.   In  July
 1991, -following the findings  of the task force,
 Sfl initiated Operation dean Sweep, an indus-
 try-wide education -campaign  aimed at commit-
 ting  the plastics industry  to  the total contain-
 ment of pellets.  It is anticipated that SPI and
 the industry will use this  EPA comprehensive
 study along with campaign literature and infor-
 mation to  control pellet releases from industry
 sources to the aquatic environment.

 The  release of pellets from  pellet producers,
 transporters/contract packagers, and processors
 can be controlled through actions identified  in
 this study.   Recommendations to  She plastics
 industry are

    •   Adopt the SPI 1991 Pellet Retention
        Environmental   Code  and the  1992
        Processor's Pledge.   The code is  a
        commitment  to  total  containment  of
        plastic pellets,  and was  developed by
        SPFs  resin-producing  members   in
        response to  findings of this and  other
        EPA studies.   This  code encouaages
        source reduction activities to prevent
        releases,  and suggests ways to recap-
        ture pellets that are spilled,
    *   Educate employees and train them  to
        minimize pellet  spillage and  loss.
        Employees must recognize their role  in
        preventing releases.
    *   Install pallet containment systems or
        me portable containment  apparatus-
      . es.   The use of inexpensive portable
       screens or  similar devices can  effec-
       tively  control   pellets at  the  spill
       source.
    *  Institute  pellet  containment activities
       during routine  plant  operations.  For
       example,  cleaning pneumatic lines into
       a  portable  screen  before  breaking
       connections will minimke pellet loss
     .- through spillage.
    *   Improve the  quality  and  frecpieney
        of pellet  spill  cleanup  procedures.
        Frequent   vacuuming    and  broom-
        sweeping  collect pellets  before  they
        escape into the environment.
    *   Use   puncture-resistant   packaging
        arid minimize the .use  of valved bags,
        The use of reinforced  valveless bags,
        such as polypropylene woven bags that
        are  sews shut, would  minimize pellet
        loss due to damaged  or incompletely
        sealed packaging.
    9   Inspect shipping containers  before
        loading and  after offloading of pel-
        Sets.   Containers may  be resealed or
        repaired before  additional pellets are
        lost,  and  pellets  May  be  recovered
        instead of being released  into the envi-
        ronment,
    •   Inspect shipping vehicles (e.g., rail
        hopper  cars,  bulk trucks,  freight
        trucks) before and after loading and
        offloading  of  pellets.  This will pre-'
        vent spillage from leaking railcar and
        truck valves, and securing the valves
        with  tamper-resistant  cable  will  dis-
        courage pellet loss due to  vandalism.
    *   Recycle spilled pellds*  By recycling
        spilled pellets^ the plastics industry can
        recover revenue  that would have been
        lost  by 'disposing them, and  wUS mini-
        mize pellet  releases to the environment
        during trash disposal.

Many of the recommended1 control mechanisms
are currently available and are being voluntari-
ly implemented by  some companies  within the
plastics industry.   Most of the  mechanisms*
such as employee education, portable screens,
and  improved  housekeeping,  control pellet
releases immediately at the source; these mec-
hanisms can be easily and inexpensively imple-
mented.  Systems that direct spilled pellets into
one  containment area  are  effective but  are
more expensive to implement.
Plastic Pellets in the Aquatic Environment:  Sources and Recommendations

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      NEXT
The plastics industry should play a major  role
in protecting the  environment  by voluntarily
'implementing the  recommendations  identified
in this report,  which includes  adopting SPFs
Pellet  Retention  Environmental  Code  and
Processor's Pledge<

EPA wUl continue to work with SPI and the
plastics  industry to implement the recommen-
dations, and  will        industry progress in
eliminating pellet releases.

Using Jhe existing  regulatory framework for
guidarice, EPA will continue to monitor storm-
water effluents for compliance.
                                    Hajtic PeUels in the Aquatic Environment: Sources and ReeonunendftiioM

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                      1.0 STUDY BACKGROUND AND OBJECTIVES
 Over the past few "years, public and scientific
 awareness has  increased  concerning  the  aes-
 thetic, economic, aad biological hazards asso-
        with  persistent manmade debris  in the
 aquatic environment.  In  response to  public
 and  Congressional          about Ae debris,
 the  White  House  Domestic  Policy  Council
 formed an Interagency Task Force on Persis-
 tent  Marine Debris la 1987.  The Interagency
 Task Force  (FTP) was chaired by the  National
 Oceanic   and   Atmospheric   Administration
• (NOAA)  with   partieipatioa by   12  Federal
 agencies, including the Environmental Protec-
 tion  Agency (EPA).  The TTF wai         to
        the problem tad the need for
 Identify  potential   reduction  measures,  and
 consider  alternative actions to  address  the
 problem  of plastic  marine pollution"  (TTF,
 1988),

 As a result of increased reports of resin pellet
 Mgestion by aquatic wildlife and evidence that
 the ingested' pel lets may be harming the wEd-
 life,  the HP            resin  pdJets
 known as plastic        as a debris problem
 that required additional research.  These
 pellets are the raw          from which plas-
 tic products- are manufactured.  When  released
 into the environment, these pellets either
 float on  or  near the water surface, may be-
 come suspended  at  mid-depths, or may sink to
 the bottom of a water body.  Whether a specif-
 ic pellet      or              on the type of
         used to       the pellet, on additives
      to modify toe characteristics of the
 (pellet), and on  the -density of the- receiving
 water.  The pellets most commonly found in
 the environment are composed of polyethylene,
 polystyrene,  and  polypropylene (EPA,  1990a).
 These  compounds  are also         the most
 commonly used       (Prater, 1987),
The IFF '(1988) and others (e.g., Prater, 1987;
Colton £1 al., 1974; Ryan, 1988b)       sever--
al          sources of pellets  in the environ-
      ineludiog:   "(1) pellet manufacturers,  (2)
ships  transporting the pellets, (3) pellet proces-
sors,,  and  (4)       pellet transportation vehi-
cles. . However,  evidence was unavailable to
support or  confirm  the ' importance  of  toe
suspected sources.   Therefore, discussions of
likely sources were limited  to Suspicions or
educated guesses.   As  a result,  one of  me
recommendations  of the Task  Force was  for
Federal          to conduct         to deter-
mine  land-based  and water-based         of
       debris including plastic pellets.

The Task Force did  not  address whether plas-,
tic  pellets  in  the environment and resulting
.environmental  problems  ware associated with
historical releases  or were related to  current
releases.  However, In  the late  1980s,  the
Society of the Plastics Industry, Inc. (SPI), had
reported that plastic        in the environment
     have been the        of historical
and  that the  industry   had_ addressed these
        (SPI,  as   cited  fa. CMC,  1988).   In
contrast, Heneman (1990) reported a 200% to
400% increase in the numbers  of pellets pres-
ent  fa the North Atlantic Ocean between 1972
and 1987.   to addition, recent, results from
EPA studies conducted in several U.S. harboa
(EPA,
distribution of plastic pellets, most  of
were  not            and  were probably  re-
leased recently. The EPA       found that

    «   Plastic pellets' are present in harbor
             that are  inaccessible  to
       ships  and  other  major ship  traffic,
       implying that these-vessels are not the
       only source- of plastic pellets In  the
       environment 
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        Harbors of cities with older combined
               overflow (CSO)         *coa-
        talned significant           of .pellets
        In  the                  (EPA, 1990b,
    «   Harbors near known production,
        port, and                  bad
                      of       (EPA,

    «   Pellets are         la CSO and  storm
               outfall             and
                 In


These-                that the        indus-
try         a  likely        of
     Ae             and         that signifi-
cant                                 exist.

             to  its  1990        to the Con-
               ft>         aaf
         EPA                         as in
item of partienlir         (EPA,, 1990a) due
to  increasing  evidence            ecological.
        from       materials,   EPA      in-
        aa          Item  to             the
         of               to the
and to evaluate
1,1
As     of EPA's          to the
included in the Report to the          (EPA,
1990s), a        was          to
possible  land-based          of  plastic
within the plastics industry, including peito
              (producers),               and
            "Hie  objectives  of this
to (1)         and                        of
pellet         into the             (2) evalu-
ate the significance of      source  as t pellet
       pathway,  and (3)
      for controlling or            the
of pellets.
To obtain the                      10 meet
       objectives,  EPA
               These                  to

    «  Review the literature on plastic pellet
       characteristics.
    *              pellet producing and pro-
                              ia the
       industry,
    «  Determine _  the  procedures        to
                die                the vari-
       ous
    *              the          oa the  envl-
                          of  plastic  pellets
       when         into the
    *  Contort site      to
       in the                 of the
       Industry to         and          ill
       potential release points  to the environ-
            and to         the          for
       controlling pellet
    •  Continue                      in the
       U.S.
    *  Evaluate potential         of
              into
    *            an
       SPI.

This  report          the                and
                           are           of
the following

    *  Chemical  and  physical properties  of
       pellete, including          and
               on  pellet   befaaviof fa  fee
                           2).
    *  Geographical distribution of      and
       the known  and                   of
               in • the
               3).
    9  Generic descriptions of minufictaring
       and                     of     plas-
       tics industry        (pellet producing,
                              and
       operations) (Sectlffo 4).
                                      Plastic Pdkts in the Aqimiic Environment  Sources tad Meeonameadatifioi

-------
         Summaries  of observations made dur-
         ing the  visits to several  facilities  in
         each Industry sector (Section 4).
         Identifications  of likdy pellet release
         points  in eieh  sector of the industry
         (Section 4),'
         Existing   regulatory  framework  and
         other government ,and Industry efforts
         to  address .the pellet  problem (Section
         5).
         Recommendations for controlling  pellet
         releases (Section 5),
 1.1    AQOTOWLHQGMENT
 The study was  completed with tb'fc assistance
 and cooperation of the Society of the Plastics
"Industry, Inc., which  is & major trade organi-
 zation   representing   the  plastics  industry.
 Information was gathered through discussions
 at  SPI meetings- in  Washington, DC,  and
 through site visits to seven different companies
 (two pellet  producers, two transporters/pack-
 agers,  and  three  processors),  which  were
 arranged by SPI- is response  to a -request for
 voluntary   study participants.    Information
 gathered  at  and supplied by  these companies
 was invaluable to this study.
Plastic Pelleto in the Aquatic Environment: Sources and Recommeadatioos

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-------
                           2.0  PELLET CHAKACBEEIZATION
 "The demand for a wide variety of plastic prod-
 ucts  has,  necessarily,  created a demand  for
 many different resins (polymers)  and  resin
 blends.  Resins are synthesized from petroleum
 or natural gas derivatives, iuch as

    *   Acetylene:   Polyvinyl chloride (PVC),
        polyurethane
    •   Ben«ne:   Polystyrene (PS),  polyure-
        fljane,   ,aerylonitrMe/butadiese/styrene
        (ABS)
    *   Butadiene;  Polyurethane, ABS
  •  «   Eihylene;   Polyethylene  [high-density
        (HOPE) and low-density (LDPE)], PS,
        polyethylene  terephthalate   (PET),
        PVC, ABS, polyurethane, polyesters
    •   Methane:  PET, polyurethane
    •  Naphthalene:  Polyuretbane
    *  Propylene;  Polypropylene (PP)» poly-
       urethane, polyester
    *  Toluene:  Polyurethane foams, elasto-
       mers, polyesters; also used to derive
       benzene
    •  Xytenes  PS,  PIT,  ABS,  unsaturated
       polyesters, polyuretbaae

By blending polymers, creating new polymers,
and  Incorporating  additives,  resins may  be
tailored according • to  the desired  application
and end product (EPA, 1990s),

An  estimated 60  billion pounds of resin are
manufactured annually in the United  States,
              Rgure 1.  Examples of Different Pallet Sizes, Shapes, and'colors.
                  Left to Right:  Polystyrene, Titanium Oxide, Polyethylene;
Plastic PdLkte in the Aquatic Environment:  Source* and Reconeunendatioai
                                        II

-------
                                Tabto 1. Annual U.S.
                                             from          (1991)]
Rain
Thermoplastic Beans
Low-density pefyatiyletti CLDPB)
Pol jvlnyldilofide (PVQ
and copoly mers
ffigiHfetisity polyetbytaae (HDPB)
Polypropylene (PP) md copolymers
Polystyrene (PS)
Thermoplastic polyester —
(PET)
ThenDOpIaBlic polyester —
P»BT)
(ABS)
Otter slyreaies
Other vinyls
Polytnuide (nylon)
Acrylic
Thermoplastic
% Aanuaf
19B9

18.5
14.7
14.0
12.5
8.S
3,6"
— ,
2.1
2.0
1.5
1.0
1.3
0.9

1990

19.3'
15.1
13.8
.13.2
8.4
3.1*
—
2,0
1.8
1.5
0.9
1.2
0.9
Resin

Polycarbonate
Wypbeoyiene-bssed alloys
Styread/aayloaitrile (SAN)
Polyscstyl
CelMosica
Thermoset Resins
Pfaeioltcs
Polyttrethane
Una and tnelarmae
Poly«ter» unsatunfed


Ofljers
% Annual
19B9

1.1
0,3
0,2
0.2
0.2

4,5
5.5
2.4
2.3
O.S
0.6
0.5 •

If'fH

1.0
0,3
0.2
0,2
0,1

4,6
5.3
2.3
2,0
0,8
0,5
0.5
HA; Not *vaa»bk>,
       tQtt] aamiai KaJOs of 58,151 sr.ti 6!(48<5 blilioa poundsof regb in (9f$aad S9W, respeeiivsiy.
      for PET, HJT, and otber th*Rnopk«ck poiyaeter wsiat,
       of which is            If     pound of
             HDPE
  22,000        (Mr.                        of
  the                  Inc.,         ^conmuai'-
                 1991, Washington, DC), and
  this           aumber is         to all pellet-
  ized resins, more titan 1 quadrillion (1- x lO1*)
  pellets may be-produced tnnually.  Palletized
  resins,  or, simply, pellets,  are  produced  in
                (e.g.,                   disto,
  and  cylindrical nibs),        and colors,. a few
  of        we shown in Figure L  Resins
      be            In
                             granules, flakes, and

                           *•»

             Two                   are
                            Md                     (EPA,
             1990a). Thermoplastic       can be       or
                         without           or "dungtag Ae
             chemical  or physical  properties  of the poly-
             mer;        ire MgMy  .malleable but become
             rigid        coaled.   Because^ttie
                  be                 the         point of t
                                 afld the              at
             -which the
  12
Plutie Pellrti in the Aquatic Envkoianent: Sources »nd

-------
 resins ire kept  in a liquid (melted)  state for a
 minimum amount of time and are pelletlzed as
 soon as possible (EPA, 1990s),

 Thermoplastic resioi comprised 83% and  84%
 of the annual U.S.  resin sales in J989  and
 1990, respectively (Table 1); U.S.  resin  sales
 increased  5.5% in  1990 after, no increase in
 1.989  (Martino, 1991).  The most  commonly
 used thermoplastic resins include LDPE, PVC,
 HDPE,  and  PP;  these resins  accounted for
 61%  of  the  total resin production in  1990
 (EPA,  1990a).   Common  products made of
 thermoplastic  resins include milk bottles  and
 other food containers.

 In  contrast to thermoplastic" resins, thermoset
 resins are stronger  when  exposed to  high
 temperatures,  tend to  be rigid, infusible,  and
 insoluble,  and  cannot be  remelted and  re-
 formed,  Thermoset resins often are shipped to
 processors is  liquid form, where the resin is
 cured  and molded  (EPA, 1990a),   The most
 commonly used thermoset resins include  pfae-
 nolics and- polyurethane resins,   Thermoset
 resins typically  are used in building materials
 and automotive parts (EPA, 1990a),

 Thermoplastic and thermoset resins are further
 categorized according to the volume produced
 and the  market demand for the  resin.   The
 categories  and the uses of the resifls are listed
 below.

    »  Commodity resins
       These  resins 'are produced  in  large
      . quantities and   are  used  as  the  raw
       materials for many  plastic products.
       These  resins are libeled  as  commodi-
       ties because  they are  commonly used
       and are not refined, or differentiated by
       the resin manufacturers.   Commodity
       resins,  such  m  LDPEt  PVC,   and
       HDPE, are 'the least expensive resins
       to produce (EPA, 1990a).
        Transitional resins
        These resins are produced less  fre-
        quently  than  commodity  resins  but
        more  frequently  than   engineering/-
        perfarmanee resins  (discussed  below).
        Transitional  resins,  such  as PP, ABS»
        and acrylics, are also more expensive
        to  purchase  than   commodity resins
        (EPA, 1990a).
        Engineering/performance rains
        These resins have  narrowly  defined
        applications and are produced  by only
        a few companies.  Engineering/perfor-
        mance resins,  such  as  polycarbonate
        and nylon,  are  the  most  expensive
        resins to produce" (EPA, 1990a).
 2.1'             ADDITIVES
 Some  resins  are  used  in  the pure-polymer
 form, but, more frequently,  me properties of
 the polymer must  be changed  to produce the
• desired end product.  Additives, are used to
 alter the physical  characteristics  of the poly-
 mer, such as aesthetic properties (e.g./color),
 physical  properties (e.g., heat-resistance  and
 hardness),  and the ability to be further pro-
        (e.g., porosity) (EPA, 1990a). Table 2
 shows  additives, additive concentrations,  and
 typical polymers to  which  the additives are
 applied,

 The type of additive determines when and how
 die- additive is  applied  to a polymer.   Two
 methods  _are  used  to  incorporate  additives:
 (1) the additive (solid or liquid) is mked with
 the polymer,  or (2) the additive  is  reacted
 chemically with the polymer (the additive is
 bonded with me polymer),

 Is ecological  discussions, this  distinction is
 very important when considering leaching of
 the additives  into the environment and poten-
 tial  toxicological  effects  of  the   additives.
Plastic Pelkts in the Aquatic Environment Sources and Recommendations
                                          13

-------
                    Table 2.  Characteristics and Uses of Plastics Additives.
                                  [Adapted from EPA, 1
Examples of Types . Additive Coat*
aw
Antimicrobials — Increase resistance to microorgajaisms
OxybispbencHUuvne; isotiaiazalone Low (<1)
Antkuddants — Prevent ddterioraiios duriaf processing
and loog-terta use
Pbeoolics; amines; phosphates; tfaioesters Low (< 1}
Antistatic agmts — Control static buildup during
processing ami in final product
Amlne sails; phosphoric acid esters; palyediers , Low (< 1)
Stowing — Add porosity to produce foamed plastics
Azoysfonnanride; dUorofluoroe&rboaa; peatana Moderate (1-5)
^ Catalysts anil curii^ agents — Facilitate polymerization
and curing of resins
Nuaertjus Low(
-------
             Table 2.  Characteristics and Uses of Plastics Additives, (continued!
                                   [Adapted from EPA,  1990aJ
Examples or Types Addiiwe Cone,*
-:- Ob)
R-ee-radleaS iniiiaiore — Assist in polymerization
and curiag processes
Peroxides; azo compounds Low (<1)
Heat stabilizers — Improve beat resistance or prevent
degradation by heat
OrgaBoiin mercaptides;, lead compounds; barium, Moderate (!-5)
cadmium, and zinc soaps
Impact modifiers — Improve strength and kopaet resistance
Metfascrylate bwtediepe styreoe; chlorinated PE; High (10-20)
acrylic polymers; elhylene vinyl acetate
Lubricants and mold release agents — Improve viscosity,
reduce Jraetioo between resin and sunouading surfaces
Fatty acids; alcohols and amides; esters; metallic Low (
-------
the repellent requires the intentional dispersion.
of pellets in a. given area.  Thus, this and
applications for pellets may involve inten-
tional,  as opposed  to accidental, introduction
of pellets into the environment
                                    Table 3.  Polymer Densities.
                        [Adapted from EPA (1990a) and Anon, (1988a)l
Resits
Thermoplastic Reins
PaSyrtyieae (PS)
Other styietues f&-g.» styienfr-
hutadime and s£yrene-bsaed latexes,
stywie-aaleie anhydride (SMA),
styreofr-batadieoe (SB) polymers]
Low-density polyethylene (LDPE)
TfaenaoptoMie polyester —
polyethylene tertpfatWate (PET)
PolyviayJcMoride and copolymers
(PVQ
Polyxmide (nylon)
AcrylonitFUe/butadieae/gytraae (ABS)
Polypropylene asd copolymcra (PP)
ThermopiastiC elaaiciuers
Acrylic
Polycarbomate
Ctellulosics
Polyacetal
Other vinyls (e.g., poiyvinly acetate,
polyviayl butyrol* polyvinylidme
chloride)
Iteisity
Cg/mL)

1,04-1.08 '
1.05-1.14
0.89-0,94
1.29-1,40
1,30-1,58
1.074.08
1.01-1.08
0.89-0.91
NA
1.174.20
1.2
1.094.24
1.414.42
L 164.35
Resira
Thermoplastic Resins (corstinued)
Styrene/tcrylonitrile (SAN)
Polypho»ylen®-bawd alloys (i,e.»
modified piieaylene oxide and
modified pheoyiese
High-density polyethylene (HDPE)
Henaoplastic polyester —
polybutylene teepfatolatB (PBT)
Tlwinc^et Resins
Phenolic*
Polyurethane
Poiywter,, uasatunted
Epoxy
Attyd
Urea anil melamiae
Others (swtM-volunje filennoplMtic
and fliennosel rains)'

Sea water
Fresh wate-
Density
(g/raL) '

1.024.08
1.064.10
0.94-0.96
1.30-1.38

1.24-1.32
1.174.28
1.014.46
1.11-1.48
1.30-1.40
1.47-2.00*
NA"

1.024.03
< 1.015
NA: Not»vsikbJe.
*V«3ue a for PET, PBT, «nd oftuw thwmojilajitk: polyester nmsa combined,                                '-
bDer,jjt8t« IK for filled moWilJf syitams; values for unfilled p«lku weft not available.
"I»elu
-------
 2.2-    PELLET BEHAVIOR'IN
              AQUATIC ENVIRONMENT
 Many types of resin "pellets float in fresh water
 or sea  water (Table 3).   Basically, pellets and
 granules  with  specific  gravities" lower  thai
 water will float, and pellets with higher specif-
 ic  gravities than  water  will  sink.   Additives
 may  affect polymer density,  thereby influenc-
 ing whether a pellet will float  in water.   Be-
 cause salinity affects water density, a particular
 resin pellet could float in sea  water, but sink in
 firesn water.

 Most additives  are used in  moderate  to  low
 concentrations   (Table 2),  and  the additives
 may  not  significantly alter the  pellet's ability
 to float in fresh water or sea water.  However,
 some additives -and polymer modifications will
 result in  significant changes in  the  pellet spe-
cific  gravity  and,  therefore,  will  affect the
pellet's ability to float or sink'in water.  The
changes in specific gravity that were caused by
the introduction of additives  (fiber/flike  rein-
forcements or paniculate fillers)  into six com-
modity resins are shown in Table 4,

Hydrodynamic, processes, such  as  turbulence
and  surface tension,  may  affect  a pellet's
ability to float.  For example, turbulence may
either  submerge  pellets  that  would  normally
float at the surface, or resuspend pellets that
would normally sink below the  surface or  to
the bottom.   Also,  waters  with high surface
tension, such as waters  containing a debris
slick  or discharge  from  a  municipal sewage
system, may, either support  particles with  a
density greater than water or keep an other-
wise buoyant particle submerged.

Limited data  are available that describe the
biological  ^and  chemical  activity of pellets  in
the environment.  Van Franeker (1985) report-
                              Table 4.  Effects of Two Additives
                       to the Densities of Selected Commodity Resins.
                                [Adapted from Anon.  (1988a)]
Polymer



ABS
Polyamide (nylon)
Polyethylene
Polypropylene

Polystyrene
PVC

Density
without
Additive
(g/mL)
1.01 to 1.08
1.07 to 1.08
0.92 to 0,975
0.89 to 0.91

1.04 to LOS
1.30 to 1,58

Density
with •
Additive8*
(g/mL)
1.18 to 1.61"
1,13 to 1.62s
1.18 to 1.28"
1.04 to 1.23*
1.22 to LIT11
1,20 to 1.50s
1.42 to 1.50s
1,30 to 1.70*
            •Additive; Fiber/fluke reinforeer.
            ''Additive: Putieukte filler.
Plastic Pellets in She Aquatic Environment:  Sources and Reeommend^tioni
                                         1?

-------
  ed that many • additives ace known to be toxic
  and that toxic        from the plastics addi-
  tives may,be more significant to aquatic orgtn-
      than was previously Aought,  Ryan et a!,
  (1996)            that                  in  the
  manufacture of              be            by
                      the         Known and
           biological         of        in the
  environment are           in              in
        3.3.

 The           of a pellet to the environment
 may be           in* years, _ depending on the
      type,  the types and amounts of additives,
 and the          of the       and'         to
                          .EPA (1990a) esti-
 mated  that fte -  lifetime of         products
             less      1      to            10
 years,           on the product. In the
 ic environment, the          can be
 by biological or          fouling,      buildup
 within tibe plastic,            by microscopic
             sad  availability  of
 oxygen (EPA, 1990a).

        pellets are small, lightweight, buoyant.
 (if the  pellet's          gravity  is lower
 that of                   and           in the
        environment,      are s          haz-
 ard to                  who       the
               for prey.  Section 3.0 address-
 es  the  geographical  distribution  of  pellets,
        of pellets  to the aquatic environment,
 and impacts of pellete  on birds, turtles, other
 biota, and humans.
1 *                                    Pbutie Pellet* in the Aquatic Environment: Scurcw tad ReeoimnenikfieBi

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                               3.0  THE PELUET PROBLEM
 Plastic pellets are among the smallest Items of
 debris discharged ifito the aquatic environment.
 They are, therefore, not as visible (aesthetical-
 ly  displeasing)  or  as obviously harmful  as
 larger forms  of debris,  such  as  discarded
 fishing gear, medical  wastes,  etc.   This is
 evidenced by their  exclusion from -debris in-
 ventories reported  from   the  annual  beach
         0.e., CMC, 1989,      and from all
 but one of the National parks studied by Cole
 et  al.  (1990),    However,  these small plastic
 pellets are often mistaken  for food by aquatic
 animals, particularly seabirds.
3.1     GEOGRAPHICAL DIOTRIBUTION
 Although plastic pellets are one of  the least
 noticeable forms of plastic pollution, they  are
 ubiquitous in the oceans and on beaches.  They
 nave  been reported in  the  sediments  and  the
 surface waters  of coastal  areas  and oceans
 throughout the world (Table S); data are  limit-
 ed regarding the presence of pellets in rivers,
 streams, and lakes.  The ubiquity' of pellets is
 demonstrated by their presence in remote areas
 of the  world, such as beaches of the South
 Pacific  (Gregory,  1977)  and  Hawaii (EPA,
 1992b).  Among the earliest records of pellets
 in the environment were  the  studies by Car-
 penter  et al.  '(1972) and by  Carpenter and
 Smith-(1972).  These studies reported pellets
 in the Atlantic Ocean along the southern coast.
 of New England  and  in  the Sargasso Sea,
 respectively.   Several other authors also have
 reported pdlets  in the Atlantic Ocean  (e.g.,
 Golton et of,,  1974; Hays and Cormons, 1974;
 Morris, 1980; van Franeker and Bell, 1988;
 Ryan  et al.,  1988),   In the Pacific Ocean,
pellets have been reported in  northern waters
 (e.g., Wong et at., 1974,  as  cited in Pruter,
 1987;  Dahlberg and  Day, 1985; Pay et a!.,
 1990) and in southern waters (Gregory,  1977).
 Pellets have been reported along -the coasts of
 the Mediterranean  Sea (Sh'iber, 1979,  1982,
 1987), and the Gulf of Mexico  and Caribbean
 Sea  (Carr,  1987;  Cole et al.t  1990).   Most
 pellets  found  in  marine  waters  have  been
 identified as polyethylene (PE),  polypropylene
 (PP), or polystyrene (PS) (GEE,  1987).

Under the ongoing Harbor Studies  Program,
the Environmental  Protection Agency (EPA)
has conducted studies of floating aquatic debris
in harbors along the coastal United States since
October 1988 (EPA, 1990b, 1992a,b; Ttulll et
of., 1990; Redford  et al,  1992).  The  debris
was  collected by conducting net tows at the
water surface to a maximum depth of 0.5 m.
Over  200 different types of manmade debris
were counted.  By the end of 1991, sampling
had been conducted in  13 cities.and the Mid-
Atlantic Bight during a total of 20 surveys.

Plastic pellets were among the  most common
items found  during  the Harbor Studies Pro-
gram,   comprising  approximately  94%  (by
number) of all debris collected.  The pellets
were  generally  ovoid,   cylindrical, square,
discoid, or. irregularly spherical  in shape, and
were -approximately 5 mm or less  in diameter
(Figure 2).   Most  of the pellets  were  clear,
white,  or off-white,  but several other colors
(such as black, green, yellow, amber, orange,
blue, etc.) were also  observed in the samples.
Visual assessments made by a polymer chemist
confirmed that a variety of pure polymers and
additive-containing pellets were found in the
samples (Mr. Elmer Bradbury, Battelle Memo-
rial Institute, personal communication, Febru-
ary 1991).  The descriptions are  also consistent
with EPA's description of PE and PP pellets
(EPA, 1990a).
Plastic Pellets in the Aquatic Environment: Sources and Reoommcndalksaa

-------
      Table 5.  Pellet Observations and Suspected PelSat Sources.
(PE polyethylene; LOPE: low-density polyethylene; HOPE: Nflh-dansltv polyethylene;
                      PS: polystyrene; PP. polypropylene!
Geographies! Area of Stadj
Obsenrmflem
SoorceCf) Dimi&sed ,
ATLANTIC OCEAN
Southern New England
(Carpenter «foi, 1972)
SuipwoSo
(Carpenter and Smith, 1972)
Cape Cod to Cape Canaveral sad
areas south
(Coton «ial, 1974; Cofton, 1974)
South Alkntk: Bight from North
Carolina to Cape Canaveral
(vuiDolah«fdL, 1980)
Eastern C&nadA aod Bermuda
(Gregoiy, 1983)
. Bermuda, Bahamas, and
Maiffea'a Vjneyud, MA
(WBber, 1981)
C&pe Basin aiea of South Atkntsc
(Monii,
Southwestern Cape Province, South
Africa
(Ry«n, »8Sb)
PS pdkte (0,1- to 2-tnra dk) common ks Kkntic
Bay, Buzzards Bay, Vineyard Sound, Rhode Island
Sound, Great Salt Pond, Long island Sound, tad
Block Island Sound; average 0.01 to 1 pellet pa
cubic meter. Pclkfa in cevenl fish.
50 to 12,006 particles per square kilometer (mean:
3500 particle* per square kHometei); lowest
cowxritrstkjns near the Gulf Stream.
PS and PE pdJete ( 10, WO peDrts
per Ine&r meter), la eastern Canada, a maximum of
10 PE pelkti per linear meter. Lifetime of peBeli
suspected to be is low m 3 yean, PeDcts ovsrusted
with pgcudoplajiktoaic biote.
>7S% of aeuston tows in north Sargaauo So
contained pdkts. High Mnccntraiiooa (2fXX> per
i^uaie meter) on Bermuda uid BsJmmaa beuttet,
where they axe deposited by oceaa currents. PeQrta
ofteo wnbedd*d in tor baU« ("pluto-taibkUi")-
Whfto PE or PF psflctt (3- to $-mm di>) between
1333 and' 3600 pellets per squai-e kilo meter; pellets
«nd tutwUi roost common oontantunauts in area.
Predominance of PE and other polyolefin pellets,
most of which we« < 10 mg, PeUete may be tost
during hamlb'jig ud , released into the ses vk
drainage Hneg.
Efflueat from pSsstics
m.anufastufers or PS
prodiicea in sointem New
Englujxi.
Waste dumping bom ciscs
or caigo ihipt.
Wkgtcwaier discharge from
plutiei pksts- Most PS
and MJ pcUeis catered open
eout>l_ witen brtwoer,
Block Island and eastern
Long Iskrwi,
Shipping traffic and
edtninroent from other
4uma via euneats.
Released at dump sites or
spij.Sa.ge along Atlantic
Seaboard, spUkgc during
storage, handling, and
tnAtportttba activkks.
Spillage aad IOM at wut&!
msjiufkciurksg and ibipping
sites.
No imroedi^tts source fawwn
other thsa through targo
loss.
Peiietj toss during tmaspoit
or by imnu&cture of m»
products in iodu-ftrk! UC&M;
may enter Soutfa Africa via
oce&ak- sir&ulaiiori from the,
South Atlwtie.
                           Plaatic Pellets -in the Aquatic Environinent: Sources and

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     Table 5.  Pellet Observations and Suspected Pellet Sources,  ^continued)
       [PE; polyethylene; LDPE: low-density polyethylene; HOPE: hiflh-dansity polyethylene;
                            PS: polystyrene; PP: polypropylene)
Geographical Area -of Study
GteerrttwM
PACIFIC OCEAN
North Pacific
(Wong tt aL, 1974, as cited in
Pniter, 19S7)
North Pacific Ocean
(Day el aL, 1990)
New Zealand
(Gregory, 1977)
Alaska
(Day, 1980 and Jarrdl, pers.
commun. as oiled in Day, 1980)
North Pacific Ocean
(Day «f aL. 1986)
North of Hawaii
(Dahl»erg and Dsy, 1985)
North Pacific Ocean
and Bering Sea
(Day and Shaw, 1987)
Round, eokirksa pdlet* (1-5 -mm dk) in 64% of
tows along 35 " N longitude.
Pellets found in 6% of total itaikms and 10% of
station* with plastic, CoHeeSed primarily in
transitional and nearshore waters east of Japan,
Highest density was 6500 per square kilometer north
of Hawaiian Islands.
PE aBd PP pellets, -ovoid end irpheruloid (greater
than or equal to 5-mm dLs); 10,000 to 40,000 pellets
per' met&r on beaches in narrow zone along driJUine
or spread across the bade beach and waihover flat
Subscaniial amounls of pdlcis; PH commoo bui Pi
unknown. Ai*o reported approximMely SOG.GCQ D>
of PP pellets •were dumped .into the oceari during a
dock strike in Costa Rica.
Highest densities of pkstio debris along 40" N;
pelkiiS comprised 0.5% of all pksiic debris and
occurred at nearly 4% of the stations ,
Pellets in ncujton samples collected &kmg latitudes
31* N ar»d 34° N; densitie« must be niatively high
to have been collected at all.
Very low conccntmtiona of pcliete b tbe subarctic
Pacific, especially near the Al&skjm coaM.
Souree{s) Biscusaed

Plaitics industry,
Manufacturer outMli;
spilkge from trucks, ships,
and trains ^tils loading or
unloading; and whan used
&s baQ bearing to move
cargo.
Not discussed.
SpiQage at ports or via
streams and stoim orator
drainsg* after ipflh at
inlaml prtMsesgijig planti.
EfflusnS of plastic
manufacturer! &sid during
loading and unloading of
ships at pom.
Not discussed.
Not discussed.
Not discussed.
MEDITERRANEAN SEA
Reaches of Lebanon
(Sh*er, 1979)
Beaches of Costa del Sol, Spain
(Shiber, 1982)
PB, PS, and polymethyl methaerylate pellets fairly
ramnwnonntoitbeachei, Predomin&ot pdlet thape
was ovtj to round (2- to 5-mm da).
Pdkta (2,7 to 4.5 mm) present on all 'beaches
wrnpksd (13); abundant on four beaches and
common on most oOiers. Mostly LDPE (8756),
HOPE (8%), and eihytvinyi acetate (4%).
Encrusting biota abiene on pellets, indicating recent
introduction to marine environment.
Wtste disposal by several
plastics, fsctorks or oargo
lost at ie&.
Carekw dupos&l practises
at seven nearby pk^tios
Factories, or losi darisg *ea
shipment and, cargo
unloading.
Pelkts in tbe Aquatic Efivironroent: Sources ami ReoornmendatkiM
21

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           Table 5. Pellet Observations and Suspected Pellet Sources,  (continued!)
           • fPE: polyethylene; LDPfE:'low-density polyethylene; HOPE; hiph-jfensily polyethylene;
                                  PS: polystyrene; PP: polypropylene)
Geographical Area of Study
Coast of Spain
(SMber, 1987)
Obfenrttkuu ~
Spherute in great variety of shapes tnd colon,
often tar-cowed, ibundaat on most be&ehei. PdJcts
found were predoBuawtiy PE. •
Sources) DfectisMi
Some correlation between
abundance and be&tkm of
190 plastics factoiies in
art*; cargo ton during
.tmnsport Is Atlantic OMU
and Meditamaetn Sea,
Of MEXICO AND CARIBBEAN SEA
Costa Rica end Caribbean Sea
(Caw, 1987)
P&dre Island National Stoutens
(Cafe' it ol» 1990; Miller, pen.
oommun.)
L&rge numbers uFpeUobi on green Ma twrtio nesting
beftdi in Costa Rica.
All pdMa were whits and the SUM she and shape;
73% of plastic debris and 69% of all debris were
pellets.
Industrial wastcwatcr -
Unclear whether from
single or multiple'
discharge! or from a spill.
ESTUARIES, HARBORS, •AND;OTHE! COASTAL
Hubon of DM> United States
{TraUi «r oi, 1990; 'EPA, 199Gb,
l»92*,b; Redferi etal, 1991)
Kahsim Bay, Data, Htwrni
(EPA, l»2b)
Sanitary tystens in Philadelphia,
PA tnd Boston, MA
(EPA, 1992C)
Sewage outkt pipe* at factories
near Long Wand, NY
(Hays and Carmen*, 1974)
Brartol Channel, UK
(Morw and HamiltoE, 1974)
Severn Estuary and Bristol
Channel, OK
(KJnter fl a£, 1973, 1976, aa cited
in Prater, 1987)
Many different resits m assorted SIKSS, shapes, mad
colon found in all hubon studied czceft May&gflez,
PR, Hundreds to hundred -of-ihouaflnds of pellets
in each harbor. •
Avewige of 105 peUrtt per m3 were piwenJ toweew
low and high tide lines, concentrated mostly among
o&cr Mthrapogenlo sod oatunl debrij aear high fide
inea. Pellrta appc&red clears but weathered, likely
polyrtfayfene.
Many pella Lypc« coljeetcd in storm waiar out&lli
and In scum s&mples from sewage trcaljp.cnt pkni.
All clean, PE pcttetji collected it one storm water
outftl.
1- to 13-nun-dia PS pctkss found u &r u 1,1 fan
downstream of one indwtrinl outfalL PB peikts ,
alao fouftd nmr outbll* in MA, CT, tod NI,
0 to 20.WJO re pdtoa par •quare meter unevenly
-distributed in sedimeotc, PS beads incorporated mto
polycliaeic tubes, and becoming common in plaakton
sampks.
In 1973, 1-mm PS pelkli found in mud, aaud, and
on cooling water intake screens &i nuckmr power
pknia, Mtny poiyehaets worm tuta posssiructed
almoat tntirdy of poiicte. 1% tphcralm found in
tome flounder. By 1976, peUea virtually absent in
aU location* noted in 1972 and 1973,
Industrial aad municipd
storm water and G8O
•iisch&rgM,
&simneteM ihipptai or
carried by ocean oirrenli
frora _ distant bnd-4mMd
sources.
Storm water discharges
from plastict ind'ustry.
Induitrnd efflueaL
Effluent from a PS
manufacturer.
Effluent from pkstics
induitry.
.-*.
22
Pe!l«s in tic Aquatic Environment:  Sources and

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           Figure 2.  Pellets Found during an EPA Harbor Studies Program Survey
                                      In Houston, Texas.
 Plastic pellets were found in the harbors of 13
 of the 14 cities surveyed and in the Mid-Atlan-
 tic Bight (Table 6>» and m 29 of Che 32 sam-
 pling areas (two to four areas  were sampled
 within each  city).   Mayagflez,  Puerto Rico,
 was the only major study area In which pellets
 were not found.   Pellets were  not found in
 Hampton  Roads,    Norfolk,    or   in  the
 Weymoutfa/Neponset Rivers, Boston,  but they
 were found in other areas in these harbors.

 Plastic pellets ware the most common item (by
 number of items) in eight cities (Houston, New
 York,  Tacoma, Baltimore, Boston, - Oakland,
 Philadelphia, and San Juan), awl were among
 the ten most common Items in three additioEal
 cities (Sin Francisco, Miami, and Seattle) and
 in the Mid-Atlantic Bight.  [Note: In all, only
 20 debris  items were collected  in  the  Mid-
 Atlantic  Bight,  and the  percent  composition
 should be considered with caution.]   Pellets
'were the 14th most common item in Norfolk.
Of all cities surveyed* the  greatest number,
variety, and percentage of pellets were collect-
ed  in the Houston Ship Channel at Houston,
Texas.   Over 700,000  pellets  were collected
during the Houston surveys' combined (approx-
imately 98%  of all  Houston  debris).   One
sample  alone .contained more  than -225,000
pellets.   Although pellets of many colors and
shapes were collected, most of the pellets from
Houston were clear,  white,  or off-white and
ovoid. Notably, Houston has- one of the great-
est concentrations of plastics industries  in the
United States and several pellet industries are
located  along  the'  Houston Ship  Channel.
Most of  the pellets  were found  in Buffalo
Bayou, which is  inaccessible to shipping traf-
fic.

A high percentage of aquatic debris collected
in Tacoma, Washington,  was  pellets (71%).
Unlike the  pellets from  the  Houston  Ship
Channel, those from Tacoma were similar  to
Pkstio Pellets in the Aquatic Environment,' Sources and Recommendations
                                        23

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               Table 6.  Pellets Pound during EPA AqyatJe Debris Programs.
    [Adapted from EPA C1990, 1992a,b,c), Trulii etal. (1990); and Bedford eta!. (1992)
Survey
Area Sampled
Martor Stadia Program*
Boston I




Boston n



New York I

New York 1





Mid-Atlantic Bight
Baltimore I


Baltimore n

Baltimore in


Norfolk

Miami I


Miami n


Charles River
Chelsea River
My&tle River
President Roads
WeyraouA/Neponset Rivers
.Charles River
Chelsea River
Mystic River
President Roads
Manhattan Island
The Narrows and Lower Bay
Manhattan Island
Th& Narrows and Lower Bay
States Island
SchuylkDI River
Delaware River — Camdeo
Delaware River — Philadelphia
Wilmington Canyon to Norfolk Canyon
Inner Harbor
Middle Harbor
Patapsco River
Inner Harbor
Middle Harbor
toner Harbor
-Middle Harbor •
Patapseo River
Elizabeth River
Hampton' Roads
Miami River
Dodge Island
Little River
Mjami River
Dodge Island
Nearshore Atlantic
Number
Percent,

2.6S4
0
. 7
10
0
453
2
45
. 0
2,039
461
617
548'
7,601
461
197
219
1
600
110
70
2,625
524
1,972
698
7
135
6
56
51
7
jt
6*
173
1
30
0
'2
6
0
23
1
6
0
25
8
21
27
78
32
23
42
5*
20
12
IS
46
27
23
19
4
2
U
3
11
1
3
18
2
24
Plastic Pellets in the Aquaile Environment:

-------
           Table 6. Pellets Found during EPA Aquatic Debris Programs. Icontinued)
    [Adapted from EPA {1990, 1992a,b.c). TrutH eta/. (19901; and Bedford era/. (1992)1
Survey
Harbor Studiet Pregn
Houston I


Houston n

Seattle

Tacoma
San Francisco
Oakland
Mtyagflez
San Juan
Honolulu

Area
xaf .(continued)
Upper Ship Channel
Ship Channel
Lower Ship Channel
Upper Ship Channel
Middle Ship Channel
Duwamlsh Waterway
Lake Union Ship Channel
CoiumencemeDt Bay
San Francisco Bay
San Francisco Bay
Bahla de Mayaguez to Puerto Real
San Juan Harbor
Honolulu Harbor
Ala Wai CanM
Number
Percent

106,759
352,790
15,660
38,199
186,936
20
4,
3,134
297
279
0
714
181
. 2
98*
99
98
96
97
8
I
. 78
9
IS
§
23
5
Iid wastes it eadi.
Pkstic Peilcts In the Aquatic Environnvcnt;  Sources and
25

-------
 each other in size, shape,  and color.  Most of
 the tacoma        (2732        out of 3S34
 pellets) were found  to a single simple.  These
 observations suggest that the pellets may have
 originated from a single source.

 The New York/New Jersey Harbor complex,
 ranked  second  by number  (11,266  plastic
 pellets) and third in percentage  of  plastic pel-
 lets  (39%).   In  samples  collected from  the
         and       Rivers  around
 Island,         varied considerably in  color,
 saaper and condition,  indicating possibly  sev-
      sources of entry  into the environment.
 Some pellets from           were embedded
 in grease, tar,  or other organic matter (includ-
 ing  fecal, matter), which might be expected to
 accumulate on debris flowing from .combined
 sewer overflows (CSO).  In samples collected
       the  Kills  (the
             "from New Jersey),
 of a      uniform size*       and color.
             Immediately'following a February 1992 survey
             of the harbor it Honolulu,  Hawaii, the pres-
             ence of pellets was studied at the beach along
             Kahana Bay on the northeastern coast of Oahu,
             Most of the  pellets collected at  Kahana  Bay
             were  white  or  off-white,  and  many were
             weathered or  .discolored.  Several  Mack
             were  also fbmad in each, sample.         0a
             enumerations.along three teansects, the average
             number of pellets on the beach  at Kahant  Bay
             was  105        per m* -(range:   8S. to  115
                    per m*).  The        were found inter-
             spersed with  other manmade debris, including
             light sticks, net floats, plastic food containers,
             and plastic pieces,  and natural  debris such as
             driftwood and seaweed,  and" were  concentrated
             in me portions of the transects that were  far-
             thest from the water.  According  to the -Chief
             Scientist,  many  more  pellets  and  types  of
                   were        on fee same beach in 19S9
                    were            daring   the   survey
       Figure 3.  Plastic Powder Found during an EPA Harbor Studies Program Survey
                                      In Houston, Texas.
26
PLwtic Pcikts ia the Aquatic Environment:  Source* and Recommendation's

-------
             {Mr, David Eedfbrd, EPA, personal communi-
             cation, February  1992).  The decreased num-
             bers of pellets may have       due to  heavy
             storm activity during the two weeks prior to
             the survey,   which would have resuspended
             beached pellets in rough surf conditions at high
             tide,

             Two  'additional   pellet-related  items,  plastic
             powder  and   flattened pellets, were found in
                    cities.  Plastic powder, an intermediate
             form of the raw         used to      pellets
             and molded products, was observed floating on
             the witer's surface  and was collected in con-
                      volume  along with  other  debris. In'
             Houston, this powder was  initially thought to
             be grain dust from nearby grain elevators,  and
             was discarded as  natural debris  (i.e., not an-
             thropogenic in origin); Figure 3  shows plastic
             powder collected fa Houston,  However, dur-
             ing the  pellet producer site  visits  conducted
under  the  present  study,  the
recognized the powder,  and plastics
personnel verified that the «material was
powder.   For additional verification of these
conclusions, the investigators removed some of
the material  from the .Houston          and
heated the material  in  a metal spoon.   The
grains melted  and  subsequently solidified into
an amorphous • mass  after tooling.  Tie
appeared to be plastic," although this was not
confirmed by         analysis. Survey stiea-
     do ' 'not        collecting this powder in
other  cities, but again the material pay have
been overlooked as natural debris.

Thin, irregularly shaped plastic disks approxi-
mately 1 cm m diameter (Figure 4) were iden-
tified  in samples collected from several differ-
ent harbors. At the time, these disks could not
be  identified,  and        were subsequently
counted and recorded as miscellaneous
              R§yre 4.  Flattened Polyethylene Pellet? {Top! and a Virgin Polyethylene Pellet (Bottom).

            Pkrtib Pelleti in the Aquatic Environment: Seunxi and ReeommewMtiens  -                                 27
 I
 * *
: K

-------
 pieces.   However, several  disks  Identical to
      collected during the surveys  were found
 during a site visit to a pellet producer.  The
 plastic disks, found among plastic pellets, were
 scattered along  railroad tracks and beneath
 hopper cars in the loading and cleaning
 of the producing _ facility.    Plastics industry
          Identified the disks as plastic pellets
 that had been flattened by rail hopper cars.
 3.2
        IN
 Several  researchers  have soggested  possible
 sources of pellets to She aquatic environment
 (table 5), including

    •  Direct discharges and improper waste
       water disposal by the plastics industry
    *  Waste disposal and  sewer discharges-
       by
    *  Spillage from tracks, trains, and
       during loading, transport, or unloading
    •  Improper use of pellets,  such as for
       packing  material, for  insulation, and
       for         to facilitate the 'movement
       of cargo boxes  and  otter heavy ob-
       jects.

Unfortunately, most studies focused on report-
ing pellet distributions and  abundances, and
the source identifications were      mostly oa
empirical  evidence  rather than on' direct evi-
dence.   As  presented  in Section 3.2,1, the
recent EPA  studies  of  U.S. harbors (EPA,
1990b,          and       (EPA,        have
provided        d|rect   evidence- that storm
sewers, CSOs,  and  direct spillage  into the
waterways are sources of pellets to the aquatic
environment.
             3.2.1   EPA's Harbor Studies Program
             ,As disoissed in Section 3.1, EPA has conduct-
             ed studies of floating aquatic debris in selected
             harbors of the United States.  One objective of
             the EPA Harbor Studies Program was to iden-
             tify potential sources of floatable debris col-
             lected during the surveys.    Several possible
             sources of  pellets  were identified  based on
             field observations and conversations  with local
             authorities;1 these sources  were CSOs  and
             storm sewers, storm-water runoff, and spillage
             from loading docks.

             The results  of surveys in New York, Boston,
             and Houston, for  example, indicated that CSOs
             aad storm sewers were sources of pellets in the
             aquatic environment.  In the Kills     of New-
             York  Harbor, the cleanliness and  .uniform size,
             shape, and 'color of the collected  pellets (as in
             Tacoma),  indicate a possible single source.
             Because  the pellets  were mixed with other
             debris typically discharged from  storm sewers
             •or CSOs, storm  sewers and  CSOs  are likely
             the discharge points for "pellets released by the
             plastics industry and related transporters,

             In Boston, the majority of "the pellets was col-
             lected from  the Charles River on the freshwa-
             ter side of .the locks near the Museum of Sci-
             ence.  There is no commercial shipping on the
             River aad there are no known pellet industries
             along the banks of the River:  This suggests
             that          are  entering  the  ' environment
             through storm  sewers or  CSOs  that receive
             storm-water runoff and  other          from
             pellet industries,

             As previously discussed, extremely large num-
             bers of pellets were collected  from every area
             of the Houston Ship  Channel, Large numbers
             of pellets were found above, or  west of  the
             turning oasin in Buffalo Bayou, where there is
             no commercial  shipping  and tidal fluctuations
             are minimal  (<0,5 ft).  Because of the Sack of
28
Plastic PeUeti to the Aquatic Environment Sources and Reeomfnendaibnt

-------
 shipping and  the unlikely transport of pellets
 by  tidal  currents,  pellets found  in Buffalo
 Bayou were most likely discharged from storm
 sewers (Houston -has no CSOs) or  carried into
 the Channel directly by storm-water runoff.

 The results of surveys in Tacoma and Houston
 indicated that  spillage at loading and shipping
 docks is another source of pellets in the aquat-
 ic environment,   in Tacoma,  a  local resident
 reported that a crate of pellets  was  spilled into
 the harbor  2  months  prior  to the  Tacoma
 survey, thereby establishing the possibility that
 a single discharge was a possible source of the
 collected pellets (Mr:  David  Redford,  EPA,
 personal communication, March, 1989),   An-
 other resident stated that pellets were regularly
 observed on local beaches; this would indicate
 that pellet spills may be common to the Taco-
 ma  area.  In'addition, the  feet that people are
 noticing pellets during recreational  activities
 indicates that pellets are frequently present in
 large numbers; .large numbers  would make the
 pellets more obvious and  easier to  distinguish
 from natural debris.

 In Houston, pellets also were collected in  mas-
 sive numbers in the middle area  of the Hous-
 ton  Ship Channel  (areas below or east of the
 turning basin).  These pellets probably entered
 the channel through several sources, including
 spills at the loading dock,  spills aboard  ship,
 or spills at  industrial sites where  pellets are
 carried by rain water into the storm sewers or
 are blown,into  waterways.   Pellets  discharged
 into Buffalo  Bayou would  also be transported
 to areas  east of the turning basin. Discussions
 with a local longshoreman  Indicated that  dur-
 ing  ship loading operations pellet  packaging
 often was punctured by forklift tines. When
 the pellets were transferred from the dock to
 the ships, thousands of pellets would spill  onto
 the dock and directly into  the Channel.  . He
 also indicated   that  pellets spilled  onto  the
 docks were  swept directly  Into  the  Channel
 during routine maintenance of the area.
3.2.2   EPA'i CSO Studies Program
In  older  cities  of the  northeastern  United
States,  CSO discharge  of raw  sewage  and
street litter are  common  during  heavy rain-
storms.   Studies conducted under  the EPA-
sponsored CSO  Studies Program examined the
types and  amounts of  floatables discharged
from selected CSOs and  storm sewers, as wen
as  floatables  captured  by  bar  screens  and
settled out in the  scum  of sewage treatment
facilities in Philadelphia and  Boston.   Final
data show that pellets  are present in the sew-
age treatment plant scum (small-sized, floating
material at the  surface  of the settling tanks)
   Table 7. Pellets Collected Each Day
     at Sewage Treatment Facilities In
          Philadelphia and Boston
               JEPA (1992c)]
Location
Philadelphia
Northeast WPCP
Southeast WPCP
Southwest WPCP
Boston
Ward Street HW
Chelsea HW
Deer .Island STP
Number
Day!'

2,110
22.S20
5,520

0
0
650
Number
Bayr

1,310

19,360

0
0
160
  WPCP:  Water Pollution Control Pknt
  HW;  Hwdworioi
  STP;  Sewage Treatment Plant
  "Daily totals calculated ba*ed on the mnalyra of
  10% of the screening! and scum present each day at
  each facility.
Plastic Pellets is the Aquatic Environment: Sources and Reeommendltloiw

-------
          (Table 7),  ia  CSO          of tooth"
 cities,  and in the                     -collect*
 ed in Philadelphia (Table 6). No 'storm
 were sampled  in  Boston,   [Note: One
 was"        in the CSO           In Philadel-
 phia;      data should be viewed  with caution
         it was  not             that the CSO
 had                   the  study.]  Hie
 from this study        that        are
 ing  municipal'                    from land-
        sources,  and  are subsequently
 tike                               CSO and-
 storm sewer discharges.
 3 J           AMI
 "Here,  are          documented          de-
 scribing       and                     tages-
 tlon by wildlife,      notably by seablrds and
 set turtles  (Table 8).   Generally,         or
 biological effects of the pellets have not been
 clearly defined in most  wildlife, and, to
 direct
 and            not been              conclu-
 sively,   "His      be             to the fact
 that  the         typically  use           and
         animals, and               that die at
 sea      sink to-the bottom or are consumed
 by predators before-ftey are found by
33.1
He          of        by          has
reported worldwide (Table  8),  md
                          frequently thao  do
my  other taxon  (Ryan, 1990),   Sileo  cf at.
(1990)  reported that 80          or approxi-
                   of all -seabird species, are
known to ingest plastic debris. Pellets are tibe
                    of
by          (EPA,  i990a;  Ryan, 1990)." Day
          Figure 5.  Pellets ingested by' a Setblrd.
            (Photograph by Robert Day, Afaski
           Biological Research, College, Alaska)

                           that
        remain ia th'e digestive       of birds "for 10 to
        15        (Figure 5).

                              the vulnerability of  t
        seabkd population to the          of pellets.

            «   frequency  of  regurgltation —  Birds
               with a limited ability  to            are
                           to be          by
               ingestion.  Debris       in  birds' are a
               function of the       of fte       of
                          and                 (Ryan,
               1990),
            *   Foraging        — Birds that feed by
               pursuit diving  are the most likely to
               ingest  pellets, and       that feed by
               plunging got piracy are the     likely
               to      pellets (Bay^f a/., 1985),
            »   Pellet  color —            ire
               likely  to               mat are  light-
30
Pellete in the Aquatic Environment: Source* and Recommendation*

-------
         colored  (e.g.,  white,  tan,   brown,
         yellow) than those of any other color
         (Sileo a al., 1990; Day a al.t  198S).
         This color preference has been attribut-
         ed to the pallet's similarity to  common
         food sources, such as fish eggs,  crusta-
         ceans, etc. (Day et al.r 1985).
     «   Prey type — Pellets pose the greatest
         threat to plankton-feeding species, such
         as  shearwaters,  petrels, prions,  phala-
         .ropes, and auHets (Fry etd,, 1987).
     *   Proximity to pellet sources — Logi-
         cally, the closer that a  seabird is to a
         release point, the more likely it is to
         encounter  and   ingest  pellets   (EPA,
         1990s; van Franeker and Bell,  1988).
     »   Proximity  to,  areas  where  pellets
         accumulate — Species that feed at the
         ocean surface are more likely to togest
         plastic, most probably because they are
         more likely  to be  exposed to floating
         plastic (Sileo ersJ,t  1990).

 The  effects on  seabirds of ingested pellets and
 other plastic  debris were summarized  recently
 by Ryan  (1990) at the Second International
 Conference on Marine Debris  (Shomura and
 Godfrey,  1990).   Ryan  (1990) stated that
 anthropogenic debris -may  have three  specific
 effects on  seabirds;   (1) diminished foraging
 ability or  a decreased  foraging  efficiency, (2)
 physical  damage (e,f,f  intestinal blockage),
 and (3)  physiological effects from the absorp-
 tion  of  toxic chemicals associated with  the
 pellets.

 Diminished foraging ability appears  to- be the
 most serious effect of pellets on  seabirds". The
 presence of pellets in the stomachs of seabirds
 may create false feelings of satiation, decrease
 the storage volume of the. stomach, and reduce
 foraging.   Ultimately,  this will  reduce  the
 ability of the seabirds to accumulate the energy
 (fat) reserves necessary for migration,  repro-
 duction,   molting,  and   survival  of  adverse
 environmental conditions (Day  et al.,  1985;
Ryan,  1988a, 1990).    These  effects ' would
 occur most likely  in  proeeliarliform seabirds,
 which, compared to other seabirds-, experience
 the  highest  incidence  of  plastic  ingestion.
 (Ryan, 1988a),  However^  a few pellets to a
 bird's stomach are not likely to have an ad-
 verse affect, primarily because many  seabirds
 retain indigestible  materials in their stomachs
 to  aid  in  digestion  (Puniess,   1985; Ryan,
 1988a,  1990),  although Wallace  (1985)  be-
 lieved  that  the birds  could be  chronically
 stressed.  Studies to determine a critical pellet
 volume have not been  reported.

 Studies of..potential impacts caused by pellet
 ingestions generally have indicated that physi-
 cal damage probably  occurs  in  only  a small
 number of seabirds.  Day (1980) reported that
 ingestions increased  the gizzard  volumes  of'
 some auklets, resulting in the full distension of
 the gizzards and a potential reduction in. hun-
 ger.  Where individuals that had ingested.large
 numbers  of pellets,  the pellets were found
 embedded in  sockets  in  the gizzard wall,  but
 no  effects (good or bad) were noted.  Day et
 al.  (1985) subsequently reported mat ingested
 pellets reduce the  storage  volume of seabird
 stomachs,  •

 In  a  controlled study  of the  effects of large
-numbers  of PE pellets  in  white-chinned pe-
 trels, Ryan and Jackson (1987) reported no
 significant  changes   in  digestive  efficiency
 between  test and control birds.   Several  au-
 thors  have  document  lacerations by sharp
 debris (e.g.,  Day  et  al.,  1985; .Fry et a?,,
 19S7, Ryan  and  Jackson,   1987);  however,
because   pellets are   generally   round  and
smooth,   it  is  unlikely  that  pellets lacerate
stomach linings in seabirds.

Finally, plastic pellets in the environment may
contain chemicals  that are- toxic to seabirds.
These toxic substances may be  additives that
were  Intentionally  mixed  into  the rain to
achieve  specific properties,  or   contaminants
that were adsorbed by the pellets  from the
environment.  Carpenter et al. (1972) reported
the adsorption  by pellets  of organoehlorine
Plastic Pellets in the Aquatic Environment: Sources and Recommendationi
                                          31

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                        Table i.  Pellet, digestions and Potential Effects.
Geographical Location *
Spades leportal
Ikscripttoa of TBgeitkm or EfTeds
ilRBS
Alaska
(D»y, 1980)
Califomk
(Chu, pens, Mmaiuh,, aa
eited in Day «/ ai, 1985)
Galapagoa Isknda
(Anon,, 1981, u cited in
Day ct al , 1985)
Monterey Bay, CA
(Baltz and Morcjohn,
1976)
New Zetland
(Ember, pen. commun.,
as cited in Dty a al ,
1985)
Chatham Islands ind
GoBgfa bknd
(Bourne and fate1,
1982)
Eastern Canada
. (Brown *f si, 1981, u
cited in Day it eL, 19 15)
South Africa
(Puraeii, 1983, u oitaf
in Day et al, 1985)
Dutch COMI
(via Fnuneker, 1985)
Northern fiiliwn, sooty ahearwaten,
short-tftMed theuwmtat, red- legged
kMw&ke, thick-billed murre, Cuatn'i
aukiet, pamkert aukl«t, ftjftcd puffin,
horned puffin, folk-tailed «torm-pefcrel,
Le»ofj*s storm-pelrel, northern
phfli&repe, gkiux>ua gull, bke-k-lcggc^S
kictiwskc, and least auUct-
Sooty shearwaters
Blye-footed bcwby
Northern fulmmrs, pink-footed
shearwaters, sooty ahearwaten, tbort-
tailed shearmton, Heermuin'g giiii, and
black-legged totthMke.
Grsat-wioged petrels, kwguden petrels,
Cook's petrels, blue pdnli, bro&d-bilted
prions, antarctic prions, fairy prions,
PuMnson's petrcta, wbkft-£&wd itana-
petrcls, ulvin'i prions, tad sooty
slie&rw%to«.
Browi-byjei priont and whifo-ftfiad
itonm-pttrelt.
Greater shwrwatcrs and sooty
ihearwsten
Greater ihearwrteri
Pulm*n
Ingesfions likely due to peltef resemblaiic«to n&fural
prey, and wjjj incre&«c u anaiml plastics pnxSuctiors
tad use of pellet* increase. Some particles
embedded ia gizzard walls; mean residence tune u
gizaris nay to appronmsMy 15 monthi.
Hydro-carbon poliutwiu Wflociatai witjt the peUett
m&y decrease reproductive ability of  50% of stomachs contained pdlets; toxic additives
in pellets nisy be fiAsijniktcd by birds.
32
Pellrts in the Aquatic Environment; Sources and Reoornmenduibiu

-------
ri
                               Table 8,  Pellet Ingesttons      Potential Effects,  fcontinued)
                          Location
 Spacks Reported
                                                                                                    or
              Midway Island aad O&liu
              blind, Hawaii
              (Fry ««£, 1987)
 Wedgo-teiied shearwaters
 60% of bWs contained pe!M« (majority were PP
 and PE) and plastic fragments; toxioity of add stives
 and orgajiDcl'iteririe potlutAnts may be less sigriificant
 Jwz&ni Uwn obstmcUon/impaction of the  gut  of
 sestoird*; riski to chick* may differ  from risk* to
 adults.
             ScoMuh
             (Pumess, 19S5)
 ProeeUtrilfoim $eabMg (Letch'« petoels,
 Manx ih«rwate»» and Aiknan)
 Fulmars and Leach's petrels select debris' according
 to their preference for particular prey aizea.  Only
 equivocal stalJ-stical  cvidcoce for u  utfluowc of
 ingested plastic on body maw. Pellets not found la
 British storm petrels.
             l^bomtoiy experiment,
             (Ryan, 1988«)'
 Chicken*
 Even under Ideal feeding conditions,
 birds  cuuiot  forage  u cfficieatly  as
 birds.  Large load* of plassie anpur  feeding by
 reducing  meal iize,  which may, therefore, link
 tceumttlatioo   of  fel  reserves   essentk!   for
              roigmtion. wrf moftaig.
             Antarctica
             (van Pnmeker and Belt,
             1988)
       'i storm petrel*, northern fulmars,
and .Cape petrels.
 Pellets  comprised  73* of all  ingested puticlet
 (oombinfid  for  aD   «peci«);  plastic  pirtislei
 remaining in the gizzards of petrds may penist for
 sBoaths  or  years  if  not regurgitated.   Decrease
 fitness is a lijfely consequence of ingestioci by chioki
 and adultt.   Most plastic* originate  us wintering
 ue&a outside the Aotoctic.
             South Africa and
             Southern hemisphere
             (Ryan, ItST)
Blue petrels, great ihearmten, wfaJte-
•faced stoim-petrek, pintado petreli, thin-
billed  priori, anteetie prion, ativin'i
prion, sooty shearwater,
*retic sknm, Cary'i
baok&d •torm-petret, brotd-bUled prkm,
kergueien petrel, subaittaxctk akiis, soft-
plumaged pctrd, ^teat-win g«d  petrel,
AttanEie petrel, and white-chinned petreL
 Three fecton dctennlne the rate of pellets (and
 plastic)  Ingestion:    foreging  technique, dietary
 specialiation, md datslty of-pellet (polutantt) in
 the forapng ant*. Proedltiiifonn teabiidt exhibit
 tbe largest plastic loads owing to foraging patent
 at the sea surface.  Secondary uigestion of piwiic
 through  contaniiamled prey a un«>fninon and *•»«•
 found only in  subanlansio skua which preys  on
 imaU petnsli containing pkitic i^itieles.
             Gough Island, South
             Atlantic Oe*an
             (RyaacroJL, 1988)
Gnat Ae&rw^ers (fenaa!e« only)
 Positive^   correlation   between
 biphenyl  (PCS) and plastic loads in  the
 PCBs Ukely wiaw derived from ingested ptoatic
 particles, acul these PCBs contribute significafitiy to
 the bM&l body lo«d of PCBs m greal she&rwttcn,
             Long Island Sound
             (Hays and Cannons,
             1974)
Gulls and tmu
 PS  pellets  found  in  tern  &0d  gull  pclkts
             mdigcsUbk food).
             Southern Indian
             (Ryu and Jackson, 1987)
WhSte-chinned petrels
 PE pclJtta lort 1 % of thar asms after 12 day § (hilf-
. life equal to &i  lout  1  year);  no Instances of
 Lntesiiaai  obstrticticn or physics!  damage to the
 bird*; ingested  plastjc  sckkjm impair* digestive
          in
           'Pi&stic Pellets in the Aquatic Environment: Sources and Recommendations
                                                                                 '33

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                Table 8. Pallet Sngestions and Potential Effects,  (continued)
Geographical Location
Hawaii
(Site a al., 1990))
Bodega Harbor, CA
(Connors and Smith,
1912)
Qaiapago* Islands «nd
South Aflaniio Ocean
(W«Me sod Cafcman,
1983, && eked in
Wallace, 1WS)
Spedscs Reported
SeabinJi
Red plwktopeg
Blue-footed bodies, ihort-*a«d owls,
bro&d-bflkd prior, , and South Pokr ikua.
Deseriplkm of logestimi or Effects
80 spcdcs, or approSMTiately 25% of ajj sesbird
apecieg, we known to iogeat plastic defera.
6 of l.blrek contained plastic partadcs, most of
which were Pfi pelldt. Plastic ingestion may be
pmducing pbyiioiogicsl cflcci» Umt Ouatea auoeess-
ful migmsion snd bfsxxiing in regksns jentoto from
&e pollution gources.
Secondary ingestion of pdl«*« from fbad source:
blo»rfooted boofeics and short-cared owk consumed
fish containing pellets, ^ and broad-bilt.od prior;
cotuume*! a skua oontaiakg pelMt,
TUETLES
Te»s«»«rt
{PtotMo and Amos, 19M)
Texas coast
(Amos, pen, eommuu.,
, m cited in Bate, 1985)
Soulh Africa
'(Hughes, 1970, 1974, as
oited in BaJazs, 1985)
Florida
(Meytan, 1984, as sited
is Iftkzs, IMS)
Ftorkk East Gout and
Caribbean Se*
(Carr, 1987)
.Hawaii tud worldwide
{Bakzs, 1985)
Mediterranean Sea
(Gramentz, 19SS)
Texa$ coast
(Batkifl and Amo«» W88)
Texas oowt
(Staver, 1991, pen.
.eommun.)
Loggerhead, gnen, Kawtablll. and
ICsmp'g ridiey turtles.
Green turtle
Loggerhead turtles
Hawksbffl tuitfoi
Loggerhead and green sea uirtlos '
Sen turtles
Loggerhead turtles*
Loggerhead, green, and h&wksbili sea
turtles
Kemp't ridley s&t. turtles
PeUeti were Lngeatod by eight turtles , utd cornprued
7% of all ingested debris.
PE spherules in mouth of stranded, dead «c& feutle.
6% of stranded pesthateUings contain od pclkts in
ItDRUCb.
PS pelkts and other mannude materi&k in
ttomachfl.
Resemblaftcc to Sargmsum floats may account for
tagegtjo&i; youcg KB turtiea vulnerable dunng open*
ocean usocktiofiB with Stargossum rafts; large
nuinbc-rs of pelkti found on gteen sea turtle nesting
beach.
Mkrino turtles cat a wide v&riegy of synthciio
r&aicria!, inducing pelleti. Effects of toxk
chemicals rclttsed by these materials and physical
otaructiofl of the digestive tract* are two possible
«dvers« impacts.
PeUets, crude ail, and tarbalk apparently arc
ingested and excreted.
PE pellets iagested by 9% of necropsietl turtles;
high probability thai sea turtles inhabiting Texas
coast will some into contact with debris.
2% (2 ou« of 101 turtles) contained pellets; one
turtle wu wild and one was reared in captivity.

34
Plastic Pellets in the Aquatic Environment: Sources and Recommendations
                                                                                                         I

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                  Table 8,  Pellet Ingestions.and Potential Effects,  (continued)
Geographical Location
Species Reported
Description of Ingest*®® 0r Effects
FISH AND INVERTEBRATES
Severn Estuary
(Karter elal,, 1973, m
cited in Shiber, 1912 and
Pruter, 1987)
New York Bight
(Strimle, 1991 (pen,
eornmun,}
• Southern New England
(Qurpentar a aL, 1972)
Rounder and polychaetes
Lobster and winter flounder
Grubby, winter flounder, white perch,
and silversides (fish), and one ehaeto-
gnati (arrow worm)
Ingeatjons by flounder. Polyehaeteg uscoiporate
pellets into dwelling tubes.
Low numben of pellets ingested, and more common
in lobsters than m winter flounder,
PS pellets •in stomachs of S out of 14 specks of fish
and one chaeiognstb; ipecuktod that peiicts could
cause intcatinal blockage in nutOer fish.
OTHER BIOTA
North American water*
(Walker and Coe, 1990)
C&nad* and Bermuda
(Gregory, 1983)
Caribbean Sea and waters
off Florida
.(Winston, 1982)
Baleen whales
Bpibionti
Epfbionts
Suggested thai niter-feeding makes bakoi wbalcs
vulnerable to inckSente] ddbrii ingestion; stonmehs
of stranded bakcn wfcika should be cjumm&d.
Epibionts on pelkd include coralline algae,
bryoxoans, ealcareoug annelids, ftnd foramioifersuis.
Ptotics (including peUcta) encrusted with btyozoan
(Electro. leneUa); success of this spates on the east
coast attributed to Sti oolonizing of drifting smooth -
surfaced plastic.
ESTHETIC AND ECONOMIC EFFECTS
New Zealand
(Gregory, 1977)
Worldwide
(W&Ikee, 1985)
Bermuda
(Wilber, 1987)
United States
(Klenan and Wendt,
1990)
Humans
Humans
Hum&iW
Humus
Concentration* ranged from < 1 pellet per meter of
beach to > 20,000 pellets per mclrr, and may lend
to esdiedcaliy dispkasiag plastic sand bcachea.
Pdkts h*ve A negative effect on rsercational
activities; economic impact due to loss of raw
materiftls that must be replaced.
Beachgocrs shocked by the presence of high
numbers of pellets; pellets And pkjtic fragments
embed in t&Tbalk and bKcon-,cplasio-iarballs,
Labeled cornbination of plastic debris and pelkti
beach eartfeKi.
Plastic Pc-liets in the Aquaiic Boviranment: Sources and Rccornmeisdations
35

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 compounds  from  ambient  seawater.   Day
 (1980) noted a decreased ability to  reproduce
 In pellet-ingesting bads, which he attributed to
 the  hydrocarbon  pollutants             with
 plastic,  Ryan et of. (1988) provided the only
 direct evidence of a correlation between plastic
 loads  and PCBs in seabirds, but Ryan  (1990)
 speculated that paint chips  and tar balls may
 contribute more significantly than do pellets to
 the total toxic chemical load in seabirds.

 Further  studies  are needed to  determine  if
 pellet tagestion leads to poor bird condition or
 if poor bird condition       to pellet ingestlon
 (Connors and Smith, 1982; Bourne and Imber,
 1982;  Ryan, 1987,  1990).
333,   Turtles
Balazs (1985) found  that marine turtles ingest
many       of floating debris, including plastic
pellets  (e.g., unfoamed  polystyrene  beads).
Evidence suggested that plastic material passes
through  the digestive  tracts 'and  are voided
naturally.   However, Balazs (1985)       re-
ported that ingested  debris may       poten-
tially serious problems in sea turtles, such as
lost nutrition, reduced absorption of nutrients,
and adsorption  of plasticizers.   In addition,
      plastic            may adversely affect
turtles during digestion  when pellets  or  frag-
ments  are ground together by muscular con-
tractions, sod  pinocytotic  absorption  of the
resulting  microscopic plastic particles could
occur.   The latter phenomenon      suggested
to occur     in            [Pettjt elol., 1981,
as cited in Balazs (1985)].

Balazs (1985)            several explanations
for tagestion by turtles,

    *  Marine  organisms  encrusting  plastic
       debris may be a desirable food source
       or may      the artificial nature of the
        debris,  thereby  inhibiting a  rejection
        reflex by the sea turtles.
    *   Under conditions  of  exteeme hunger
        when available food stocks are limited,
        sea turtles may     on       that
        would not normally eat.
    *   Prey that has consumed  debris is in-
              by a predator,
        that the increasing volumes .of.
        particles In the oceans       this mech-
        anism distinctly possible,

 Balazs  eoaeluded that additional           is
        fa regard to incidence and         of
 plastic ingestions by sea turtles,

 Carr (1987) discussed the significance of non-
 degradable  debris.  Including  pellets, to sea
 turtles  duriag  early  developmental  stages.
 Because  manmade  and   natural   debris  and
 planktonie organisms accumulate Moag conver-
 gences, Carr concluded  that young, advanced
 pelagic-stige sea turtles are vulnerable  to the
         of       In the        owkg to the
 turtles*  dose  association  with  the  conver-
 gences.   The findings of Florida (1988) and
 Piotkia and Amos  (1990)  support Carr's con-
 clusion.
3 J3   Other Biota
Although most of the published literature de-
scribing ingestiori  and  biological  effects  of
pellets concerns seabirds arid sea turtles, a few
studies  have
pellets  and other  organisms,  including  fish
[(Carpenter et at,  1972; Karter el a/., 1973,
1976; Coltofl  et a/., 1974; Mr,  Frank Steimle,
Nations! Marine Fisheries Service  (NMPS),
personal communication,  August?i991)], sev-
eral- invertebrates  (Carpenter  et  of,,  1972;
Karter et.ol., 1973;  Mr.  Frank Steimle,  Na-
tional   Mariae  Fisheries   Service  (NMFS),
personal communicatloa,  August 199!), and,
                                      Pkstic PeUets in the Aquatic Environment Soureea and RecommoiclatioM

-------
  potentially, baleen whales  (Walker and  Coe»
  1990).   Secondary  ingestioas of  pellets  by
  seabirds were reported by Wehle and Coleman
  (1983, as cited  in Wallace, 1985); the investi-
  gators  reported that  the bads had consumed
  other-birds and fish-that had ingested pellets.

  A few investigators have reported colonization
  on pellets by -biological organisms that are
  normally epibioots on Sargassim floats and
  other  floating  organisms.   The  epibionts re-
  ported  include faydrozoans and diatom  (Car-
  penter and Smith, 1972; Winston,  1982; Greg-
  ory,  1983), bryozoans, coralline algae,
  calcareous          and otter           worm
  tubes,  and  foraminiferids  (Gregory,  1983),
  Accumulations of organic matter and tar or oil
  have  also       observed on         (Wilber,
  1917;          a  a/,,. 1992);  the  presence  of
  these materials  could  Increase the possibility
  that an animal might confuse  the  pellets  with
  Its        food sources.  Finally, one study re-
 ported that pellets might be  useful  to some
 .species: Karter' et at. (1973) found that 'poly-
        worms used pellets  to  build  dwelling
 tubes,
impacts of pellets to recreational areas were
discussed by Wallace        and GEE (1987),

A final impact of pellets  in  the environment
may be measured in. terms of economic costs.
The loss of feedstock and  the       of replac-
ing the feedstock  may  be offset  only if  Ae
pellets are recaptured and  recycled  instead of
replacing them (Wallace, 1915). The econom-
ic incentive to recycle spilled pellets was evi-
dent during the site waits of the        study,
where several of the  companies' were already
actively collecting  and recycling waste pellet!
and      plastic scrap.
 33.4  Aesthetic and Economic
 Several  authors have documented the human
           (Gregory,   1983;  Wallace,  1985;
 Wilber,  1987; KJemm and Wendt,        and
 economic (Wallace, 1985)        of pellets in
 the environment  Although plastic       may
 not  be  as  aesthetically  displeasing  as other
 items  of debris,  such as sewage-related  and
 medical-related  debris, the            present
 and       persistence  in  the  environment are
       for notice,   Gregory (1977) speculated
 that  some-  day man will  sunbathe on plastic
 sand beaches; Klemm and Wendt (1990) la-
 beled  the  combination of-pellets and plastic
 fragments  beach  confetti, tat  believed its
presence was not a celebration.  The aesthetic
Pkstic Petes in the Aquatic Environment: Sources u>d Recemmcacbtiom
                                        37

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                              4,0.  PELLET             TO
 I
 Because,  as reported  in  the literature, plastic
 pellets are  frequently  mistaken for  food  by a
 variety of aquatic animals (Section 3,0), atten-
 tion must be giveo to the sources of the pellets
 In the eavlronment.  One of the objectives of
 this study is to  identify  file sources of
 release into the environment within  the plastic
 industry.    To  this ead,  the. Society -of fee
 Plastics Industry, toe.  (SPI), arranged for
 sector of the  industry-  —  pellet producers,
 transporters/contract pickagers, and processors
 — to be  visited  by the study  team.  The site
 visits were arranged with the understanding by
~all parties that the        of'the visited compa-
 nies would  remain confidential.  Each compa-
 ny was assigned  a letter in the order in which.
 it was  visited (i.e.,  the first company  was
 assigned the letter A, the second company'was
 assigned the letter B, and  so on),

 The degree to which  the observations reflect
 the  overall  conditions and  practices of the
 plastics industry -was not  determined, ' Only at
 Company  C did  officials      that no inordi-
 nate               or  housekeeping  activities
•were performed  prior to the visit  and  that
 operations were conducted as usuil during the
 visit.

 In this section,  the equipment and  operations
 of each  sector  are described generally,  and
      general  description is   followed  by  a
 description of tie sector's site visits.  Sources
 of pellet          into  the environment
 each respective sector are     presented.
producers, transporters/contract packagers, aod
processors.   Figure 6 shows the organization
of "the Industry and,  specifically, the  flow  of
plastic pellets witMn       sector and
the' sectors.  The        are defined as

    »  Producers — Discussed is Section 4.2,
       illustrated In Figure 6(a)
    •  Transporters/Contract  Packagers   —
       Discussal ta Section 4,3, illustrated to
       Figure 6(b)
    •  Processors  —  Discussed in  Section
       4,4,          in Figure 6(c).

Miny of  the operations described to  the fol-
lowing sections may, in reality, occur  to more
than one industry sector.  For example, opera-
tions  relating to pellet  packaging and storage
occur at producers as  well  as contract pack-
agers, and conveying systems exist In all three
sectors.  Operations are typically described in
the industry sector  that has  primary responsi-
bility for conducting the operation,

          were sot  available of tie         of
companies from      sector in die U.S. plas-
tics  industry.   SPI  has approximately 2200
member  companies,  which  are  estimated  to
represent 75% of the total dollar volume of the
plastics industry.    SPI  estimates  that thek
metabership             98%  of the  pellet
producers, but  only 10% of the
of              within   the  industry  (Ms.
          Healey,  SPI,  personal
lion, AprM 1992).    ,

           4.1    ORGANIZATION OF THE
                  PLASTICS INDUSTRY
           For  the purposes of  this study, the plastics
           industry consists of three major sectors:

           Pkstie Pellets in the Aquatic Environment; Sowtees and ReoommcndBlioa*
jffr-
&*

-------
                                     Producer/Extruder
                            I
                      Transporter/
                   Contract Packager
                                            I
                                        Processor
                                                       figure SCa|
                                                       Figure 6Cb}
                                                       Figure 6(c>
la}
   Raltear Cteaning
       II
 Liquid
 Reslh
                                               Molten Resin
                                   Pellet Extusiori/Productton
    Clean
Rali Hopper Care
                  Transporter/PackagerJ^M
    ^——^ Pefiet Movement
    «i i« ii i u Empty Raltear,  Sylk Twdc or
            Waste Paetoflirtfl MovsrrMsrrt
                                                                 not
                                                           thl* study.
                                                                         rrwy be p*Uetii«d
                                                              1
  Ctean
Bulk Trucks
 Trudc
Cleaning
                                                                                UJ
                   Figure 6. Pellet Flow throogh Plastics Industry Sectors.
                                (a)  Pellet Producsrs/Extruders.
                                     Plutic PelleU ifl the Aquatic Envwonment Source* aund Recommendations

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  Cbl
(c)
From Producer/Extruder or Transporter/Packager
SS
«8
Ea.
is

P
CC CL
                       Hopper Cars
                 Pneumatic
                  Transfer -
                                             ±
                    Bags/Gaytords
Bulk Trucks
                          Manual Transfer
I
     Pneumatic
      Transfer
                                                          '4Sfc
a^
-
                                                             Storage Slos,
                       Bterxters
                                           Molding and Product Fabrication
             > Pellet Movement

         itiiiiii Empty Raitear,  Bulk True* or
               Waste Packaging Movement
              Figure 6.  Pellet Flow through Plastics Industry Sectors, (continued)
                     (b)  Pellet Transporters/Packagers, Ccl Pellet Processors.
  Piastre PeUeti in the Aquatic Environment: Sources and RecommeadatioM
                                                                      41

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 4.2
 The pellet producers       the polymers  and
 extrude  the pellets.  The  Envkonmental Pro-
 tection Agency  (EPA) (1990a) -reported  that a
 total  of  477 resin-producing facilities were
 operating in the United States* based- oa U.S.
 Bureau of the Census (1988)  estimates.  Most
 of the 55SOOG workers employs!  by the pro-
 ducers  reside ~ in  T«as,  New Jersey,  West
 Virginia,  Pennsylvania,  Louisiana,   Ohio,
 Michigan, and California.

 A diagram showing the flow of       through
 a pellet producer is presented in Figure 6(a).
4.2.1   Producer Equipment and Operations
Polymerisation

The production of plastic pellets  begins  with
polymerization.   Polymerization is the chemi-
cal reactions) through which low-moleeular-
weigfat  organic  molecules  (mon'oiners)   are
linked to form long monomer chains, or poly-
mers.   Polymers are produced through either
of two methods:  bulk polymerization or solu-
tion/suspension polymerization.

    «   Bulk polymerization  produces  a  hot,
        very  viscous  liquid  called  a melt,
        Mdts  are  pelletized  immediately or
                   to  the  incorporation of
        additives.  Polymers produced through
        bulk polymerization           include
        low-density   polyethylene  (LBPE),
       polystyrene (PS),  polyvinyl  chloride
        (PVC), and polymethyl methacrylate,
    *  Solution/suspension   polymerization
       produces  powders,  not liquids,  after
       the  polymer  Is  separated from-  the
                     carrier solvent  and dried;, drying en-
                     sures minimal carryover of the carrier
                     solvent,  The powders may be subse-
                     quently melted  and formed into
                     pellets  or  end-products.    Polymers
                     produced ifaraugh this process include
                     high-density  polyethylene   (HDPE),
                     polypropylene (PP), PS» and PVC.

             The ultimate use  of polymers  typically in-
             volves one or more       in which the'poly-
             mer is in pellet form.
             Pelletlzers

             High-volume  pelletizing  systems have been
             developed  that can  process  over 5000  Ib  of
                    per hour       kg/h) Punt,  1978),  or
             approximately  110,000,000 pellets per  hour.
             The most common types of pelletizing equip-
             ment include dicers,  strand pelletizers, die-face
             pelletizers, and ceotri&gal pelletizers.

                 *  Wears — Dicers  produce pellets by
                    feeding a  quenched  (cooled) strip  of
                    polymer through  rotating knives that
                    slice          a stationary bed  knife,
                    thereby shearing the strip into  pellets
                    (Mark «/of., 1917).
                 •*  -Strand Pelletizers —. Strand pelletizers •
                    force molten polymer through a row  of
                    orifices (usually  round),  thereby pro-
                    ducing- continuous strands that are 2  to
                    4  mm dia.   The        are quenched
                    in -a water bath and  passed through a
                    multikoife rotor that                a
                    Fixed blade.  The strands are cut into
                    1- to 5-mm  lengths,  depending on the
                    feed  rate  and  rotor  revolutions per
                    minute.  Most resins can be  pelletized
                    by this method,  but very brittle or
                    fragile         must  be  pelletized  by
                    another method (Mark et al.,  1987).
                 *  Die-Face  Pelletizers  —  Die-face  pel-
                                molten resin through a die
                    face,  cut- the resin Into  pellets  as  It
42
Plastic Peieto in the Aquatic Environment: Soureet and Recommendations

-------
               -through the die fece,  and cool
        the hot       by applying either air or
        water.    This           differs  from
        dicers or strand pelletizers that pellet-
        ize already.^o'led  resin strands.  The
        types of die-face pelletizers differ only
        in the        by which the pellets are
        cooled (i.e.,  air, water, or a  combina-
        tion of  air  and  water).   Pellets, are
        removed from the cooling/carrier fluid
        by allowing      to settle or      in a
        tank, depending  on the polymer, and
        air-cooled  pellets  are  transferred  to
        storage silos.   Examples  of die-face
        pdlettzers  include  water ring,  under-
     •   water,  and  rotary  knife pelletizers
        (Marie art, 1987).
     »   Centrifugal Pelletizers — Ceritrtfugal
        pelletizets  feed   molten  resin  into  a
                 drum  that           circum-
        ferential   holes.    Centrifugal  force
        extrudes  the  molten resin through  the
      "  holes and forces the strands away from
        the  drum face,   The extruded polymer
        is then cut by a stationary knife that is
        mounted  away from the       face.
        The  momentum  of fte          pellets
        carries the pellets into a cooling system
        (Markera/.,  1987). •

The type of pelletizer      determines the size
and shape of the pellets produced.  Most mod-
em pelletizers are large, enclosed, fully auto-
mated  systems, where the  pellet flow"is con-
trolled within the peiletizar.
Conveying Systatus

Conveying          are      to move  pellets
        plant operations, such m          the
pelletizers,  drying systems,  and  the  storage
silos, between the storage silos and .the packig-
tag or  shipping  containers, and  between  the
silos or'packaging and molding machines.  Hie
potential for pellet spillage is present  during
each conveyance,  The rate of pellet entry into
the conveying system cannot        the rate of
pellet  delivery  from  the  conveying system,
otherwise       spills will occur. ~

Pellet  conveying systems  can be either pneu-
matic or mechanical.  Pneumatic systems may
me either dilute-phase or             systems.
Dilute-phase systems tre low-pressure
that use high-velocity  air  and a. high'air-to-
pellet ratio  to move 'the- pellets  into receiving
vessels (e.g., storage silos, .rail hopper cars).
A vacuum can also be used to pull the air and
pellets into  the  receiving- vessel.  Dense-phase
systems  are high-pressure, low-velocity sys-
tems wife a low air-to-pellet ratio.   In dense-
phase  systems, the  conveyor  is filled  with
pellets and pressurized; the How of pressurized
air carries,  the  pellets  through the eooveytag
line.

Figure 7 shows i pneumatic conveying system
in  a  pellet-Wending operation  (e.g., where
palletized colorants are mined with pure HOPE
pellets),  Each of these operations also requires
properly sequeneed procedures to avoid spills.
Mechanical  conveyors       are used for  in-
plant  pete  movement    These  conveyors
generally are used to transport pellets
short distances, as well as  in            that
cannot  be  completed by        a  pneumatic
system, (e.g., operations that require a continu-
ously high pdlet-delivery rate).  Most mechan-
ics!  conveyors  me a  rigid  driven        to
move the pellets through a  conduit   Because
the screw      is flexible,       conveyors are
suitable only  where straight conduit runs can
be installed.

Mechanical  conveying         may be     to
transport          from  transporting  vessels
(e.g., rail hopper cars  and bulk trucks)
to storage       or directly to other packaging
or processing operations. Generally,  the trans-
porter empties the pellets-into a       that, in
turn,  feeds  a mechanical  conveyor.   TTiese
mechanical  conveyors  may also 'be      to
Plastic FdUeti in Ihc Aquatic Environment: Soursscs tnd Reconmendt&tionf
                                          43

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t
5'
Sr
t»
o

I

I'
1
f?
e
          «—•» Conveying Une
                   f
          •#*•                     Points
 Rail
Hopper
 Car
           fs________™____.
              Manual Feed
Pressure      (e.g., Gaylords.
Unloader       Bulk Trucks)
                                                                              Manual Feed
                                                                               from Bags
9
IX
                       Figure 7. Example of a Pneumatic Convevlnp System In a Pellet Blending Operation.
                                                 {Adapted from Anon,, 1990}

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 transfer  pellets from bag-  or box-emptying
         to, for example,  a Wending silo or a
 bagging  machine.    In  addition, mechanical
 conveyors may be used also to volumetrieally
 feed pellets to t blending operation.
 43, j,  Site Visit Observations
 Two pellet producers, Company F and Compa-
 ny G, were visited  during this study.   "Both
 companies ware visited on February 5, 1991,
 Company F

 Company F  is a large manufacturer of HDPE
 polymers to  pelietsed form.  Company F also
 produces PE  powders  and  other  nonpellet
 polymer products; most of the powders  are
 subsequently peltetized.

 The  company            several
 during- routine  operations.   In the extruder
 observed* during the visit, PE powder is melt-
 ed, the  liquid polymer  is extruded through a
 die, and the  resulting polymer     is cut into
 pellets.   TT»e  pellets are first water-cooled,
 then air-dried, and are pneumatically conveyed
 to storage-silos.   Pressure sensors throughout
 the pneumatic system monitor the pellet trans-
 fer,  enabling the  operators to detect potential
 blockages aad         prevent spills.  During
 routine operations, pellets may be removed for
 quality control inspection after they have been
 cooled.   In addition*  the                be
 opened  for  maintenance or  corrective action
 (i.e.,  purging during  system shutdowns);  all
              removed   from  the
 during maintenance or  corrective  action are
 placed in  specially labeled  waste bins and
 recycled; ao PE is disposed Into landfills.

 Pellets are stored  in  large  sUos  until trans-
 ferred  into  either  raE  hopper      or bulk
 trucks; over  90%  of the pellets produced by
 Company"P are directly loaded into these bulk-
 transport vessels.   Less than 10% is loaded
 Into gaylords or paper              peDefe are
 primarily for overseas shipment).  Spills in the
 bagging areas are  cleaned up immediately and
 the       .pellets are recycled.

 All rail hopper cars and bulk trucks are'thor-
 oughly cleaned Inside and outside before load-
 ing, and outside      loading.        loading,
 the inside of the  car must be  cleaned to re-
 move  ill residual          and dinging
 as well as other contaraimnts (e.g., dust) that
 may be present.  Pellets are remoYed first by
 auctioning; residual pellets are     wished out
 with water.  The        rinse is performed  to
 an  enclosed       where  residual pdlets are
 washed into the facility drainage and contain-
 ment  system             In         Wow).
 Several  pounds of residwl 'pellets may be
 washed out of a rail hopper car.

 Pdlets are pneumatically transferred into rail
 hopper ears or bulk trucks  through a closed
 loading system where the spteMer is connect-
 ed directly onto the loading spout so that (he
 loading spout  does not  have to be reconnected
 at each loading port.   After loading, tfie out-
 side of each rail hopper car  or bulk       is
 rinsed, and the rinse  water is directed into the
 facility drainage  system.   The pellete are
 shipped       directly  to a processor  or to a
 contract  packager  for repackaging (e.g.,  bulk
 shipments bags or gaylotds).  Hie processor or
 packager        the empty rail        cars or
 bulk frocks to Company F,

 He Company F property  is         so that
 storm-water and wastewtter        from all
 areas of the plant into a facility  containment
        for  reeapturiflf                 md
powders  (Figure I).  Tie containment
consists  of a  series of dams,  skimmers, and
surface       arrayed within a weir that rens
along two      of the -facility grounds.

A major focus of the site visit was to observe
this pellet-recovery         that the company
Plastic Pelsett in the Aquatic Environment; Sources
                                         45

-------
I.
s*
!
      in
       1
Padeie skimmers
remove
       by the
Fixed surface boom                                        Water
                                                        through water-
                                                        quality monitoring

                                     water surface.
                   skimmers.
      and into the
environment.
                                                                                               8
                                                                                                             I
        .X
        1 :         of
        2,4:
        3,5;'Oam
                                       6:  Fixed
                                       7:
                                       S:
                                       S:  Water quality monitoring       and
                       Figure 8.              of the Company F       Containment              View).

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              has been refining for several years,  The first
              stages of the recovery system were installed in
              late 1980.  The  current recovery  system con-
              sists of two fixed skimmers and two  floating
              skimmers within  9 weir.  By the end pf  1991,
              it is expected that additional modifications  to
              the  system  will  more  effectively  control  the
              flow of pellets under the dams.

              The storm water  and wastewater drain  into the
              weir system; PE pellets and powder are. car-
              ried by  the water into  this system.  A  water ,
              spray (Figure 9)  is directed at the Surface  of
              the water to prevent  the pellets from  moving
              back into the storm-water drainage system and
              concentrates  the  pellets  and moves  them  to-
              ward the first fixed skimmer.

             The first fixed  skimmer  is  a motor-driven
             paddle skimmer comprising several rectangular
             paddles and  a drive system that is attached  to
the weir walls. It is designed to operate under
normal  weather and  operating conditions (Fig-
ure  10).   The paddles skim the pellets and
powder from water surface and push them up
a trough to street level.   AS the pellets are
skimmed-.from the  surface,  the water1 passes
under  the  retaining  wall  immediately down-
stream  of  the paddles.   At street level, the
paddles push  the pellets  off the  ead  of the
trough into a containment area. • The contami-
nated (unclean) pellets are collected  from this
containment area and are shipped loose via
truck to a recyclar  or to be sold  as scrap.
According  to  Company F officials,  this first
fixed skimmer generates  a  very large (but
unknown)  volume   of  recyclable  material;
during the  site visit, approximately 100 cubic
feet of waste pellets  was observed ia the con-
tainment     of the first  fixed skimmer  (Fig-
ure II).
&
^
I
I
                Figure 9.  Facility Drainage System Outfall into the Company F Containment System.

            Plastic Pellets in the Aquatic Environment: Sources and Recommendations                                   4?

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                                                                                              I
                                                                              VleW
                 Figure 10. Upstream View of the First Fixed Skimmer In
                          the Company F Containment System.

     Figure 11.  Pellets in the First Fixed Skimmer Containment Area at Company F.


*                                W*«tic Pellets in the Aquatic Environment; Scarce* and

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i.
 During normal conditions, the first fixed skim-
      -Is  nearly  100%  effective in removing
 powders  and pellets.  However,  during-anil
 after periods of heavy precipitation, the fixed-
 sWoMner  system  is" breached by  high  water
 levels, and  the  paddles  become partially  or
 totally submerged and do  not skim the pellets
 from the surface; according to company offi-
 cials,  this was the condition,just prior to and
 during the site  visit.    By  contrast,  during
        of drought or abnormally light precipi-
 tation, the water  level can drop so low that the
 paddles are completely out of the water.   In
 either of these two  situations, the first  fixed-
                  cannot  operate  properly,
 allowing the pellets to bypass the skimmer and
 proceed downstream  to the second  fixed-skim-
 mer

 Hie 'second fixed skimmer is located several
         yards downstream of the first fixed
 skimmer.   The second  fixed  skimmer and  its
 pellet  containment area are configured  identi-
 cally to the first -fixed skimmer and  its contain-
 ment  area,   A  white  mass of accumulated
 pellets, and powders was observed between the
 two fixed skimmers.  The mass resulted from
 either  a  breach  of  the  first fixed-skimmer
 system or entry  into -the weir system  in the
 storm-water runoff from       downstream  of
 the     fixed skimmer,  'The water level had
 not yet receded,  and the  paddles were  com-
 pletely submerged in  the water and1 could not
                  the  surface.   Pellets
 powder were also accumulating on the down-
 stream side of the second feed skimmer and'in
     of a fixed                      down-
 stream of the second  skimmer; this accumula-
 tion was likely me result  of  a breach of the
 second fixed-skimmer system.

 A short  distance downstream of the  surface
 boom are two retention ponds.  The first pond
holds the wptewater before it is  pH-adjusted,
The water  flows from the first pond  through
the pH-idjusting station and  into the
retention  pond.  No pellets could.be       at
the upstream side of the pH-adjusting station.
 In the  second  retention pond, a portable sur--
 face'boom is positioned'in front of waste-water
 culverts that     to the facility outfall.
 and powders collected at  this point are re-
 moved  by      a vacuum (Figure 12)'.  From
 this basin, the' water passes into the eovirQn-
 ment through  the  culverts, through a  water
 quality  monitoring station and the outfall, and,
 through,a small stream into a nearby river.

 Three times each week,  one  24-i  sample  is
 collected  at the outfall water-quality monitor-
 ing station.   Total suspended solids (TSS),
      with "all        National  Pollutant Dis-
 charge  Elimination  System (MPDES) analytes,
 are          for each simple.  Company  F
 'officials       that the water         may not
        pellets,  but it       collect powder.
 Only one pellet could be            the
 of the  stream  immediately below the outfall,
        the heavy rainfall and           large
 numbers of pellets in the weir.

 Despite torrential rainfall  the previous night,
 the Company F  containment  system was ex-
 tremely effective in preventing the discharge of
 pellets.   Company F  developed this relatively
 simple but effective system, in part, to comply
 with' NPDES permit regulations that  limit TSS
 discharges.   Prior to developing this system,
 Company  F exceeded the  NPDES  permitted
 levels for TSS  owing to the presence of  poly-
 mer powder and pellets. However, the compa-
 ny recognizes the -environmental hazards that
 pellets'pose and  is         &             to
 mMmize its contribution to the problem.   The
 company, also recognizes the          advan-
     to recovering and recycling      pellets.

 Company F officials believe that She
 operation of their pellet                   is
 accomplished through a combination of physi-
 cal plant systems and  employee commitment.
As a  result, all new employees  -are trained in
pellet spill prevention  and cleanup.   In  addi-
tion, Company F has       a video of its pellet
containment measures; this video is  required
viewing by all new operators.
           Pkrtfc Peltes in lie Aquatic Environment: Source*
                                                                                          49

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                 Figure 12.  Portable Boom and Manual Pellet Recovery from
                             the Company f Containment System.
 Currently, company officials  estimate that the
 recovery system Is nearly 100% efficient under
 normal operating  conditions,  as  evidenced  by
 the absence of pellets at and beyond the out-
 fall.  However, during periods of heavy ram-
 fill,  the efficiency of  the  system
 allowing plastic powder  and,  to  a  lesser  de-
 pee, pellets .to be discharged into the environ-
 ment.  On the day of the site visit, the heavy
 rainfall had stopped before the visit began, and
 the recovery system  was .returning  to normal
 conditions.  Company F anticipates that future
 system modifications (scheduled to be complet-
 ed 'by  the end of 1991) will  control powder
 and pellet discharges  during  abnormal condi-
 tions (I.e., heavy rainfall).
 Company G

'The second pellet producer visited under this
 study was Company G. Company G manufac-
             tures  approximately 6QQ million powads  of
             pellets  each year,  the  bulk  of which  are
             shipped by raU hopper  car.  Pellet manufactur-
             ing is ooly one of several  operations at tills
             facility.   Pellets are  also  bagged or  boxed
             onsite, and a portion of the pellets we shipped
             by using bulk erucks.

             Drainage  ditches are located along the roads.
             throughout the Company  G facility.  All
             water and wastewater runoff are  directed Into
             the facility drainage system for treatment and
             are discharged  into the  river idjaeent  to the
             property.    Disposable surface booms were
             located  at several junctions in the
             ditch  system.   The  surface booms prevent
             floating material, such  as plastic pellets, from
             backflowing -into' nonpellei-related       of the
             facility,                       5"

             The first area observed was the rail hopper car
             loading area. The rail  hopper car loading area
 50
Plastic Pelfcte in the Aquatic Environment* Sources and Rsoommewiatioog

-------
 is  paved and  has drainage  gutters or troughs
 between • each pair  of rails.   Pellets  spilled
 during loading are washed into the gutters and
 carried  into  the  facility  drainage  system.
 Pellets could  be ,«een   throughout the rail
 hopper car loading area, on  the ground, and in
 the gutters.  Pellets* including those that had
       flattened             raH hopper cars,.
 were also visible throughout fte area.

 At the point where  the gutters discharge into
 the facility drainage system, Company  G had
 installed a  simple containment system.   After
 flowing from  the gutters, the pel!ets are col-
 lected "by  using concrete  barriers that  act  as
 fixed  skimmers in a reservoir          from
 the facility                  (The,      in the
 reservoir is       "than the water in  the drain-
•age system.)   Pellets      fte reservoir from
         the fixed           and float  to  the
 surface of the reservoir.   An  electrically-pow-
 ered  surface  skimmer pumps floating  pellets
 and water  from the surface- of the reservoir
 into a box-shaped basket made of-small-mesh
 (smaller than the  diameter  of  the  pellets).
 screens.  This system continuously skims  the
       and  collects       in  the         bas-
     where  they        until they are removed
by  Company  G  employees.   The
        are          twice      workshift and
pellete are removed.

Water flows through the                  into
the  reservoir .and into the  facility drainage
system under a         fked  skimmer.   The
second fixed           prohibits  the flow  of
pellets into the drainage system,  even during
periods of  heavy precipitation.   (Both  fixed
skimmers extend, well above the normal water
level   in the  reservoir.)    Additional  small,
portable floating skimmers -are  used at strategic
locations to capture any pellets that  enter the
containment system from  other areas of the
facility.

The rail hopper  car  cleaning  area  was also
visited; this area  was located some distance
from the loading facility.  Before loading, the
Interiors of the rail hopper cars are completely
cleaned  to  remove  residual pellets.   These
pellets  are  rinsed onto  the ground  and are
directed by using a  water spray into troughs
alongside the rais.  The troughs transport the
pellet-laden wastewater  to a collection reser-
voir  where  it         through  a small-mesh
screen capturing the pellets.

During the  site  visit,  piles of  pellets  were
visible 'on the ground throughout the rail hop-
per car cleaning area and the  area's contain-
ment system  had  overflowed; in some  areas,
pellets were piled as high as 1  ft.-  The con-
tainment system in the rail hopper car cleaning
area,  configured  similar  to  the system  ID the
rail hopper car loading area,  was  completely
         with pellets, and several  employees
were shoveling the  pellets  Into  barrels for
disposal (the  barrels were 'then  emptied  into
dumpsters),  An employee said that Ms pellet-
overflow condition was  typical  during periods"
of heavy rainfall  and  during unusually busy
periods.  It was  unclear whether the contain-
ment system  at the  rail hopper  car cleaning
area was linked to the facility drainage system.
It was also unclear whether the runoff  in the
raO         car               and
      (where        covered the  ground)
directed into the          system or elsewhere.

Scattered pellets and small patches of accumu-
lated  pellets were observed  on walkways and
in the parking areas  of  the rail hopper car
loading area and the rail  hopper car cleaning
area.   Loose  pellets  frojn the rail hopper car
cleaning      apparently were tracked to
outsidfe toe rail hopper car cleaning area.  The
fate of  these pallets was not identified 'during
this site visit.

Pellets  collected  by _using  the
systems described above are recycled.   Com-
pany  G officials           that between ,25,000
and 60,000 ft of recyclable pellets are recov-
ered  each  month from "the rail  hopper car
cleaning area  alone.   No estimates were avail-
able for the total volume of pellets recycled by
Plastic Pellets in the Aquatic Environment* Sources and Rescoimoetjditioijg
                                          51

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 the facility      month,  to addition, Company
 G                that rail         car
 are  often found'             the        raU
 hopper ear        to the rail hopper car clean-
 Ing      §        of              to the envi-
 ronment.

 No             visible  it the facility
 that discharges into the nearby dyer.  Howev-
 er, the        of the              not  dosely
            owing  to time limltafSons  and re-"
 sumption of rainfall. Considering Ae extreme-
 ly large          of        that were      In
 the rail hopper car cleaning      and the lack
 of visible pellet               at the  outfall,
 the            system at Company G
 to be           in  controlling  the        of
           the

         of the lack of time,  the       powder
                and the
 could not observed during the  site visit.  In
 addition,                       in
 aw! employee            of the environmental
               by plastic  pellets were-not dis-
 cussed       the visit:
 4J J           of Pellet
 Officials §f Company F and Company G
 abfe to provide insight Into several sources of
                                    that  the
             were   attempting   to   control.
 Through die site visit observations, dls«s,siom
 with          officials, and i  review of exist-
 ing literature,                of
               at pellet production facilities.-

    »                        eotiteylng  sys-
              Hie             be        ibr
       routine  maintenance,   repairs,   and
                                   The sp-
                  also                if the
       systems  are operating incorrectly or
                are not completely
               'tenanee  tnd  other           routine
                operations.  •  A  signifietat  source, of
                              is               from
                           to  raft -hopper     ,  and
                bulk tracks, particularly      connect-
                ing and  disconnecting the         and
                the valves on the rail car and trucks.
            » .           or
                bap,  in particular,  are easily  .dam-
                                      to  flow
                from  the  bag.   Also,
                      packaging, such as          bag
                valves,
            »   Mall  hopper   car and  bulk
                cleaning operations,   Waste .pellets
                are       to fall      the         and
                become entrained in wtstewater,  Oace
                on the ground, the pellets may flow
                      with fte            the
                        system,  or the.       may be
                washed  away  by storm-water rundff
               into      outside of the facility.  This
                is                       at
               lacking a containment  system      is
                        to       pellets.
            «  Jack  of  a                 system.
               Uncontrolled  waste-water and storm-
               water  runoff will      to the loss of
                          the environment.
            •  Failure  of  the
               during heavy  rainfall.   Containment
                            not be          to  oper-
               ate correctly during periods of moder-
               ate to heavy rainfall.  Company P was
               in the         of            this  r&-
               lease mechanism.
            •  Infrequent or Inadequate housekeep-
               ing.  Spilled or              that  are
               not quickly recovered  through'
               housekeeping practices may  be lost to
               the environment.   Loose
               be tracked.into every      of a facility
               via forkllfts and employee's      and
               clothing.
52
Pcllett in the Aquatic JBnvuponment: Sources and Recommendations

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                 •   Unsealed  or  unsecured  rail hopper
                     car  valves.   These -valves may  be
                     improperly  or  inadequately  sealed,
                     thereby allowing loss of pellets through
                     seepage through  a small opening or by
                     enabling  vandals to open the valve.
                     Pellets also may spUl from valves and
                     connection hoses that are not complete-
                     ly emptied before a rail hopper car or
                     a bulk truck is moved.
                 *   Lade of employee awareness.   Em-
                     ployees may not be properly educated
                     in regard to  the hazards  posed"  by
                     pellets in the aquatic environment,

              Observations  at  the  two  exemplary facilities
              visited  during this study indicate that effective
              pellet containment measures  can "be developed
              and implemented at pellet production facilities,
              The number  of pellet production facilities in
              the U.S.  that have installed such containment
             .measures is not known.
                                                   break down these bulk shipments into smaller
                                                   containers such as bags and  gaylords.  These
                                                   smaller containers are subsequently carried by
                                                   transporters to other  contract  packagers or
                                                   processors.  In the  following discussion,  the
                                                   term packagers refers to. those facilities that
                                                   only repackage or store pellets  (Le., contract
                                                   packagers),  and  does not  refer to packaging
                                                   operations of pellet producers,

                                                   Each time pellets are moved, whether within a
                                                   facility  or  between  separate   facilities,  the
                                                   potential exists for a pellet spill and subsequent
                                                   release into the environment.   The type of
                                                   packaging may also  affect  the potential  for a
                                                   pellet spill.  Pellet  transport and packaging
                                                   methods  are discussed  to  the  following sec-
                                                   tions.  A  flow diagram  is again presented in
                                                   Figure 6(b).

                                                   The  numbers of transporters  and  contract
                                                   packagers   operating  in the U.S.  are  not
                                                   known.
             43     PELLET TRANSPORTERS/
                     CONTRACT PACKAGERS
                                                   4.3.1   Equipment and Operations
f.
the pellet transporters and  contract packagers
are. the mechanisms  by which  plastic pellets
move from the producer to the processor.  The
pellet transporters carry bulk shipments (ks rail
hopper cars or bulk trucks)  of pellets from the
producer to the contract packagers and proces-
sors,  and  carry repackaged  shipments (in  bags
or gaylords) from the contract packagers to the
processors.  The major methods of transport-
ing pellets  include cargo  and  containerized
ships,  rail hopper  cars,  and bulk  or freight
trucks.   Cargo  ships are being replaced in-
creasingly by  containerised  ships as the  pre-
ferred vessels for overseas pellet shipments.

The contract packagers,'or,  simply, packagers,
receive  from  producers  bulk  shipments  of
pellets in rail hopper cars and bulk  tracks, and
                                                                Equipment and operations at pellet transporters
                                                                and packagers involve moving and repackaging
                                                                large volumes of pellets, such as in rail hopper
                                                                cars, and small  volumes, such .as in bags and
                                                                gaylords. Some producers ship pellets by rail
                                                                hopper car or bulk truck directly to the proces-
                                                                sors that use large volumes of pellets. Howev-
                                                                er,  pellets are often  repackaged into  smaller
                                                                containers for shipment to processors mat use
                                                                small volumes of pellets.
Packaging ,'

Pellet producers may ship pellets either in bulk
shipments,  {i.e.,  rail  hopper  cars  or  bulk
trucks)  or  in  smaller  packages.  Frequently,
bulk shipments are  sent to contract packagers,
where pellets  are packaged into Smaller1 con-
             Pbstic Pellets in the Aquatic Environment; Sources and ReeommendaJioM

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                                    From Producer/Extruder
                       Pallet Movement
                Empty Baiter,  Bulk True* or
                Waste Packaging Movement
             Figure S.  [Repeatedl Pellet Flow through Plastics Industry Sectors.
                              fb| Pellet Transportars/Paekagers,
tainers, such as bags, -gaylords,  or cardboard
drums, for storage  and shipment by  freight
truck.   Hie capacities of bags  and gaylords
(i.e., 50 and 1000 Ib, respectively) are limited,
and  mechanical  conveyors  (i.e.,  forldifts) are
needed at the offloading  point.   The extrq
handling  involved  in filling,  handling,  and
emptying       smaller containers  makes  Ms
method of shipping prone to accidental spills at
the plants and in transit.

Several different types of bags  are  used for
shipping p,el!ets, and each bag type has  advao-
     and disadvantages (Table 9),   The most
commonly used  bag material is paper,  which
has the advantage that it can be broken easily
for quick  emptying by the processor, but has
the disadvantage that it can  be easily broken or
torn  during shipment and  storage.   Bags-are
also  made of PE or waves PP.  Bag  openings
are either  open-moathed or  equipped with a
valve that is incorporated into the bag, Vaived
             bags are filled by placing the valve over filling
             tubes and           the _ pellets  into fee bap
             directly from the storage silos,  a  process that
             is very quick and inexpensive. These bags are
             designed to be self-sealing; once a bag  is filled
             fall, the mass of pellets inside the bag
             the bag valve shut.  The advantage of valved,
             self-sealing      is that filling and sealing are
             completed  at one machine,  eliminating  the
             need for additional equipment to     the bag;
             however,  the  disadvantage to valved  bags is
             that the valves often leak.   Sew-close bags and
             heat-sealed bags require  additional handling
             and equipment to seal the opening.

             Bags  typically  are  stacked  onto  a  wooden
             pallet' covered with a cardboard |ray to  catch
             pellets that leak  from valves  or  punctured
             bigs. When all of Che bags have
             on the pallet, the entire pallet, and the bags are
             wrapped in plastic to  prevent the      from
             shifting  during  shipment  and  to retain any
54
Plastic PeUeti in the Aquatic Environment* Sourcea'and Recommendations

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                              Tabls 9. Comparisons of Most Commonly Used Pellet Bags.
Bag Material
*»
Polypropylene woven
Polypropylene woven
Paper (4-ply paper, l-ply
polyethylene liner)
Polyethylene form-fill and
seal (FF and S)
Opening
Open
mouth
Valve
Valve
Open
mouth
Sealing
Method
'Sewn
Self-sealed
Self-sealed
Heat-sealed
Puncture
• Ranking"
1
1
2
3
' Retention
Ranking
1
2
2
1
Cost per bag
($)
0,2? to 0,32
0.45 to 0.55 '
0.35 'to 0.40
0.25 to 0.30
              "Ability to nrat puocnuing. I; GiMlctt, 3;
              * Ability to retain pellets with minima] leas wktsQ bsg is not broken.  1: Greatest, 2: Lea*!,
              Source; United DC; Mr. Merc Levine (Pwidenl), penona] connniinkujon, 30 July 1991, Houswa, TX.
f.
fr
k .
fe
             pellets that leak from valves or bag punctures.
             The  wrapped  pallets are  moved by using a
             forklift to storage areas or onto freight trucks,

             Cardboard  gaylords  are lined with a  large
             plastic bag to  contain the  pellets.   Gaylords
             usually are set on a wooden pallet to be moved
             via forklift.  The  gaylords  typically are  filled
             by conveyor and sealed.

             Bag« and gaylords are moved to storage  areas
             and  to shipping vehicles (i.e.,  freight trucks)
             by using forWifts  or  other  similar .equipment.
             Depending  on the spfll maintenance protocols-
             at-a facility, punctured bigs or gaylords may
             be repaired or  the pellets may  be repackaged
             into  a new container.  Spilled pellets may be
             recovered  and  recycled,  or unusable pellets
            may  he  disposed into  the municipal  waste
            system.
            Shipping

            For  nearly 20  years,  rail hopper  cars  have
            been available for  bulk pellet transport.  Rail
            hopper  cars  have  a  100-ton capacity,  or ap-
            proximately 4.4 billion pellets per hopper car.
            A rail hopper car can have either a single tank
or be conjpartmented into two or more tanks.
On top  of the cars are ports that couple with a
conveyor system for pellet loading, and on the
bottom  are ports that couple with  conveyors
for rapid flow  of pellets during unloading to
bulk storage facilities.  Each port has a rotat-
able tube valve that controls the pellet flow
rate by  increasing or decreasing the opening of
the discharge slot.  Each top  and bottom port
is equipped  with "a cap that must be secured
ewer the port whenever the rail hopper car Is
not being loaded or unloaded.  If these caps
are not  secured or if there is vandalism of the
caps, spillage can result  (Figure 13).

There are two kinds of truck! used to transport
pellets;   bulk trucks and freight trucks. Bulk
trucks" are used to tensport large volumes of
pellets where rail service is unavailable.  The
design and  operating features  of bulk trucks
are sinular to .those of rail hopper cars, and all
are  loaded  and  unloaded  similarly.   -Bulk
trucks have a 50-ton -capacity or approximately
2 billion pel!ets (22,000 pellets per pound) per
truck.

Freight  trucks  and  cargo/containerized ships
transport  bag-  and  gaylord-packaged  pellets.
Pellets may also be transported aboard ship in
            Plastic Pellets in (-he Aquatic Environment: Sources and Reeamineadatiotig
                                           55
£

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LA
0%
8
J7



I
                         Figure 13. Pellet SpiU Caused by Vandalism to Rail Hoppe? Car Valves.

                       (Photograph by John H. Williams, The Morning Advocate, Baton Rouge, LA)

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 bulk shipments.   Prate  (1987)  has reported
 that pellets have been -used as ball bearings on
 the declcs of ships to      the movement  of
 cargo,  and  pellets would  likely  enter  water-
 ways as a result of this practice.          they
 completely enclose bulk and            pellet
 shipments, contain       spills,  and  prevent'
 leakage to the environment, sea containers are
 increasingly becoming the preferred method  of
 shipping pellets.

 The costs of shipping-by ocean-going vessels
 are relatively low as compared to air freight
 costs,  thereby   making  the  former  method
 attractive for shipping pellets overseas.   Ac-
 cording to EPA  (1990a),  the world fleet  of
 containerized ships had grown from SOS fiilly
 containerized      and 597 partially container-
 ized ships IE 1976 (<5% of the  world fleet),
 to  1097 and-1720 ships,  respectively, in 1988
 (12% of the world fleet).  Therefore, with the
 use of containerized  ships increasing, pellets
 are more  likely  to  be  transported  by "using
 these vessels than by using cargo ships  filled
 with bulk shipments of pellets.
          is the mktag of polymer- pellets  (or
powders)  with  additives  by  using  either a
continuous-blending process  or  blending  in
batches.   Continuous-blending processes  re-
quire  the coordinated, steady  input, of each
ingredient into the 'blender,  The pellet feed
             be. either voluinetrieally or gravi-
                   from a            .   Con-
                               the        by
free Ml into a         unit.

Storage      are used primarily by the  large,
high-volume producers, packagers, or proces-
sors.   Pellets are conveyed from the silos to
          or processing areas through perma-
    instrument-monitored conveying lines.

Warehouses are  used typically by  the  low-
volume processors to store smaller containers;
 Packages are mechanically            (a
      on a forklift) to the molding area,
 deliveries may be in bags or cardboard
 anchored  on § pallet, in large'boxes,  or  to
 large bulk bags.  These units are likely to be
 offloaded  from  trucks and handled  with  a
 feridift.
 433,  Site Visit Observations
 Two  pellet  transporters/contract  packagers,.
 Company  B  and  Company  C,  were visited
 during this study.  Both companies were visit-
 ed on February 4, 1,991.
 Company B

 Company B ships and packages many different
 commodity,   transitional,   and   engineering
 resins in pelletized form.   Photographs were
 not permitted to be taken during this'Site visit

 Company B  receives on the average approxi-
 mately 300  rail              (or 54 mUJiott
 pounds) of pellets annually.  Officials
 that  approximately  99.75%  .of  the  pellets
 (I79,500,lb out of each 180,000-lb  shipment)
'received by  Company  *B  are repackaged and
 shipped  to.processors,  and 0,25% of the pel-
 lets are lost  or recycled.   The  facility has
 500,000 ft3 of available 'storage space.

 Plastic        are                raM
 cars in a         area         to the rear of
 the  facility.   He         are            by
'pneumatic conveyor directly from  the  ral
 hopper      to  the packaging aren.  Before
 offloading the pellets,  a  portable-  screen Is
 placed  beneath  the valve outlet  of die .rail
 hopper 'car.   This screen' is  used to  capture
 pellets that       during coupling tad uncou-
 pling  of the  rail          ear's  valve;
 pellets fall       the  valve and      the
 veyer         hose.   The                of
Plastic PeOcU in the Aquatic Environment:  Source* and ReconnneadaikHii
                                          57

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 wlndowsereen-sized      mounted on a 1-  x
 3-ft  rectangular frame  made  of 2-  x  4~m,
 lumber.  The screen can easily be handled and
 moved by one person.  Pellets captured by the
        ire temporarily' placed  in  a specially
            bin and are eventually sent -to  a
 reeyder.

 Despite the use of the screened       a large
 number of toose       were      along the
 siding  {a short track  connecting a  railroad
 directly with  the premises of a  business con-
 cern) where the rail fadpper cars  are unloaded;
 the  presence  of        pellets        indicate
 Imptopar use  of the          boxes.   These
 pellets  had become'interspersed with the large
 stones that formed the bed of the siding.  Only
      pellet spills had been         up In  this
 area;                  not recovered.  Drain-
 age  routes for the rail hopper car siding
 were not observed and, therefore,  the release
 of pellets ftom this area could not Be assessed.

 Two            operations        observed  at
 Company  B._   The      packaging operation
 was the filling of  valved paper  bags.   Paper
 bags are manually placed over a  spout and the
 pellets  are pneumatically transferred into the
 bap.   After  fill tog,       of •• the       pass
 through a 
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»K

 Company B        that  they  occasionally  re-
 ceive information       processors  regarding
 package         sad pellet loss during transit.
 Most of the Information relates to  exported
 shipments,  and  less information is received in
 regard to domestic shipments.  Approximately
 99% of all  international shipments are In paper
 valve bags, which are inspected for damage by
 independent  inspectors  during  cargo vessel
 onloading.    In  some  cases, the  inspectors
 photograph  damaged  shipments   and notify
 Company B of pellet loss.  Company B is not
 notified of pellet spillage or loss  during 'Off-
 loading at the receiving port.   However, most
 large shipments  are         fa  containerized
 cargo vessels  where  pellet  spillage during
 shipment  would be-minimal,

 Pellets that  escape  onto  the parking lot  and
 Into  the  storm-water drain- are removed  by
        set  of  -screens,. one        and  one
 fine,  installed just  inside  the storm  drains.
 The  fine  screen  is  the       as that in  the
 screens used under the loading docks and  tail
 hopper car outlets.  A small number  of pellets
 were      on the screens  over  the  observed
 storm drains,   Otter  storm drains were  sub-
 merged owing to  the heavy ralas and flooding
 and,  consequently,  only  a few drains were
      during the  visit.   'The  frequency with
 which these storm-drain  screens were
 was not noted during the visit.

 Throughout the visit, employees were observed
 swelling  and collecting        pellets, particu-
 larly in the packaging area.   In Addition to
 hand-sweeping,   large   street-type  cleaners
 routinely  sweep  the aisles'and, receiving, areas.
 To monitor the             of routine malnte-
       procedures  at the  facility, Company B
 de¥doped in environmental inspection check
 list (Figure  14).  The  frequency of'  these in-
 spections was not noted during the site visit.

 Company  B officials estimated  that the annual
pellet         is 10,000  to        Ib during
packaging and 2000  to  10,000  Ib during ship-
ping  and  warehousing.   Spilled  pellets  are
                                                                collected  in  specially  labeled  containers  and
                                                                are recycled. Company B officials      aware
                                                                of the SPI efforts to educate 'the industry
                                                                the problems  associated with pellet releases,
                                                                and recommended that the SPI information be
                                                                made available in bilingual form.

                                                                The  company's  quality          office is in
                                                                the process of developing  written protocols for
                                                                routine  maintenance and  spill  cleanup; these
                                                                protocols will be written in English and Span-
                                                                ish.  Dufiig training, the          plans to
                                                                discuss  economic  and environmental reasons
                                                                for strict  adherence to quality  confrol  and
                                                                maintenance protocols.
Company C

Company C  receives and          balk ship-
       of many different pellet types.    A few
photographs token during the visit are present-
ed below.

Company C Is located in one section of a large
industrial park      includes at      one other
pellet  packager/transporter.    The  company
receives  and  packages bulk shipments of many
different pellet types.    Company C  officials
      that It          and ships approjumatdy
65  million         of  pellets ,per month,', and
between  a minimum of 5000 to 10,000  Ib and
a maximum of 20,000 Ib of spMled 'pellets are
recycled  each  month.    The  company also
         plastic powders .that  are shipped in
supersacks (S x -4 x 4 ft),

Company C receives bulk shipments of  pellets
in rail hopper      that'offload  at a railroad
sldtog behind the facility. TUs railroad  siding
is paved with large       and t stem-water
ditch and dram  are       alongside fhe'sidtag
area.  Pellets  are transferred pneumatically
from the rail hopper       into         silos
located in the packaging      of the facility.
The rafl  hopper car valves are not
after the care  are emptied.   No screens  or
other containment  apparatuses are      during
     Pelted in the Aquatic Environment: Source* and ftaconuneadktioni
                                                                                                        59
P
 I

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ENVIRONMENTAL  INSPECTION CHECKLIST
Inspected by: 	  -   .
Date: '   '     	
Time:  ..      	-i—
                                                                YES   NO
 (1) Are  all  catch troys .properly placed under each shipping boy?    [_J   j|
     !f no:   How many were Improperly placed? _	
            How many were missing? —	

 (2) Are  bins preparSy placed  under hopper cars being unloaded?     [__]   L_]
     If no:   How many ware Improperly placed? _	
            How mqny were missing?	

 (3) Are  the screens over the drains  clear of sxeess debris which    Q]   Q
     could Inhibit water How?

 (4) Is the roof clear of product?                             •     CH   CH
     If not   Estimate' amount of product on roof.	 Iba.
 (5) Are trackt free of pelfets and/or powder?
    tf no:   Identify location of any problem(8).
a   a
 (@) Ar® fences and drainage ditches free of plastic?                [~]
    If not  Identify location of any probiem(s).  •
 (7) IB there any evidence of piastlc being dumped into trash        ["]   C~~j
    compactor?

 (8) Is ail transfer equipment capable of keeping product frem       [  J
    ^jfl ling/being rafeased Into the environment?
    If no:  Identify equipment which requires attention.
(9) Are log books being maintained  at each production Ihne wfth
    Information about spllle, actions taken, recommendations,, etc.?
(10) Were any other potential problem areas fdentiffed during       r~j   r~J
     Mie Inspection?
     \f yet: List specific problem areas.

       Commenta
         Figure 14.  Company B Environmental Inspection Checklist.



                            Plastic Pelkti in the Aquatic Environment: Soyrees and Recommendation*

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               Figure 15,  Storm-Water       In                at Company C,
the coupling and uncoupling of the pneumatic
        Although company officials       that
         are      to
in Ae siding      many
         the       throughout the siding" area
and  in  the stonn-waier ditch (Figure  15).
Pellets are        by storm' water  through the
      and into § storm-water
       storm water torn Compsny C as well
as from several  other           in the  Indus-
trial park,

       are                             from
the         to   the            or   packaging-
machines.  At the bagging machine, the
bag valve Is manually           a spout, and
the       are blown into the       The bag
valve            the big is               .the
      and         J conveyor, and the
inside the bag press against the valve  end and
seal the

The            are         by          belt
onto  a  wooden pallet          with  a card-
board tray,   The                is       to
               that            from
valves or bag punctures.  Company C officials
       that the cardboard trap on pallets are
only             but  not  entirely,  effective,.
Once the pallet is loaded with       the
is wrapped with plastic and        via forklifi,
to i

                  on the               the
tagging         (Figure  16),  Residual
also were      to be spilling from the spout
before and      a bag was secured.  After the
      bag was        on  the
          to be
       valves.  Similar, but not as       were
              of pellets  found beneaA other
      of the         and tie conveyer.  No
             were          la tills

After packaging,      of       are      by
using a forkJtft into the warehouse where they
are                                  pellets,'
      spills, and                       and
                                  He "ware-
       Several spills were the result of
valves.  Spills md/or                  to be
a common  occurrence Arougfaout the  .ware-
     Pelett in the Aquatic Environment:  Seuree* tad
                                        61

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            Figure 16, Loose Pellets beneath a lagging Machine at Company C.
                  Figure 17.  Pellets Spilled at a  Company G Loading Dock.
house and' loose pellets were obvious in every
aisle. Spills in storage       ace swept up and
disposed in reeycliog bins.
             Palleted  bags of  pellets  are transferred via
             forklifts onto truck trailers at the loading dock.
             Pellets in torn or broken      are
             at the  dock before they are loaded on to the
             truck.   Large  numbers  of pellets were ob-
62
Plastic PcOds in the AqirtSie Environment: Source* and Recominendttiatts

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 served In the loading dock      (Figure 17),
          no pellet  containment-         were
 installed at       tihe loading docks or over the
 parking lot storm -drains, pellets spilled at or
 near the  doda can.&ll onto the outside pave-
 ment.  These       would .be carried by storm
       to                            feet away
 •in the        of the parking lot (Figure 18).

 He stonn drains in  the railroad -siding
 and. In the facility parking lot  empty  into a
 storm-water interceptor adjacent to the indus-
' trial park where  Company C is located (Fig-
      19 and  20);   Because several  inches of
 rain had  fallen (and continued to Ml)  on the
 day  of the visit, the  storm-water interceptor
 contained  a very  large number- of pellets.  In
 some areas of the storm-water interceptor, the
 Figure 18.  Pellets in Storm Water outside
        a Company C Loading Dock.
 pellets formed a       across  fce surface and
 were               the
 the       (Figures 21 and 22),          Com-
 pany C is not the only pellet-handling facility
 in the industrial jpark, it is highly unlikely that
 all of the pellets in  the                  from
 Company  C.   Once to  the  interceptor, the
 pellets would Be  transported downstream and
 Into nearby waterways.

 Broom-sweeping was  observed throughout the
 facility.   Company  C officials stated that the
 entire facility is broom-swept and vacuumed at
 least once daily, and  broom-swept throughout
 the day as needed,.  During training,
 are  instructed  to  clean -up all  spills within a
 few  hours; on a typical  workday, this would
 involve broom-sweeping recyclable pellets two
 or three times.  The parking  lot and loading
 dock      are swept once  weddy and large
 spills are           yp as        as
 Pellets,  collected  during  routine maintenance
.and  spill 'cleanups  are recycled.

 During, the                    the site visit,
 Company C  officials                • pellet-
 release points,  These      were (I) the rail
 hopper- cars,  particularly when  a load  of pellets
 is quality*controL- Inspected  .before -offloading
 '(valves are        briefly to collect a subsam-
 ple  of.'the load);..-(2) the             in Ae
 siding                           are
 into' the municipal drainage system; and (3) the
.loading1 docks, .where pellets are washed  into
 the parking lot      drains1.

 Company'C .officials believed that more pellets
 are los't-from bag'         than from acciden-
 tal spills  or  leaking -bag valves,          all
bag  valves tend to leak regardless of the bag
 material.   Other  than  general housekeeping
 (e.g.,  sweeping),  no special  measures  have
 been instituted at Company  C to  mMmize
pellet release into  the environment However,
 Company C   is installing pellet containment
 systems at a new facility.
Plastic Pellets in the Aquatic Environment:  Sources and Recommendations
                                         63

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                   Figure 1 §.  Storm-Water Interceptor near Company C.
                Figure 20.  Pellet Accumulation (and Other Aquatic DebHs)
                        in Storm-Water Interceptor near Company C.
Company C  officials  felt that their employees
are not well-informed In regard to environmen-
tal concerns  associated  with plastic  pellets,
although the SPI literature has been discussed
at monthly  Company C  meetings.   The offi-
             cials  recognized that employee  awareness of
             the environmental impact of pellets is directly
             related  to the investment  that management is
             willing to make in employee education. •
64
Plastic Pellets in the Aquatic Environment: Sources and Recommendations

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 I
 '
 K

 i-

                   FSgure 21. Pellet Accumu!ation in Storm-Water Interceptor near Company C.
              Figure 22. Pellets along High-Water Line in Storm-Water Interceptor near Company C.
I
           Pkstic P«sU,et« in the Aqwiic Environmeitt; Sourrass &nd'Recomm«idAion«
65

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43 3          of Pellet          from
       Transporters/Contract
Through the site visit observations, 'discussions
with industry officials, and a        of
tag literature, several sources of pellet release
were identified at pellet
These

    *   Incompletely              or leaking
       bag Calves.  Valved      do ~not seal
       as well  as     that are      or  heat-
       sealed.  Pellets          leaking from
       valves at the                  and In
       the        areas,
    *   Improper   bag  storage   practices.
              of       may be          too
       high,                             on
       and rupture of lower bags.  Also, the
       exterior plastic          of pallets is
       only                     and Is  inef-
       fective once the pallet  is broteu  open
       or the      .have shifted.  Pallets may
       be         a           tray,
       allowing loose pellets  to fall  to the
       ground.
    *   Lack of employee               Offi-
       cials at  both facilities        that the
       SPI educational materials  had  been
              but  that
       generally unaware of the environmen-
       tal hazards posed by pellets.
•   «              training of forklift
       tors.  The       of packaging damage
       dial was most frequently cited  by the
                 was           " bf - forklift
       tines.
   •   Infrequent   routine    maintenance.
       Pellet                  Aroughout the
                 facilities.  Typically,  only
       broom sweeping "was used to recover
       pellets, and vacuuming          infre-
       quently.
 one     to        by elotbiag, shoes,
 forMifts, and      vehicles,
^ Improperly or inadequately       or
          mil   hopper  car  mires.
 Spills occur when the hopper      Is
        to  the  open, position  before
 coupling  to "the
 Also,  port       are  frequently not
 closed or        after the car is emp-
 tied,         allowing
 to               the  rtl  right-of-way.
 Finally,              rail          car
 ports (top and bottom)     be, opened
 by          "allowing        to
     the ground.
Lack  of a                       or
                            Transfer
 of  pellets  from  rail  hopper      to
inside areas.  If there a  no screening
 in       over              at
                 lots,  etc.,  or  the'
         ace  not          'routinely,
        ire  carried  by   storm-water
runoff into the
or     natural drainage areas.  Recent
revisions  to  the           Pollutant
Discharge  Elimination   System
(NPDES)                 prohibit the
       of         in  storao-watet run-
off.
Improper handing of      cargo it
           and         ship.  Spilled
           be       into the
       of'being           from
and ship decks,
Gterfllllng  of                  If the
delivery rate of the  conveying
        the rate at which, the reeefrfa-
eie can receive the              will
result.
Displacement of the conveyor system
ports.    Incomplete              be-
      conveying         and shipping
vehicles are known to result in pellet
spills. ,
                                     Flutio Pelleti in the Aquatic Environment:  Source* and Reeommeixlfttioni

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 Observations  at the two companies  Indicate
 that inexpensive conteoJ measures  can be de-
 veloped and  quickly  implemented at  pellet
 transporter/contract packagers.
 4.4
                             The terms converter and processor are      in
                             this Section to refer to the production of plas-
                             tic goods  from pellets  and granules.   After
                             conversion of the polymer pellets to commer-
                             cial and Industrial products, the potential for
                             spills and entry into the environment Is elimi-
                             nated.   However, ancillary handling  of the
                             pellets Is required prior to molding.
 Pellet processors mold the pellets into fabricat-
 ed user products.   More than 12,000  pellet
 processors were operating In the United  States
 in 1988, and employed a work force of ap-
 proximately   580,000   workers  Nationwide
 (U.S. Bureau of  the  Census,  19S8;  EPA,
 1990s).  According to-SPI, this accounting is
 dependent  upon  the definition of  processor
 used daring  the  census (Mr, Ronald  Bruner„
 SPI, personal communication, January 1992).
                             4.4,1   Equipment and Operations
                             At the processors [Figure 6(c)J, pellets are fed
                             into molding or conversion         where the
                             pellets are melted and formed into user prod-
                             ucts.   Manual  addition of pellets  to a feed
                             hopper on a  molding unit frequently is per-
                             formed at small conversion operations.   How-
                             ever, as the .size of the converter output (and

to, s
3 i. »
|j> O «•
? 15 •
*5 3 ™
11="
S.&.
   Package
   Dispo'sai
                    From Producer/Extruder or Transporter/Packager     |
                  Rait Hopper Cars
                Pneumatic
                 Transfer
                  Bags/Qaylords
                    Storage Sitos
Bulk Trucks
                         Manual Transfer
                  Bag Processing
                   Operations
     Pneumatic
      Transfer
      Silos
Blenders
                                                     Product Fabrication
              Pellet Movement
              Empty Raltcar, BulkTaickor
              Waste PaiAaging Movement
             Figure 6-.  [Repeated] Pellet Flow through Plastics Industry Sectors.
                                     fcl Pelfet Processors.
Plastic Peflets in the Aquatic Environment: Soarces and Recotnroeatktion*

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the         of pellets mod)           the use
of automated                      increases.

Pellets ate manually,  mechanically, or pneu-
matically conveyed from storage silos or bags
and  ftylords  Into the blender/converter, hop-
per.   Manual loading of pellets may be into a
bag,  drum, or box hopper,  from  which1 the
pellets  are -mechanically  or   pneumatically
conveyed  to  the next operation to the feed
sequence (I.e.,, screening, blending, or drying),

Pellet spills may occur during any of the man-
ual and  mechanical transfers to downstream
equipment - Spills are     likely la a pneumat-
ic'system       the              is
and the fill/flow      are monitored and con-
trolled.  After the feed has entered a hopper on
the conversion unit, there is little potential for
a  spill  during         operation.   There  is
      possibility for a spill, however, when fee
product produced in the  conversion  unit  is
        and the hopper is emptied manually.

Two  primary  processes  are  performed by
conversion equipment   The initial process  is
to fuse  and consolidate1 the  feed pellets.  Ine
second process is to shape and cool the prod-
uct.  These       functions are performed by
several  different types  of equipment, and the
pellet-use  rate may be controlled or demand-
based.   Most of the  conversion  equipment
utilizes pellets fed from i hopper.
                                                                                                       •.
              Figure 23.  Primary Bulk-Storage Hoppers (Silos) at Company A.
                                     Pkst» PtBeti in the Aquitic Environment;  Source* and ReeontmenctttloB*

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 4.4.2   Site Visit Observations
 Three pellet processors, Company A, Compa-
 ny D,  and Company  E, were visited  during
 this study.  Company A' was visited on August
 22, 1990, and Company D and Company E
 were visited on February 4,  1991.
 Company'A

 For several years,  Company A has produced
 food-grade  plastic   containers  made   from
 HDPE, LDPE, PP, and PS pellets, and pellets
 containing pigmentation  [e.g.,  titanium oxide
 (TiOj)].   Company, A  granted permission to-
 photograph all phases and areas of their facili-
 ty.
 At  Company  A,  bulk pellet  shipments  are
 pneumatically transferred from  bulk trucks to.
 the  facility's primary storage hoppers  or silos
 (Figure 23). Each hopper holds approximately
 60,000 Ib of plastic pellets • or granules. Com-
 pany A officials  stated that the pellets: com-
 monly  escape    into the. environment during
 connection and disconnection at the pneumatic
 transfer  tube  (Figure  24),  and  pellets  also
 occasionally-        from the hopper air vent
 when the hopper  h  accidentally overfilled.
 Pellets were seen, beneath and in the vicinity of
 the hoppers (Figure 25).

 The pellets are then pneumatically- transferred
, through the conveying system ,ftom the storage
 hoppers into, a. small room adjacent to .the pro-
 cessing room.   Connections.-to  the" various
 internal operations, - including internal  -storage
 hoppers,  are manually made  in- this", small
 room.  At the internal storage hoppers, pellets
          Figure '24.  A Pneumatic Transfer Tube Used To Transfer Plastic Pellets
                 from Bulk Trucks to Bulk-Storage Hoppers at Company A.
Plastic Pellets in the Aquatki Enwonmept: Sources and Recommendations

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                       Figure 25.  Pellets on the- Ground In the Area of
                           the Bulk-Storage Hoppers at Company A.
are removed manually through a slide valve on
the bottom  of the hoppers.  Company  A offi-
cials  noted  that pellet spillage has been ob-
served, during connection changes, and pellets
were seen .on the floor and accumulated in the
fence  _guard -surrounding the  Interior
hoppers (Figure 26),

Pellets  are  added  to  the  molding machines
either manually, pneumatically, or by a combi-
nation of      methods.  'Company A officials
stated that  there is little  likelihood  of pellet
leakage in the pneumatic delivery system once
the pellets are inside the plant, except in the
      of equipment malfunctions.  Plastic scrap
produced  (luring the injection molding  process
was  observed on -top of several molding ma-
chines  (Figures  27),  and  pellets also  were
observed  on top of one manually loaded ma-
chine.
             Accumulations of  pellets were observed  in
             several expansion joints in the concrete floor
             of the shipping .area and  in other areas of the
             plant (Figure 28).   Pellets also  were-      in
             the expansion joints in the printing shop, even
             though ao  pellets  are  handled  in  this area,
             Company  A  officials  explained that  pellets
             cling to forUIft  tires,  workers* clothing and
             shoes, etc., and are transported throughout  all
             interior and exterior      of the facility.  The
             pellets are then swept up during routine main-
             tenance and are 'disposed of in the facility's
             dumpster.

             Because the facility parking lot slopes toward
             the building, water historically leaked into the
             shipping area during rainfall.   To correct this
             problem,, a  catchment basin was installed  near-
             the overhead  exterior doors  of the shipping
             area to intercept the storm-water runoff from
             the parking lot before  it can  flow into  the,
             facility (Figure 29).   The  catchment
70
Pkstic Pellets in the Aquatic Environment;  Sourea and RecoijunendatioMi

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                Figure 26.  Peltate Caught Jn Fence Guard and on the Floor
                   Beneath the Internal Storage Hoppers at Company A.
       Figure 27.  Plastic Pellets and Scrap on Top of an Injection Molding Machine
                                    at Company A.

Plastic PdLkts in the Aquatic Environment:  Sources and RecommendaJionj
71

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   Figure 28, Pellets Accumulated In an Expansion. Joint In the Company A Printing Shop.
72
Figure 29.  Pellets Accumulated In the Catchment Basin
      yndar the Overhead Doors at Company A.

                 Plastic PeUeti in the Aquitk Environment; Sources and Reeommendttiaiw

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                  Figure 30,  Company A Driveway Where All Storm Water
                            .   Is Transported to the City Street.
 serve as collection points for pellets released in
 the transfer area and in  other exterior areas of
 the facility.  During the  site visit, a number of
 pellets were found In this catchment basin,  A1S
 runoff from the facility,  including runoff from
 the parking  lot, catchment basins,  and roofj
 flows down  the driveway and into the street
 (Figure  30).   Once  in  the  street, the runoff
 flows along the curb to a storm-water intercep-
 tor,  where  it enters  a municipal storm-sewer
 system.

 Until recently,  Company  A  officials  were
 unaware of the hazard's to aquatic life posed by
 plastic pellets  floating on the surface of the
 ocean,  and  to their knowledge,  employees
 were not aware of the hazards.  These officials
 believed  that  employees would  be generally
 apathetic toward the  pellet issue.  However,
 Company A officials also believed  that  the
pellets used  at their ftcility would not float in
water.    They  tested  this  theory by placing
handfuls of LDPE, HDPE, PS, and polyethyl-
ene-base TiO2 pellets  into a small container of
tap water.  Only the LDPE and HDPE pellets
floated, the PS pellets floated initially and sank
after gentle agitation,  and the TiOa pell* sank
immediately.   Similar results were found sub-
sequently when the  same  pellet  types were
added to saline water  (at room temperature and
30-32 ppt salinity).

Because food-grade containers are produced at
Company A,  the, cleanliness  of the physical
plant is closely monitored.  Company  A offi-
cials frequently stated that the facility is rou-
tinely swept clean of pellets,  both inside and
outside, and that the pellets are discarded into
an onsite dumpster.  The  dumpster contents
are collected  by  a commercial waste  hauler
and is,swbsequendy disposed into the municipal
waste stream.
Pkstie Pclkts in the Aquatic Environment: Sources sad Recommendation.*
                                         73

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 Company D

 For over 50 years, Company D  has produced
 specially 'molded products for a diverse clien-
 tele.   Most of the pellets used by Company D
 are engineering (or performance)  resins that
 have  a  limited  range of uses  and narrowly
 defined  applications; these pellets are the most
 expensive  pellets available.   Company D pro-
 duction  runs are  limited  in size and  small
 volumes or" any one particular pellet type are
 used.    The  company has   the  capability  to
 extrude  small amounts  of  special blends  of
 pellets.  As much as possible, the company,
 •purchases  precoiored pellets, but  may  color
 pellets as needed.

 The company purchases pellets in small .quanti-
 ties.  . These pellets typically are  shipped by
 truck in bags or gaylords and are subsequently
 stored in the receiving area until used.  The
 tracks are offloaded at the  loading docks; no
 materials  are   handled  outside  the  loading
 docks.  A storm-water drain was located next
 to,  me building and  at  the bottom  of dock
 incline; a few pellets were seen near the drain
 and along the dock wall.   No pellet-containr
 ment devices were seen  in  die loading dock
 area.

 Company D  had recently expanded their ship-
 ping  and  receiving 'area to accommodate a
 growth in  business.  Pallets  of        pellets
 and gaylords were stored  in one area, and
 packaged products were stored in another, area,
 Loose pellets could be seen beneath the pallets
 and, occasionally, scattered on the floor.

 In general, pellets are manually-loaded into the
 molding equipment, but Company  D can load
 the pellets directly from gaylords,  if necessary.
Employees  are  encouraged   to  avoid  spills,
 primarily because the pellets  are expensive and
 spilled  pellets  are  not recycled.    Scattered
 pellets were observed on the floor beneath and
 around the molding equipment.
              A  few pellets  were  present, in the cooling-
              water tanks adjacent to the molding  machines;
              molded- parts are placed in these      to be
              cooled before inspection and- packaging.   The
              cooling, water  is disposed of into me facility
              drains, which in tiirn feed into the  municipal
              sewer system.   Officials  stated  mat pellets
              could enter  this cooling  water only through
              accidental  spills during  manual machine load-
              ing.   .

              Maintenance protocols require that  the work
              areas, including the areas around fee molding
              machines,  be cleaned,  at the end of each shift.
              The floors are swept, vacuumed, and mopped
              every other day.  Spilled pellets typically are
              broom-swept and  disposed into a refuse con-
              tainer.  No effort is made to recycle or reclaim
              materials,  and waste  pellets are disposed of
              into  the  municipal waste stream.   Routine
              maintenance  and spill-cleanup protocols,appear
              to  be the  primary  methods  for controlling
              pellet releases into the environment

              Company D  officials stated that the employees
              are  trained to  minimize spills primarily  for
              economic reasons (the pellets  are expensive) as
              opposed to environmental reasons.   The offi-
              cials were aware of the SPI educational efforts,
              but  the information was not disseminated or
              otherwise posted in the facility for the workers
              to read.   Workers had  not been briefed or
              otherwise trained with regard to pellet-related
              environmental concerns.
             Company E

             Company E is an injection molder that manu-
             factures  specialty parts for industrial applica-
             tions;  no consumer  items  are manufactured.
             These specialty parts'are made of engineering
             resins, such as polycarbonate and nylon.  The
             company has resin-handling approval from the
             Underwriters Laboratories (UL); this approval
             is used as a measure o£'quality assurance and
             is issued  after successful spot inspections  by
             UL.
74
Piastb Pellcti in the Aquatic Environment; Sources-and Recommendations

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 Company E receives- pellets by track, and the
 pellets typically are packaged In either pappr
      or gaylords.   Company E officials
 that pellet           often arrives punctured or
 torn; the receiving "clerk  records the condition
 of  the pellets,, and  Company E may ask for
 compensation  from the shipper or  packager  If
 the damages are extensive.   Scattered pellets
 were observed to and around the        docks
 and in the facility parking lot.  'A storm
 was located at the bottom of the inclined drive-
 way at the docks.   Because rainfall was heavy
 during the visit, there was a heavy  flow  of
 water through the drain and into a storm-water
 ditch i few feet from  the warehouse.   Pellets
 could be      In AIs storm-water ditch.

 Small quantities of a wide variety of pellets are
       at the facility;  however,       are no
             at tihe facility. All pellet packag-
 es • are stored above floor level;  the
 are stacked "both manually  and via  fbrjdift,
 depending on the size of 'the shipment and the
 storage location.   Loose pellets  were
 throughout the  storage or warehousing       "
 primarily'  in         where routine sweepiig
 would not  reach them.   Specifically,  pellets
 were-       under  loaded pallets  and pallet
 racks, between  storage "racks, awl  between
 stacks.of bags.  Very few pellets were-seen to
"the  working areas  of the  warehouse,  and an
 employee was       broom-sweeping a small
 pellet spill,

The injection  molding            are
manually, tad                of        were
found  around" and  underneath the maiden.
Company  E officials         that  all  spiled
        is           of in a dumpster and is
not  recycled because spilled  pellets  may be
contaminated with  a mixture of grease,  oil,
absorbent materials, dust* etc., as well as oilier
pdletized resias.  The equipment k completely
        and vacuumed                produc-
tion run to
        products.
 The  facility  generally was dean, and  there
 were no accumulated  plastic-scrap piles.   A
 few pellets      visible in cracks in the con-
 crete floor and  in areas inaccessible to routine
 maintenance equipment.  Company E-officials
 believe  that good  housekeeping practices are
 the best way- to  control pellet loss.

 No                              -as
 over         or            devices       toe
 loading docks, are to place at. the facility. Tie
 company         to  follow  effective
 maintenance protocols, as evidenced  by" the
 presence of  very- small  numbers  of pellet*
 throughout 'the  facility".    The  employee1 in
 charge of shipping and receiving  seemed 'eoa-
 seientious about, sweeping up  spilled pdlets
 and  taking every  precaution  to
 spilled        do not        a      hazard.

 Company E officials were aware  of the prob-
 lems  that plastic pellets pose to  the  environ-
 ment, and recognized that they may be eonttib-
 utmg to the problems,         were not dis-
 cussed regarding employee education .about the
 environmental hazards of plastic pellets.
4,4 3
        Sources of Pellet Releases
        from
During routine           at pellet processors,
       are      likely to be released prior to
the  actual  conveniop  (molding)   process.
Through the site visit observations, discussions
with industry officials,  and a review of the
existing literature, several pellet release path-
ways were identified at pellet processing facili-
ties. These sources included

    »   Uncontrolled manual pellet handling.
       Spills occur        the
       of        into         equipment,  or
       during recoanection of pneumatic
       to die molding machines.  Pellet spills
       while   refitting   molding
Plastic PcSkts In the Aquatic Environment: Sources and Recommendations
                                         75

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        when 'changing products to be molded
        and  during ithe  addition  of coloring
        pellets (I.e.,  TIG, pellets)  to the poly-
        mer pellets.
        Improper  unloading  and  warehous-
        ing procedures.   Pellet packaging Is
        not  carefully                    off-
        loading or Is damaged during offload-
        ing, and pdlets may be spilled onto the
        ground  and  throughout  the receiving
        area.  Improperly warehoused piekag-
        es (e.g.,  stacked haphazardly or  too
        high,  punctured while .moving to stor-
        age) "may fell and result in pellet spills.
        Inadequate  housekeeping.    Spilled
        pellets that are not  quickly recovered
        are tracked throughout a  'facility and
       • mSy be released into the environment.
        Lack  of wastewater control. -Cooling
        water from the molding  machines  is
        discharged  into  municipal  wastewater
        systems; this  water may contain pellets
        that are spilled in  the molding area,
        Lack  of control  of storm-water run-
        off. Pellets spilled at the loading dock
        or transported into the parking lot are
        carried  by storm-water  runoff  into
        storm sewers or  into natural drainage
        basins.
        Disposal of waste pellets Into dump-
        sters,  Waste pellets may be lost to the
        environment -through municipal  land-
        filling and  other  solid waste  disposal
        methods.
Observations at the facilities visited during this
study indicate that pellet control          can
be developed and implemented at pellet pro-
cessing facilities. None, of the visited facilities
processed large volumes of  pellets, and the
facilities did  not      produce consumer prod-
ucts.  Sources of pellet loss and        house-
keeping  and  operation  procedures  may  be
different at larger-scale facilities than at these
smaller-scaled processors.  However, the pellet
release points identified above should be appli-
cable to all processors.
              4.S                 OF
                     TO1NTIFIEO SOURCES
             The representativeness of the visited companies
             as indicators of pellet release and containment
             conditions industry-wide  could not be deter-
             mined,. The possibility that the visited compa-
             nies represented best-case  conditions is  sug-
             gested by the  fact that the            volun-
             teered to participate  in the  study;  companies
             with  significant  pellet containment problems
             would aot  volunteer         to  a  regulatory
             agency regardless of           of no regulato-
             ry assessment or action. The fact that the two
             visited producers. Companies F and G, recog-
             nkact  the  uniqueness  of  their  containment
             systems  and developed materials, highlighting
             the systems, supports this possibility.

             Despite  the unknown  representativeness, the
             study       was      to identify  several pellet
             release points in      sector.  No        was
             male to  rank  the  release points in order of
             significance or-quantities  released.   Basically,
             the         pathways  may be categorized into
             eight general        where  deficiencies  may
             exist.  These areas are

                 *  Lack   of  communication   between
                    Industry  management.   Not all com-
                    pany                             the
                    pellet problem and the need to control
                    pellet releases.  Pellet spillage' faformt-
                    tion,     as the condition of packages
                    and the receipt of         rai hopper
                    cars, is shared between companies  only
                    occasionally.
                 *  Inadequate employee awareness  and
                    training.   Employees  are generally
                    unaware of the hazards posed by pel-
                    lets  and the employees'  responsibility
                    for  causing  and  controlling  releases,
                    A major release, pathway  is through
                    package damage" caused  by improper
76
Plastic Pellets in the Aquatic Environment;  Sources and Rewaaneadaiioni

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         operation  of forkllfts  while  moving
         pallets.   Cargo handlers may  allow
         pellets to fell into waterways  because
         they  are  unaware  of'the hazards  of
         pellets, .'
         Inadequate facilities.  With the excep-
         tion of the  producers  visited  during
         this study, companies have few or. no
         cooling-,  waste-, or storm-water  con-
         tainment  systems in place,  including
        portable   screens  and   facility  wide
         containment systems.  Pellets may be
        'entrained  in these waters and are dis-
         charged   into  municipal  storm  and
         sanitary sewers or into.natural drainage
        systems.
        Careless routine operations.  When-*.
        ever pellets are  handled  there  is  the
        potential  .for pellet spillage.   Manual
        pellet handling is more likely to result
        to spills than handling by" pneumatic
        conveying " systems.    However,  if
        pneumatic          are  not properly
        maintained and   closed,   pellets  may
        leak through openings in the system.
        Pellets "may be released     during the
        transfer of damaged, unrepaired pack-

        Inadequate  housekeeping  practices.
        If pellets  are not  quickly  recovered
        after they  are spilled,  they may be
        dispersed  and  eventually released  into
        the  environment.    Pellets  may  be
        transported  throughout  interior  and
        exterior       of a facility via shoes
        and clothing, vehicle tires, wind, and
        waste- and storm-water runoff,
        Easily-damaged  or leaky packaging.
        Paper and cardboard  packaging  are
        easily           during  transport  and
        handling,  aid,   in   Act,   may   be
                 to be  easily  broken
        loading molding  machines. However,
                packaging  is -a major  source
        of pellet loss to  the environment.  Is
        addition, the valves to self-sealing bags
        may  not  completely close,  allowing
              to leak from the opening.
    *   Improper shipping  praetleet.   If' a
        rail  hopper  car valve or port is not
        sealed or secured sufficiently, pellets
        may  leak  onto  the right-of-way  or
        vandals may easfly open the valves and
        release large numbers of pellets;   In
        addition, pellets may be  spilled  onto
        loading docks, ships' decks,  and
        holds, and be  washed overboard into
        waterways.
    *   Lade of recycling.  Some companies
        do not attempt to recycle spilled pellete
        and,  instead, dispose the pellets into
        the municipal waste stream.

"He identified pellet        pathways'can be
eliminated by   implementing  a  few  simple
control  mechanisms.  Several possible control
            were identified       on the site
visits conducted  during this study, and recom-
mendations to the plastics' industry were devel-
oped.  Recommendations  for controlling pellet
releases,  including  the legal framework  for
controlling the releases, are  described in  Sec-
tion 5.0,
Ptastje Pellets in the Aquatk Environment:  Sources and
                                         7?

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                                      5.0  CONTRO1WNG PELLET
 n:
   ,,.

&
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 wild-
life, including several  "endangered or  threat-
ened species.   These  issues were  detailed  in
Section 3.0 of this report,

Pdlets are released  to the etwironmeht 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 con-
tainment systems.   However, under  severe
weather conditions (heavy rainfall) many of the
pellets may escape even the best pellet contain-
ment  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 envi-
ronment Effective prevention of pellet releas-
es requires both the  implementation of appro-
priate 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 beinf taken by'the indus-
try to  control pellet releases are included  in
Section 5.2,
                                                                5.1     RECOB4MEMDATIONS TO
                                                                             PLASTICS INDUSTRY
 The following recommendations for preventing
 and controlling pellets releases to the environ-
 ment were developed based on the  site visit
 observations (described in Section 4.0), knowl-
 edge of plastics  industry operations, a litera-
 ture  review,  industry recommendations (SPI,
 1991),   and  Department   of  Transportation
 (DOT)  Cargo Security Advisory Standards (49
 CFR Part 101).   Concurrent with mis study,
 the Society of the Plastics Inducstry, Inc. (SJI)
 has also developed  recommendations for con-
 trolling pellet releases; these recommendations
 have been  incorporated  into  tibe  followkf
 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 recommenda-
 tions and indicates the sectors to which to each
 recommendation applies.
                                                                5,1.1   Industry Management
 Poor communication between industry manage-
 ment  and  management of  related  industries
 hampers  the  identification and elimination of
 pellet release pathways.  Despite the SPI ef-
' forts to educate the industry, some •company
 managers did not understand the pellet prob-
 lem' and  'the  need  to  control pellet releases.
 Information is rarely  'shared between compa-
 nies in regard to pellet spillage, the condition
              Plastic Pellets in the Aquatic Environment: Sources sad

-------
             Table 10.  Summary of Recommendations to the Pfasfics Industry
                               According to Industry Sector.
Recommendation
Prod
Tran/
Pack
PTM
Management
Adopt aad uaplemmt SPI's Pettet Raentlon Environmental Code*
Conduct self evaluations to identify problem areas.
Encourage Information sharing between companies.
Continuing developing educational materials.
/
y
y
y
/
/
/
/
/
S
/
/
Education and Training
Educate key officials and company managers regarding the fate and
effects sitd the economic disadvantages of pellet loss.
Educate company employees regarding enviroBmestel hazards and
employes responsibility for corrective actions.
Train pellet handlers to operate equipment, particularly fork lifts, in a
roaaoer that minimizes the potential for pallet loss.
Train longshoremen and other cargo handlers regarding proper pellet
•handling procedures,
/
/
/

/
s
s
s
J
y
/

Equipment and Facilities
Install a containment system to capture storm water runoff.
Improve dry cleanup procedures.
InstsJi connecting hoses equipped with valves that will dose
automatically when Che connection u broken.
Direct She water flow from fail hopper cars and bulk trucks through &
screen to .capture (he pellets rather than spill Leg them onto the ground.
Seal expansion joints in concrete floors with a flexible material.
Install alarm* in the pellet conveyisg system.
Pave all pellet handling areas, including loading docks and rail sidings.
Place screening is storm drains.
Elaw control devices' where they eaa bs serwced without losjng pellets.
Equip bag-handling stations with vacuum hoses to facilitate spill cleanup.
Use tarps or containment devices to collect pellets as they am spilled.
Issiall grating at doorways for wiping feet.
y
/
/
/
/
/
/ •
/
/ ,
/
/
/
/
s
/

y
^
/
/
/
/
^
y
y
y
y

y
y
y
y
y
y
y
y
80
PUatw Pellets in the Aqualie Enyironmeitt: Sources and Recommendations

-------
              Tsbfe 10. Summary of Recommendations to the Plastics Industry
                         According to industry Sector, (continued)
Recommendation
Modify loading systems so that transfer lines can be completely emptied,
with any residual man being contained when loading ceases.
Prod-
/
Tran/
Pack
/
IVoc

Routine Operations
Place portable screens underneath connection points when makkig and
breaking all conaectioas.
Place permanent screens along the exterior edge of the loading docks.
Completely empty transport and storage vessels before disconnecting
from die conveying system.
Supervise longshoremen sod other cargo handlers during cargo loading'
and unloading to ensure proper pellet containment
Inspect cargo immediately upon receipt sad note the condition of
shipping containers and parcels as fee carrier's receipt.
^ Inspect seals on mil hopper cam 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 can
and trucks.
Insist on handling procedures Chat nunimizfe punctures and pellet spillage.
Do not sweep pellets off loading docks and into Jhe water.
Repair punctured bags immediately.
s






'
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            Table 10.  Summary of Recommendations to the Plastics Industry
                        According to Industry Sactor. (continued!
Recommendation
Improve pallstiag methods.
Tape leaks or replace leaking bags immediately.
Inspect pellet packaging before offloading.
Pmi'
/
/

Trml .
Ripk
^
/"
^
Proc

^
s
Shipping ¥ehfcle§
Us® containers for cargo skipping rather tea iadividuAJ pallets.
Identify the person naponnblfi for eealiag the ports os nil hopper cam
MM! bulk tracks, and doounenl sating.
Close and secure the nil hopper car valve with strong wire or aircraft
able in addition to tha sonnal sealing aJfictauim.
Visually confirm &a£ each compartmeet and tube of shipping veliicltss m
empty.
Inspect interiors of trail ere and sea oontufifixs for defects thai imy
pun^ura p*M»3t packaging.
I Consider v&adaiistn espossire wliea selecting leased track sites.

Avoid oa-dfick pellet sto'wage.
Bo HO* jettison pellets or containers of pellets.
Sea! empty nil lioppsr cars aud Uk trucks before returning them to
shipper,
/
/
/

/
/



/
/
,/
/
/
/
/
/
•/


/
/




/
Residing and Waste Disposal
Store waste pellets la properly labeled oontamers.
Inspect aod amUnn proper haadlbg and storage procedure* if an outside
vendor is used for waste removal.
Recycle or resell waste peUete.
Check brakea and discarded psekajpug for residual pellets.
J
/
/
/
/
s
/
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fnd;
Tran;
P*ck;
Proo;
                                  Pkrtb Pclto» in did Aqmtie EnvkomiKnt; Soure«i and leoomawidatbiig

-------

 of shipped packages,  and the receipt of un-
 sealed rail hopper cars.

 The following are recommendations  for con-
 trolling the release of pellets into the aquatic
 environment through improving industry man-
 agement practices,

    *   Adept and implement  SPI's  1991
        Pdlet Retention, Environmental  Code
        and  1992 Processor's Pledge.   Hie
        code and pledge are presented and dis-
        cussed in  greater  detail in  Section
        5.2.3.
    «   Conduct self  evaluations to identify
        problem  areas.  The checklists devel-
        oped by SPJ (1991) should be used by
            sector (Appendk),
    «   Encourage  information-sharing  be-
        tween companies.   The information
        transfer  should include pellet contain-
        ment  system  successes,  identification
        of problem areas  (e.g., the manufac-
       turer should notify a  processor if the
        raU hopper  cars  return  with valves
        open and unsealed), and other mdustry
       successes sod failures fa pellet contain-
       ment.    This  communication should
       extend between companies of the same
       sector (manufacturer to manufacturer,
       etc.) and between  companies of differ-
       ent sectors (manufacturer  to packager,
       processor to manufacturer, etc).  Good
       examples  of information  transfer are
     •  the Dow Chemical and  Paxon Poly-
       mers  videotapes of their containment
       systems,
    *  Continue '  developing   educational
       materials, advertising In trade jour-
      - nals,  conducting   presentations  at
       professional meetings, sending mall-
       ings, and producing tfde®tap«s for
       distribution throughout the Industry.
S.I3,  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  pellef
releases result more from improper  employes
attitudes  than  from  equipment foilure.   This
would  .indicate  that  employee education  is
critical to the success of any corrective action.
Recommendations are' to

    *  Educate key officiate  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 eco-
       nomic   considerations   of controlling
       pellet releases, the economic benefits
       of recovering and recycling lost pel-
       lets, and  the economic disadvantages
       (loss of feedstock,  loss  of  recycling
       revenues)  and   regulatory  penalties
       [National Pollutant Discharge Elimina-
       tion System  (NPDES) permit  viola-
       tions] for releasing pellets.  Also, use
       modern teamwork practices  to  wive
       problems,  and build a consensus and
       coffltoitmeHt .to the task (SH,  1991).
    *   Educate company employes regard-
       ing  the environmental  hazard! • of
       pellets and employee responsibility in
       instituting  corrective  actions.   If
     .  employees  fed involved or responsible
       they may  provide  simple and  useful
       solutions to  eliminating pellet release
       pathways.   Tills can be accomplished
       through  (1)  conduct  of   employee
       awareness programs to educate person*
Plastic Pellets in the Aquatic Environment: Soyrces wid ReoQnuneijdatlona
                                         83

-------
        nd of the      to prevent pellet loss.
        This  could Include posting SPI educa-
        tional                    m
        5.2J),            the          partic-
        ularly to       where        are fre-
        quently spilled.  A
        (l.e»» •luachtime          and
      -  for                  be         with
        the employees; (Z)            bound-
             of              for  spill  re-
              and         (SPI,  1991).  For
        example, designate ~ one or more per-
             per      who will be
        for         prompt and
                within a specified work area,
        or  for   monitoring  and            a
                               and (3) initi-
        ating a         of        for
                 for                    and
        exemplary             in preventing
        pellet loss to the environment.
    *   Train                   to
        equipment,  "particularly  forfdifts,. fa
        a manner that           the poten-
        tial for             For example,
        the                 to
        er                                of
        pellets*      as        that the
        of  the  forkiift ire property
        before contacting- the pallet.
    •   Train longshoremen 'and  other cargo
        handlers              proper  pdlet
                             (49  CFR Bud
        181).
        that       workers" .he         in the
                all
5,13  Equipment and 'Facilities
Many companies  have few  cool tog-,  waste-,
and                                     for
           the         of         from  the
facility,  or          for             -conttol-
ling  spilled         ,                   .for
controlling pellet         to Ae        envi-
ronment by improving existing equipment and
facilities are         below.

    •         A containment system to cap-
           storm-water runoff from pellet-
                            Hie        of
                               into
       worst                            SPI
       (1991)             a
       of  handling "50-  to  100-year  high*
       conditions.    Within the
       system, install baffles, skirts, Booms,
                        and vacuum
       to            and              (SPI,
     •  1991).   Two
                     be             (1)  an
       area-specific                      in
                 handling area. Area-«peeif~
       ic  .containment systems  would be the
       primary pellet containment systems and
       toe Ikcilff-wide       would serve' as
       a .backup; or (2) a facility-wide con-
       tainment               m the
           at           F  and  G
       in  Section 4.2,2),  These         are
       'effective  in controlling pellet
       from          covering  a  large
       and              volumes of pellets.
   •   Improve dry  cleanup  procedure,
       particularly  In  arms  subject   to
       storm-water  runoff.    By .-allowing
              to be          ta
       runoff, the        are
            by           in the
       (SH, 1991).
   *   Install
       with valves that will
       cally when, the eunnectten is broken.
       Hoses   of  this  type  are   commonly
       available,
   *   Direct  the cleaning water flow
       rail               and  bulk  trucks
                a         to           ike

       the-pellets  to           the -ground.
       This                         would
                                     Pkstk Pelktt fa the Aquatic Bnvuonmeof SOUTOM and

-------
•Tl
I-.'"'
                    Immediately capture the pellets  at the
                    release  point,             relying  on
                    elaborate  passive  control          to
                    recapture lie pellets, downstream,
                          expansion  Joints in  concrete
                    floors wlilt  a  flexible material  to
                    eliminate  the pellet-collecting  con-
                    tour. Pellets  that accumulate in ftese
                    joints are difficult to recover by broom
                    sweeping, and may have to be recov-
                    ered either manually or by vacuuming.
                             the  joints  would  facilitate
                    cleaning  and  would not interfere with
                    the expansion and  contrsetioi 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          to"
                    prevent  dogging,   awl  install  a oag
                    house or  filter bag assembly- in the
                    transfer        to                   la
                   1 unloading lines that cause        to (be
                    vented  into  the  environment  (SPI,
                    1991).
                    Pawe  all pellet  handling  anas, .in-
                    cluding, loading docks  and  rail sid-
                    ings.    Pellets  accumulate  between
                    paving       and gravel making pellet
                    recovery difficult iioot impossible.
                    Place screening In storm drains.  The
                         of the screening should be small-
                    er than the                        at
                    tie facility. Regularly clean the storm
                    drain        to prevent drain clogging
                    and overflow.
                   Place control  devices,  such- as bag
                    houses and eydOMi,  where they can
                    be serviced without losing pellets.  If
                   these devices are placed           or
                   bins,  pellets accumulate  on  top of the
                        or      and are.-washed down by
                   rainfall Or blown by  wind {SPI, 1991).
        Equip   bag-handling          : with
        vacuum hoses to facilitate spill clean-
        up.
        Use tarp or containment devices  to
        collect          as       are 'spilled.
        This   facilitates   cleanup,  minimizes
        contamination  of the pellets  (so  (bat
        they  cm  be  recycled),  and  permits
        quick  pellet  recovery by containing
        them '(SPI, 1991).
        Install  grating at doorways for wip-
        ing feet.  During the site visits, pellets
        were observed' in areas of the facilities
        where  only foot  trafpe  could nave
        transported the pellets.
        Modify  loading  systems  so
        transfer  lines  can  be  ecmpletelf
        emptied, with  any residual  pellet*
        being contained  when loading
             1991).  Use stainless stud  el-
        bows on all transfer lines, and cycle
        the outlet "valves  whle the ak is flow-
        ing through tte rail hopper car or bulk
        truck durjng 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 releas-
es to the  aquatic environment by modifying
and improving routine          are
bdow,

    *  Pises  portable  screens  underneath
       connection points when         and
       breaking  all  connections.      The
                should , be placed under the
       valve before the  connection is made,-
       and remain   in  place  during pellet
                 and   valve   disconnection,
       These        are inexpensive, easily-
            Pkstic Pellets in the Aquatic Envirorirnenl; Soured tod
                                         "85

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    rawed, and  me  an
    for                  at the
    point  For          the
    by  Company B           of §
          of 2-  x 4-in,  cut  lumber that
                  on  one      by wke
             (Section 4.3.2),   Additional
                include  (i)  use
                                   (QC)
            breaking      conveying sys-
          etc.,  (2) conduct          only
    in.                  by,
               (SPI,  1991),  and 0) use
    wide-mouth           or         for
                            -These eon-
                wide          that facill-
    tate      (SPI, 1991),
*   Place permanent          along the
                  of file loading
    Time          will
                 punctured           and
                       lag  valves,  and
                             the
                         of Ae 'facility.
    The                      be- .smaller
         the          of the         pel-
    lets        it the facility.
*                       transport  and

    from  the  conveying  system.   TWs_
  ,  would            to  possibility  of
    overfilling a        and
    wb'De        or          connections',
*   Supervise   longshoremen

    loading  and  unloading  to  ensure
    proper pellet containment (49 CFR
    Fart 101).
•   Inspect  cargo  ipupediatelf   ypon
    receipt,             the            of
                        and         on
    the  mkler'i  receipt  f49       Part
    101).
»                 on  rail hopper  cars
    before unloading.  Allow only sutho-
                 to  remove the shipping
            (49 CFR Part 10 1). This
       ihit only         properly        to
                or                      wit
             -the          Document
            and the notify tibe shipper of the
       seal condition,
       Check             for       before
       moving raiicars or trucks.  Visually
              the                 of     the
            and die-                  hose,
       Purge lines before unhooking      and
       lit        to
    *                caps and
                full or         rail
            and trucks.
    *  Insist on warehouse  and other han-
       dling             that  minimize
       and  box punctures and
       
-------
        of all         will be          If  not
                                 also      a
        safely hazard to the employees.
        Invest more time In routine hoi3s«-
        'keepfng.'  The
        are collected, the less      the
        are to be          Into  the  environ-
        ment.
        Initiate                          to
               and          spilled  peJlete.
                are             and
        sweeping  may                of  the
              rather Aan      them.
                                     proce-
        dures  (SOPs)  for
        cleaning up      (SM, 1991).
        Conduct  routine inspections for the
                 of            on the facili-
        ty                    parking  lots,
                   mreat,               etc.
        Peiets           in storm-water runoff
        from any      will impact compliance
        with NPDES          (see
        5.2,1).
       Use sea                   of itmk
       butt packaging.         -a set, con-
       tainers        be released during ship-

       Intprote
       sal                          filling
       to                       valves,  am!
             bags on pallet in
       ing           Shrink-  or stretch-wrap-
             to               and      con-
       tain lost         Use           card-
                  on the top and cm the bot-
       tom of pallets to          puncturing
       or              and to         loose
                 Finally,         and
       outbound loads to avoid            in
              (SPIt 1991).
       Tape       or  replace  leaking
                    (SPI»
                                particularly
                     In unrdnforced paper
       V   cardboard ..  packag«/gayk>rds,
              offloading.  This will preveixt
                            the jpp
       Ae vehicle and the        dock.
5.1.6
                                                  5.1.7
                   is §             of -pellet
loss to 'the eavironmeat; this fart was-
           the site -visits.  Therefore,
                  can be      _ to
      toss        leaky

    «
     •
    *  Use rdnforced  bap,       as woven
       polypropylene       and  line
       containoi  wift   jwoetiire-resistanl

    *            the we of              or
            vaived       immediately afkr
Changes  to  current  shipping  practices and
        can          the likdttiood of
        to. the                       There-
fore,                        cm- be      to
the shipping industry and      of the
industry._

   *.                  for
                                       The
       shipping          wili
               and  will .prevent than from
                                        the
              on the deck of vessels, etc.
   *   Identify the -pwson  responsible  for
               the       OB rail hopper ears
           bulk                tlse
Piwtk Ptikt® in, the Aquatic EavinitiTKaK:  Sources and
                                        17

-------
        document the completion of the seal
        (49      Part 101).  This -will
        lish  the               for
               toe car and §        for tack-
        ing the point at which a     Is
        and       are
     P  Close and        the rail hopper car
        valve with  strong wire  or aircraft
              in          to the        seal-
        Ing  mechanism.   This  redundancy
                 the time  and effort that a
                           .to       the seal
        .and        Ae         Close
        and
        or         the pellets.       on
                  that require-           to
        be properly               rail
        cars .are moved, and request customers
        to do the
        cars (SPI, 1991).
    *             the condition of      and
        cargo containers and rail hopper car
        seals, and promptly notify the manu-
        facturer of           (e»g.»
        packages,  broken  valve         (49
             Part 101).
    *   ¥iaual!y confirm           compart-
        ment     tube of shipping vehicles is
        empty  (SP1»  1991).    In  addition,
        sweep, Wow, vacuum,  or  rinse  the
        exterior         of loaded  rail
             to  remove  loose  pellets  before
                 the             area.   Di-
        rect pellet flow Into  a          bin or
        Into the containment system.  Mao, air
                           to remove residu-
        al       in rail hopper cars and tracks
        (SOT,
    •                   of trailers 'and set
                 fir           walls, defec-
       tive floors, or other defects, that
       puncture                      Cover
                                        or,
       if necessary,  Insist on a replacement
       vehicle,        or vacuum  any ,loose
       pellets In tracks or sea            and
              and        of nay
                     previous  shipments   property  when
                     cleaning ship       .or sea
                                                   (SPI,
                     1991).
                 *   Consider vandalism
                                          site.
                                        as         (SPI,
                     1991).   Advise  companies to
                              to  the                   as
                          as to  the           'and
                     security personnel.
                 •   Avoid
                     1991).  Stow      products oa top and
                                        to sMp wells.
                 •   Do not Jettison        or
                     of
                 *       empty rail hopper cars and bulk
                                            to the
                     per.  "His will        loss of
                     pellets.
             5.1.S            and Waste
             Many                  do not recycle
             pellets, or recycle the       only sporadically,
                        me Joss of recyclable        into
             the muaieiptl              could         me
             likelihood of' fteir                  into  the
                    environment.  Therefore,  several ree-
                          can be       fa       to
             recycling and the-disposal of waste

                »                       in properly  la-
                         containers. Do not permit
                          tb           on the "grooM' oc
                    on       (SPI,  1991).         a  mini-
                         of     pellet-specific       eon~
                   , tamer in
                            container^ should be      for
                    recyclable and
                *          and confirm "proper handling
                    and storage procedures if  an
                           i&       for        removal.
88
Pisigtic Pellets in the Aquatic EnviRtcunciig  Sources and Reeoininenditiaiii

-------
               OQ   TO-loss-to-tibe-envIronment
                  (SPI» 1591).
        Recycle or             pellets.  Use
        incineration  and  controlled  landfiHing
        only whett  recycling or         are
                       Consider
               in a fed  Wending
        (SP1»                       "beds,"
        and       that     are         sad
        recycled,        or         of prop-
        erly,   Tbe
        method  is by  recycling, followed by
        reuse, Incineration by  approved
        odsf or deposit in a. controlled
        (SPI, 1991).
        Check brokers  and          packag-
        ing for
 5.2
                        for            and
 controlling tie        of       to the
 environment.  An          regulatoiy
 work is          that         of
       and
             developed policies and
 in          to  plastic  debris-related regula-
 tions.  Industry has also         policies and
            programs        toward control-
 ling the        of         and, consequently.
       Into the              Descriptions of
                           and'        are
         below,  .
5 J.I  Legal Framework
       legal  authorities, such as international
           and        regulations* have
          for           the        of
             the                      TM§
       reviews       of the
for            the         of plastic
              into                   (water-
based  sources)  and the          of  plastic
debris from land-based  sources, such m
try and        and
Water-Based

The United       is §          to       V
of the         of 1978         to the Inter-
national Convention  for the Prevent!! oe of
                                Protocol of
                           to as MAKPOL
Annex V).  Under the      of the Conven-
tion, MA1K1L        ¥                on
          31, 1988.  "Hie               the
at~$ea         of  all
       normal shipboard

MAKPOL Annex V       be used as a mticb-,
       for  controlling  land-based releases of
pellets into "the environment because the treaty
       only to         at sea awl is not appli-
cable  to                       la addition,
MAKPOL Annex V        only to       of

        are not bound'  by the treaty's
tioos,  but  signatory        are          to
provide          for the          of
       at      (Anon.,  1988b).

The Marine Plastic Pollution Research  and
Control   Act,   Public   Law   100-220
(MOPPRCA)              'the  provisions  of
MA1POL -Annex V by           Ae Act to
Prevent Pollution             is          in
1901 (TIT, 1988).            afad
       other       of                    in
the         in 19S6 MM 19S7

The MPPRCA  specifically prohibit!  the  dis-
posal  of  plastics  at-sea 'by  B.S.-registered
       is any         nod
       "m                 (i.e., baysf
             waterways,  and
and the                                 to
2(11               of the             (TIT,
Plastic Pellets in the Aquatic Environment: Sources md

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       CMC,          The law         the
 responsibility  of  developing  regulations  for
             the MPPRCA, implemmtifig and
         the           aM            clvfl
         for           to  the  United
            (USCG).

 Several            of the MPPRCA that ar.e
 applicable to

    *•  Public            —  Tie
       Oceanogr^pfaie aud              Ad-
                   (NOAA)  and  EPA  are
       required to develop and
                         for           the
       public       the
            the         of       and
       debris into the aquatic environment.
    •  Waste-Reception             —  All
            and
                    of ^400            or
       > 500,000  Ib  of commercial
       products fa a calendar year  must have
                waste-handling  and
                        for          ship-
                                  on load-
       ing docks,  ships*        and to
       holds may  be considered  shipboard
             (A.T. Kearney,  1991).
    *  Waste                   — All U.S.
                    develop  and
       shipboard                  plans that
               the provisions of  MA1POL
             ¥,   He USCG is           to
                any  vessel >         .or  do-
       mestic,             of        within
       200        of the U.S.-       (CMC,
               •    '

               law that may apply to 'water--
              of        into the environment
is  the Marine ^Protection,  Research,  and
           Act of 1972                  is
                  to  as the
Act        tiii MPRSA, m U.S.
         any material, including plastic,  for
the purpose of dumping  the         into  the
            Ae       has  a        to
      EPA; EPA      not             for the
         of            the      and regula-
 tions Implementing the  MPRSA     prohibit
• such dumping.

 In          to              and
        to       the United       is a signato-
 ry,       aid local             may
 tibe         of       from vessels- in
      their-jurisdiction.        (1987)
 erf that      tnd
 on-           or
       waste-storage requirements and provi-
      for          waste-disposal facilities at
 Land-Based Sources

 The          of                   or other
 land-based point                   or
       is subject to regulation
 402 of the        Water Art (Bean, 1987).
 Prior to           16, 19§0»          Pollut-
 ant
       guidelines  for  the
 controlled only the pH of fte effluent and did
 not limit the- discharge of solid or
         (Bean, 1987).  On November  16,
 1990, EPA          the             to "tie
 NPDES            for storm-water
 es.           ' 122  of ' Title  40  [40 CPE
 122.26(b)(12)]                           to
 be significant in storm-water            and
             we                 as
                 Therefore,         can  be
       to                the NPDES permit
 guidelines.
                         to        NPDES
        for all              that cany
wtter from industrial      into  public waiet-
           and Mumraert, 1.991).
                   include 'storm-water run-
off •                     yards,
       roads  and  railroad  sidinp,
ponds,          handling'
                                    Phutie Pellets in the Aquatic Environment: Source* tnd

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 •wastewater  sites,  equipment  bandliog/main-
 tenance areas,  residual treatment  areas, tod
 loading/unloading         (40  CPU  122,26)
 (Bain and' Mummert,  1991).   Areas excluded
 from NPDES permitting include lands separate
 from  those        mentioned  areas, such as
 employee parking lots  where runoff from the
 lots does not mix with runoff from areas of
 industrial activity (Bain and Miunmert,  1991).

 Other Federal laws thai may  apply to  land--
 based         of pellets into the environment
 include

    •   Mvers  and  Harbors  Art of  1899
                Art) — Although  the
        Act of  1899  has      superseded  by
        the  MPDES  permit  program  of the
        Clean Water  Act, it              a
        prohibition against  the' unpermitted
        deposit of- "material of any kind* that
        is likely to be transported into naviga-
        ble waters, other      what would be
        carried  by^   sewers   (CMC,  1988),
        According to CMC "(1988),  it is possi-
        ble that the        Act  of 1899 "could
        be used to prosecute against, for exam-
        ple, an industrial source of large quan-
        tities  of  plastic        or a  landfill
        operated  in such  a  way  that refuse
        could be washed into rivers.**

    »  Toxic   Substances    Control  Act
                of 1976  -  Under  TSCA,
       EPA  has the  authority  to  require the
       testing of new  .and existing chemical
       substances ~ entering the emmroameat,
       and,  subsequently, the - authority  to
       regulate  these ' substances   (EPA,
        1990a),   EPA  (1990a)        that a
       serious         of plastics disposal  in
       water bodies is the injury to and death
       of marine -animals  that mistake plastics
       for food.  However, EPA has histori-
       cally applied Its  authority to  substances
       more  acutely toxic than plastic materi-
       als, and the      is on the toxicity of
       the chemicals and not  on the       of
        •the products in  which the chemicals
        are used (EPA, 1990a)>
     •  Resource  ConserwaUoa     Recovery
        Act of 1P76  (RCRA).— MCRA de-
        fines hazardous waste'as "a solid waste
        , ,  . which         of its .  . .  physl-
        'cal  [or] chemical .  . ,  characteristics
        may . . .  pose a substantial present or
        potential         to  ...   the environ-
        ment when improperly treated, stored,
        transported, or disposed of,"   Based
        on this definition,      (1987) coosM-
        ers  plastic trash  (e.g.,  pellets  to the
        solid waste stream) to be  hazardoui
        waste.  Because the focus of the BPA's
        RCRA  program  focuses on chemical
        toxicity and  generators  that produce
        this- type  of waste  in the         of
        manufacturing  other products,  EPA
        does not regulate pollution  by  plastic
        trash under tie authority of the RCRA
               1987).'

 Additional strategies  to reduce plastic marine
 pollution from land-based          should be
 aimed at state and local governments  (Bean,
 1987).   To date,  no states  have        laws
 restricting  pellet  releases,  although
 states have enacted laws limiting the use  of
 plastic products such as beverage, yokes  (Beaa,
 1987) or requiring the use of
 rial  in lobster/or*      and pots (TTF,  1988).
 Bean (1990) encouraged the development  of
 recyclable or degradable plastics m the solu-
 tion  to          pollution       the growing
 contribution,. of  plastic  to  the solid-waste-
 stream), and recommended  solid-waste dispos-
 al laws" of general  applicability  in  lieu of a.
. major shift to degradable or 'recyclable
 or oonplastie alternatives.
 5.2.2   Government Programs and Policy
The MPPRCA           in       in
5,2.1) requires that  EPA, NOAA,  Ad the
PLaslk Pellets in the Aquatk Environment; Source* and Recommendationi
                                         9J

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            of,                jointly
               public'         programs.  To
       In         . to the        study, EPA -has
  sponsored          activities thai" directly ad-
       the       of       in the environment


     •            the 1990       to fie Con-
                       fo         fliwf Control
                      (EPA,
     •           MPDES
        for                        (40  QPR
        122>
     «  Developing -a          for
                   of the       Water Act, to
                to
        (CSO)
     »  Initiating       of CSOs as        of
                debris,                (EPA,
                   ,   '•-
     »                            of
               in        of the
        (EPA,                TrulII  er of.,
    '   1990;         el a/., 1992)
     *           t pUot         for
        tog the           of        on U.S.
        beaches,  This program Is being con-
        ducted In conjunction with the
        Park Service,
 The         iOcean Pollution Planning Ad
 of 1978  required that  NGAA prepare 5-year
       for             !and monitoring
 pollution,          the         of
      and         of       %        organ-
       In '1987, NGAA" 'convened a
 to  establish  the ' National -  marine  pollution
          priorities,                was
' 'the top five                  aid the
       of the              and        on the
 eavTOmnent       specifically named.   He
' proceedings  of" the worisfaop             to
        the         Pianfor       PotlMtion
          ,               and            for
 Under  the             of  NOAA and  the
                                   
-------
 >j"
 f
 * V
If.
i
              provide'several good             for control-
              ling                     rail hopper  can  in
                            aad      the         right-of-
              way,  Applicable recomniendatloni have
              Incorporated Into        5,1.
              '5.23  Industry          and Initiatives
 In            .to   the                   of
 MARPOL       ¥           and
 evidence  of tie                of        to
 the         environment,  the plastics Industry
 and
           md developed  policies  aimed at
 controlling the         of plastics,
        into the        SIM! waterways.
        Industry Programs'

In addition to the voluntary cooperation of SPI
and the                       in the
               4,0),  SPI has          other
activities deigned to Inform and         the
                  in        to the        of
released pellets on the-environment,

To alert pellet           of  the          of
              into the             SPJ host-
ed a briefing for pellet producers  in  Septem-
ber,  1986.                       by a Cento
for                     (CMC)
on        debris, as well as              of
industry pellet reclamation activities, eventual-
ly led to t
below). la           1981, the SPI       of
Directors       in        policy           la
       to                  the plastics indus-
try's pledge to solve the problem.  la        to
pellete  specifically; the statement dearly
that SPI  was           to             condi-
tions       which-      are         by man-
ufectwen and transporters (Bruner, 1990),
 la 1987, SPI, NOAA, and CMC jointly
 ed a           to        'the
 die        of         ip          Tie cam-
 paign        on all types of              tad
                         audiences.   Pellets,
 whose       audience .was the
           and             was oae of five.
 target points of the campaign (SPI,  1990).  SPI
         t                       and Educa-
 tion  Kit for the                  , included
                                    Infonoaa-
 tion, md 'peBet-related          carrying  the
•               Qpwt      rte
 a            of  a  single pellet (Figure 31).
 The kit was          so that
 Ma                                   -cam-
 paigns and educate employees  about  the owl-
                         by pellets.   Sevenl
                  were          for
 ling •               during              iUp-
 piog,  and  handling.   SPI                 kits
 to 1500                        and
 published  portions of. the kite  in
        In  I9S8, the  kit                   to
 the              community;   SPI Pr«Ment
 Larry Thomas                  to the
 tional Association of Plastics  Directois.   By
 the end of  19S9»       than  1000-
       of                    (25
 in 10 publications) or              had
         to the                '(Bruner$  19%;
 SH,  1990).        kits          to be
                   aad the pellet
         in                       1990,

 EPA'.studies .between 198S aad 1992
 1990b,.  19§2a»b»e)       tfcat
         to be an               problem,  fa
         to              SPI         i
 Pellet Tisk Force to investigate Ae problem.
 In November 19%,           the         of
 the                   Form,  SPI          t"
•second  campaign'          Operation
                at die                nd Its
           (Figure 32).  The' 1991       Jte-
       Envtroanuntal' Code'.(Plgan  33) tod
 the      Processor's-               34) are
 an              of  this             SPI has
             Plwtk PeSrta in the Aqo&tic Environment:


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             A
  this                    for a fish         And die.
             Keep Resin Pellets In Their Place . . .

        And Let The Birds Find Something Else To Eat
                      I Th« Society of Che Piasiics Industry, NIC,


Figure 31. A Poster Distributed during the 1987 SPI Marine Debris Campaign,
                        Ptastic Bdlets in the Aquatic Environment; Sources and

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                            V-P>*>^t«-™!**^^^
                Out To Stop Resin Met Loss !
      ft
                     to project ow enwooment , . . and four business with Opemion Ckan
            Sweep. A poweriiilpn^on designed 10 reach evei>t)odx
        producers to cfiseribuiore to processors. Fran the loading dock to the boaatrofm
           Eventhe5iraUestk}Korfesinpelleisisapro^^
        fxt3cfaKiJoij,.,BtfolcKinpKkffli^a«l di^iqg ...zero toss to receiving, ..zero Joss to
        pctKsssiag. It 's as simple as nunimair^ sptts, prompt art tteoughcta^
           Be part of dK solutioa Hnd ouihowyou cm reduce the loss of resin pdkts and noc'
        only he§ to protect the environment, but obey the law. Write woUforOfSeratlQCiGeifl
        Sweep information today, Ancthdp our industry keep the envbonment'dean.
                          CaM     fTl-5215 or     te
                     The Sodetypf the Plastics todsistr?. Me.
                 1275 K     NW, Suite 4l»,           DC 20005
 Figure 32.  Advertisement for the 1991 SPI Opefation Clean Sweep Campaign.
Mett in the Aquatic Environment: Sounoa and
95

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       Its
 to      the                  'Environmental'
      tnd», thereby,•         to  *ttie      eon-
 tainment  of plastic pellets  throughout  thek
         and -to           In foil  compliance
                         and            im-
 pacting on                     ,{SPJ»  1991).
 By the 'end  of August 1991, nearly
 of the companies had signed and       to the
      and the                          con-
 sidering toe        (Mr.                SPI,
                                 28,  1991,
 WasMnglOtt,  DC,).   The Processor'$
 WES developed  and introduced to SPI's proces-
 sor           In the         of 19® in an
       to        that         of the
 mpre aware  of the  importance of preventing
      loss.                 Sweep was Intro-
 duced to the         industry at the National
        TtM&       In July 1991, to
 lllBGfs,   The            was  also
                   of
 over 25          it  the             Associa-
 tion of        Directors to June 1991.  SPI it
                       of
 of the                 for distribution.
          by Individual Companies

                               programs to
        the         of              into the
               Good           of
        measures-were         at      pro-
ducer Companies- F and G {Section 4.2.2) and
                         B        4.3.2).
Merchant          Initiatives

                     that the          Insti-
tute of                   (AIMS), a
      issoeiitloQ for'many -U.S.-flagged'mer~
             his given-testimony to 'the. Con-
     to        ,of fte provisions .of MAKPOL
Annex V,  AIMS-
of                                pollution'
,            and              of
 with.                ¥          ,
 5 J                           TO
        MIGULATOIS
 A  logical          for identifying problem
             § facility are  the Federal,
 and                                    die
 ttiree          This      not       that
 inspectors should  be empowered  to  fine or
 otherwise           the  facility   operators.
        the                    flie
 nity to point out                  and
 problems  during their routine

 Therefore^  title following  recommendations
                   for

    *  Educate local,  -state,  and Federal
       Inspectors.  These'inspectors generally
                           to  the
            do tny                 official,
       Although tie          have no rep-
       latory  authority over  pellet contain-
       ment, &e fact that i regulatory official
                 a

    »  Establish  guidelines for sealing the
      ~ ports  on  rail  hopper  can,  bulk
       trucks, and  other shipping vehicles,
       The, DOT                  AMsory
       Guidelines,          to 49 CPU Part
       101, include  several reeGmniendatiQB&
       that have been incorporated into  ftfs
       report
    *             .                      to
       notify  the        Mid
       broken or                 are  ob-
       serwed.    Although" pellets are  not
                  by D0T to  be

       be        to the
       if  no preventive measures  have  been
                                    Ptatie WkSi in the Aquttks Environment: Sownse*

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                     taken  (e.g., ral hopper ear valve not
                           or inadequately §ealed).
             5,4                 OF
                     RECOMMENDATIONS
                                                    would be inexpensive to  implement.   Facility-
                                                    wide containment systems have bees shown to
                                                    be  effective  pellet control mechanisms,  tat
                                                   . these systems may not be-          at smaller
                                                    facilities or at faculties that effectively control
                                                    pellet      where they occur.
if
,-4
  Existing  Federal  regulations,  such  as  the
  MPPMCA, provide a       for requiring con-
  trols over the release of all plastic materials.,
  including pellets, tate the aquatic environment.
  Provisions of  the recently finalized  stonn-
  water discharge' rules specifically
  in storm-water  discharge.   All  facilities  are
  advised flat they      to be         of pellet
  contamination of storm water and the need to
 comply with any  applicable terms  of their
 permit regarding pellets.   However,
 alone cannot  control the       of pellets; &e
          can only            companies  to
 implement  control  measures.    Ultimately,
 controlling pellet         into the environment
 is  the  responsibility of the  plastics- industry^
 and effective  controls should be continued and*
 enhanced  through  voluntary  industry  "pro-
 grams.

 Controlling pellet           can   begin  with
 proper  training and education of        indus-
 try managers  and employees and by increasing
           of  the         posed by pellets and
 of  the  economic  incentives  for controlling
 releases.   Capital investments hi containment
         miy  be            to control
 at facilities that  handle large volumes  of pel-
 lets, but Inexpensive control measures, such as
 portable        or tarps, may be         for
 controlling releases at small-volume Compa-
 nies.    All facilities  could  improve  routine
 housekeeping              by  increasing  'the
 frequency of sweeping and including the use of
 vacuums to recover spilled"pellets.

 In conclusion, several mechanisms -for control-
ling pellet         are currently available, and
most  of the meefaaiusms,  such as education,
portable screens,  and Improved housekeeping,
            Plastic Wtett in the Aquatic Envlronnwrt;; Sources &ad Recoiunadaiktai

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DM«fa» (PMTO)drrbeSoeietf oftfae
               Member OMBpanfes of the Wytnerfc
                         to ojwafing in fill
               OB pdkt oonabunau. To adaiesc this goal, the following sate* are snwgljf encouraged.
               pfans to hdp bring sfccwi die Mkwfag §eak
                     * Property SCOXTE sad CEtemafly dean bulk cEBitsio^
                      fttwkte ciDK^tainiTieBC gyaen^ 10 prevem prik« tham eac^^
                              «ys^™ thw pr w4des fc rtx^^
                                    ciiBi thtar eic^i
                                                         ^^
               caBy adviie tbem as 10 hot* Important adrieweoimt of thoe goate k ID the enrviiWBHeet, dbe pubfc and
               ttte irtdi^Mry d»ey serve. MeMibcrc£«j|>m)a«faiBprtWBdc asaistffloiUit^^
               ttes ta pdlct CMiBinmcni: and ask »hein to actaiosAM^e Adr aecqM*noeofl6egMfcirftfclicocle.
                 S*eru» Itefccskm
                                                                        i pete eontsfanieni
                      FVtividg appropriate TOBtsmmoitsjf^^
                      D«?>«k^as¥Mcm thai. prc^iioferEsx^^roifja^is tobe
                      inanaier ifctt pwwna dhdr ««^te into 4e enwrewnent,
               theknpcrtaiKC af raspoasibtecsrc, Mfflaber cnmfKinfca ato wiB prcmdc asrf^^K^ in i3BpfXi
               a»»«jiBc«" capaMitto In pelet eoatatomcat send a* tu^h ou»aai««t»atiaioiilc^pAdt»
               of she goab of dai code.
                                                          i^
                    * l^oitt approprte amtsfam^
                    8 Devefep i swgm tb^ piTovkks fe all recovCTixi pdkw
                            that ptwoMi ihar escape inso ft* eroif
                                                                Dfefefass
                                                           fcdussry, Inc
                                                              40)
                    Figure 33,  1991 SPI  Pellet Retention Environmental Code.


98                                        Pkstic PdJ.etg in the Aquatic Enviroiimer.f: Sources and

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                                                 T©
                                  PREVENT EESIN PELLET Loss
             Recognizing the importance of preventing the loss of re$in pellets into the
             environment this company commits Itself to the following principles -
             We will!
                »  Comply with all environmental laws and regulations impacting on pellet
                   containment,
                »  Install containment systems or devices as needed in unloading/transfer
                   areas to effectively prevent release of pellets into the environment  •
                •  Conduct regular training of employees ©n spill prevention and cleanup
                   procedures.
                *  Prevent all spills possible, cleaning up any spilled pellefs as quickly as
                   possible.
                •  Ensure that shipping containers (rail cars and bulk trucks) arc
                   properly secured prior to movement or return, and that disposable
                   containers (gaylorefs, bags, etc.) are completely empty before disposal.
                *  Recycle any recovered pellets or otherwise secure them in a manner that
                   prevents their escape into the environment upon disposal.
Ste
            Company Names..	,.	 Dales.
            Authorized Representative:.	„	«.	
            AddlCM!.....	„„..„.„...„.'	,
            City:...	..•		..State:
.Zip,
                                 Figufg 34.  1992 S PI Processor's
          Plastic Pellels in the Aquatic Environment: Source* and Heeommendafcions

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                                       6.0  GLOSSARY
 Additive
 Conveyor



 Culvert


 Effluent


 Epibiont
 Extrusion
 Gaylord
 Gizzard
Hopper
Melt
Monomer
 Used  to  alter  the  physical
 characteristics  of a  polymer,
 such as the .esthetic and physi-
 cal properties and the ability to
 be further .processed.

 A  machine  that  transports
 materials  from  one  place  to
 another.
 A  sewer  or
 under1 a, road.
drain  crossing
 How of waste water released
 from a facility,

 Organism that lives attached to
 another organism  but  without
 benefit  or  detriment  to  the
 Host.

 Shaping  plastic   by  forcing
 through a.die.

 Large, IQOQ-Ib capacity, card-
 board box used  for shipping
 pellets.

 A muscular enlargement of the
 digestive tract of a bird,

 A receptacle in which  materi-
 als are held  in readiness  for
 unloading or dispersing.  .

 A  hot,  very   viscous  Jiquid
 produced'  by  the  process  of
 bulk polymerization.

 A molecule that can be chemi-
 cally  bound as  a  unit  of a
polymer.
 Neuston       Small-  to  medium-size organ-
               jsins that live on.or under the
               surface film of water bodies.

 Pellet         Resins   that   are   generally
               spherical, ovoid, or cylindrical
               in sbape, and between 1 and 5
               mm dia.

 Pelletizer      Equipment  used  to   create
               pellets  from  polymers.   The
               type of pelletizer used  deter-'
               mines the size and shape of the
               pellets.

 Packager       Sector of the plastics  industry
               that breaks down  bulk ship-
               ments  of pellets into smaller
               containers  such  as  bags and
               gaylords; also called  contact
               packager.

Processor      Sector of the plastics  industry
               that molds  the pellets  into
               fabricated user-products.

Producer       Sector, of the  plastics  industry
               that creates the polymers and
               extrudes the pellets.

Transporter    Sector of the  plastics  industry
               that'  moves   or  carries  the
               pellets   between   the   pellet
               producers,   packagers,  and
               processors.

Pinocytotic,    Active ingestion  of fluid by  a
               cell, by imagination of the cell
               membrane to form vesicles.

Pneumatic      Operated by compressed air.
Mastic PdJets in the Aqu-aEic Environment: Sources and Recommendations
                                                                             lot

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 Polymer       A         or  synthetic • com-
                                 of
               Inter-linked molecules.

 Polymerize    To        or          into a
               polymer,

 MJtoad siding A length of railroad track that
               Is          to the main track.

               A
                         or        gas deriv-
               atives.

           •    A
                         of        reetangu-'
               iar        ani  a drive system,
               The
               water surface       a contain-
Thermoplastic
rafats
Tberaaoset
resins
Weir
                            •Resins that cm be       or
                                        without
                            or           the           or
                            physical properties of the poly-
                            mer.         are MgMy mal-
                            leable but
                            cooled.

                                  that     to be rigid,
                            Infesible,  and            and
                                   be          and  re-
                            formed.

                            A   mechanical   device   that
                                    the       and'      of
                                  by            or
                            mechanical devices.
102
Pl*stiie PeBeta in tiw Aquatic
                    Soure« *nd

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 Anon,   1981.  Galapagos fainted, by plastic
 pollution.  Geo 3:137,

 Anon.  1988a. Modern Plastics Encyclopedia.
 McGraw-Hill Publishing Co., Inc., New York,
 NY,

 Anon.  1988b,  Plistic dumping at sea to be
 banned.  Mar, Pollut. Bull. 19(4):90-91.'   •

 ABOH.  1990,  Dynamic Air Conveying  Sys-
 tems.  Advertisement.  Cham. Equip, 29(4):2.

 A.T. Kearney.  1991,  Revision of tide  Port
 Reception Facility Section of the IMO Guide-
 lines  for  the  Implementation  of MAKPOL
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-------
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-------
               . Appendix


FOR
      AND

-------

-------

-------
                   .:P-reven€ing  'Pellet   Loss
                   RESIN PRODUCTION  FACILITIES
                               CHECKLIST
      (You may wish to use this checklist after you've reviewed the recommendations in the
      preceding chapter. It is suggested that each resin production location complete a checklist)
      Put A-General
      Yes No
       Q  Q Is your company implementing the SPI Pellet Retention Environmental Code?
       Q  Q Do you haw written procedures for reducing and recovering any lost pellets?
       Q Q Do each of your resin production facilities haw *iero-los" containment systems
              that will prevent pellets from escaping plant boundaries?
       Q Q Is direct responsibility for preventing pellet loss assigned to specific individuals?
       Q Q Have you conducted an employee educational awarenea campaign on preventing
              pellet loss? (If no, consider ordering Operation Clean Sweep materials from SPI.
              See page 36.)

     Part B-Rail Hopper Cars           -
      Ye No                              •
      Q Q  Do you collect - for recycling or proper disposal - ail peUets recovered during
              cleaning of empty hopper cars?
      Q Q  Do you cleanse hopper cars of loose pellets after they hate been loaded and
              before they leave the "secure area" of your containment system?
      Q Q  Is sampling conducted only in areas protected by your containment system?
              (If not, do you insist on use of a mrp or "catch tray* to collect any pellets
             spilled during sampling?)
      Q  Q Do you use heatyduty aircraft cable scab on all outlet caps and hatch covers?
      Q  Q Do yoo regularly remind customers of the importance of securing outlet caps
             before returning empty cars to you?
PeUeti in the Aquatic Environment: Sources and Recomrrienektiofts
A-l

-------
                        Prevent! 11 e  Pellet   Loss
                       RESIN  PRODUCTION  FACILITIES
          Part C - Padogmg/Warehousing
                                                                4
           ¥« No
           Q  Q Are loading/unloading areas paved to facilitate cleanup?

           Q  Q D© transfer lines include a bag house or filter bag assembly to preventpellet
                  loss during surges?
           Q  Q Do you use packaging that minimizes leakage from bag valves and offers
                  maximum puncture resistance?
           Q  Q Are corrugated caps (lop and bottom) used on palletized bags? Are palletized
                  bags shrink- or stretch-wrapped?
           Q  Q Are "caich trays" placed at each shipping/receiving bay to help contain spilled resin?

           Q  Q Do your procedures make cleanup the responsibility of the person (s) causing
                  the»pill?
           Q  Q Are floor sweeps and other waste pellets disposed of in a manner that prevents
                  their loss into the environment?
         Fadlity Location.
         Checklist Completed By.
         ResponsiWe for Corrective Follow-up
                 .Date
A-2
Ptastk Pellets ta the Aquatic Environment:  Souroa and Recommendations

-------
                          Preventing -Pellet   Loss
               RESIN  HANDLING/PA-CKACING/WAREHO USING

                                      CHECKLIST

             (You may wish to use this checklist for each plant location after reviewing the
             recommendations In the preceding chapter.)

             Part A-General
             Yes No
              U  Q Do you have written procedures for reducing and recovering any lost pdlett?
              Q  Q Is "direct responsibility for preventing pellet loss assigned to specific individuals?
              Q  Q Have you conducted an employee educational awareness campaign on preventing
                     pellet loss? (If not, consider ordering Operation Clean Sweep materials from SPL
                     See page 36.)
              Q  Q Are tools/materials readily available to handle cleanup of spills?
              Q,  Q Are yon aware of permk requirements pertaining to resin pellets that are required
                     % die U.S. government's new storm water regulations? (If not, contact SPPs
                     Technical Affairs Department for further information.)

            Part B - Resin Delverf/Storage

             Q  Q Is your unloading area protected by a storm water containment system?
             Q  Q Is it paved  to facilitate cleanup?
             Q  Q Do you dean up immediately all spills resulting from sampling of bulk shipments
                     or unloading procedures ?
             Q  Q  Do you insist thai employees replace 'and secure afl outlet caps and hatch
                     covers on bulk rail hopper cars before releasing cars for return shipment?
             Q • Q  Do transfer lines include a bag house or filter bag assembly to prevent loss of
                     pellets during surges?
             Q  Q  Do transfer lines have stain less steel elbows? Nozzle interlocks? Is there adequate
                    capacity to prevent plugging?
             Q  Q Arc "catch trays" placed at each shipptag/recewing hay to help contain spiDed resin?
             Q  Q Do your procedures make cleanup the responsibility of the person ($) causing
                 •  the spill?
             Q  Q Are floor sweep* and other waste pellets disposed of in a manner that prevents
                    their loss into the environment?

            Facility Location	
            Checklist Completed By	_Date	
            Responsible for Corrective Follow-up	
Ptutic Pellets in the Aquatic Environment:  Sources and Recommendation*                                     A-3

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                          Preventing   Pellet   Loss
                          PROCESSORS  &  REP1QCESSORS
                                     CHECKLIST
            (You may wish to use this checUm after you've reviewed the recommendations in the
            preceding chapter.)
            Part A-General
            Yes No
            Q   Q Do you have written procedures For reducing and recovering any lost pellets?
            Q   Q Is direct responsibility for preventing pellet loss assigned to specific Individuals?
            Q   Q Have you conducted an employee educational awareness campaign on preventing
                    pellet toss? (If not, consider ordering Operation dean Sweep materials from SPL.
                    See page 36.)
            Q   Q Are tools/materials readily available to handle cleanup of spilk?
            Q   Q Are you aware of permit requirements pertaining to resin pellets that are required
                    by the U.S. government's new storm water regulations? (Knot, contact SPFs
                    Technical Affairs Department for further information.)
            Part B - Resin Delivery/Storage
            Q  Q  Is your unloading area protected by a. storm water containment system?
            Q  Q  Is it paved to facilitate cleanup?
            Q  Q  Do you clean up immediately all spills resulting from sampling of bulk
                    shipments or unloading procedures?
            Q  LJ  Do you insist that employees replace and secure ail outlet caps and hatch covers
                    on 'bulk rail hopper cars before releasing cars for return shipment?
            Q  Q Bo transfer lines include a bag. house or filter bag assembly to prevent Io« of
                   pellets during surges?
            Q  Q Are "catch trays* placed at each shipping/receiving bay to help contain spilled nesn?
            Q  Q Do your procedures make cleanup the responsibility of the person (»} causing
                   the spUl?
            Q  Q Are floor sweeps and other waste pellets disposed of in a manner that prevents
                   their loss into the environment'
          Facility Location	.j	
          Checklist Completed By	Date	
          Responsible for Corrective Follow-up	
A-4                                     Plastic Pelkte in the Aquatic Environment: Sources and Recommendations

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                          -Pre veltt in g  Pellet   Loss
              MACHINERY  MANUFACTU.RERS/MOLDMAKERS/
                    -^RESEARCH  AND  TESTING  FACILITIES

                                      CHECKLIST

            (You may wish to use this checklist- after reviewing the recommendations
            in the preceding chapter,)

            ¥es No

             Q  Q Do you have written procedures for reducing and recovering of any losipeieto?


             Q  Q Is direct responsibility for preventing pellet loss assigned to specific individuals?


             Q  Q Have you conducted an employee educational awareness campaign on preventing
                    pellet lots? (If not, consider ordering Operation Qemn Sweep materials from SP1.
                    See page 36.) '

            Q  Q Are tools/materials readily available to handle cleanup of spalls?.


            Q  Q Are you aware of permit requiremen ts pertaining to resin pellets that are required
                    by the U.S. government's new storm water regulations? (If not, contact SPI's.
                    Technical Affairs Department for further information.)  '

            Q  Q Are "catch Days" placed at each sWppuig/reeewing bay to help contain ipiUed resin?


            Q  Q Do your procedures make cleanup the responsibility of the person (s) causing'
                   the spill?

            Q  Q Are floor sweeps and other' waste pellets disposed of in a manner that prevents
                   their loss into the environment?
           Facility Location
           Checklist Completed %_
           Responsible for Corrective Follow-up_
Date
Pkrtie Pdte ia the Aquatic Environment  Sources and Reoommeod»tiop«
                                        A-S

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                         Preventing   Pellet   Loss
            TRANSPORTATION'  SERVICES &  REPAIR. FACILITIES

                                    CHECKLIST
           (You may wish to use this checklist after reviewing the recommendations
           in the preceding chapter.)
           Part A-General

            Yes No
            Q  Q Do you have written procedures for reducing and recovering any lost pellets?
            Q  Q Is direct responsibility for preventing pellet loss assigned to specific individuals?
            Q  LI Hawe you conducted an employee educational awareness campaign on preventing
                   pellet loss? (If not, consider ordering Operation Qean Sweep materials from SPI.
                   See page 36,)
            Q  Q Are too Is/materials readily available to handle cleanup of spiib?
            Q  Q Do yow procedures make cleanup the responsibility of the person (s)  causing
                   the spill?
            Q  Q Are floor sweeps and other waste pellets disposed of in a manner that prevents
                   their loss to the environment?
           Part B - Repair Fadlitiei

           Yes  No
            Q  Q Are pellets coleeted and properly disposed of (in a manner that prevents their
                   release into die'environroent) during routine maintenance and cleaning of rail
                   hopper cars, hopper trucks, package trucks, bulk shipping containers, etc., prior
                   to loading with a new resin order?
           Q  Q Do you insist that unloading ralves be dosed, outlet caps secured, and hatch
                   covert closed before returning empty cars?
           Q  Q Are any pellets spilled during rail yard repairs promptly and thoroughly cleaned
                   up and properly disposed of?
A~6                                    Plastic Petes in the Aquatic Environment:  Sources and Reoommeodatioof

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P r c v c n I i n %
                                                       llet
           TRANSPORTATION  SERVICES &  REPAIR  FACILITIES
           Part C - Maine Uransport
            Yes No
            Q  Q When ship holds or ocean containers are cleaned after break-bulk shipment*,
                   ire loose pellets properly contained before disposing of them?
            Q  Q Do employees know the importance of not sweeping periets into the water?

            Q  Q Are- ocean containers in good repair »thai interior deficiencies don't tear
                   open bags/boxes?
            Q  Q Are ocean container! of resin stowed in the ship wells, not on deck?

            Q  Q Do shipboard emergency procedures provide for priorities of other cargo to
                   be Jettisoned rather than plastic pefiets?
           Facility l/Kaoon.
           Checklist Completed By _
                                Date
          Responiibk for Correetwe
Pkstic Pc.lkts in the Aquatic Environment;  Sources and Recommendilion
                                                                     A-7

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                          Preventing  Pellet   Loss
                             WASTE  DISPOSAL  S-EftVICES
                                     CHECKLIST
            {You may wash to use this checSdiit after reviewing the recommendations in the preceding
            chapter.)
            Yes No

             Q  Q  Do you have written procedures for proper disposal of waste peUea?

             Q  Q.  Is direct responsibility for handling waste pellet disposal assigned to specific
                    individuals?

             Q  Q  Do you use only covered consainere or vehicles without teaks when transporting
                   .or $KMing waste pellets?

             Q  Q Are waste pellets incinerated, whenever possible?

            Q  Q When disposing of pellets in a secure landfill, do you "make sure the pellets are
                   confined in such a manner that prevents their lost due to rate, wind, Hooding, etc.?
           FaciMq' Location
           Checklist Completed By,
                   Date
           Responsible for Corrective Follow-up.
A-g
Ptatie Pellets is the Aquatic Environment; Sources and

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