United States EPA 842-S-93-001
Environmental Protection August 1993
Agency
Office Of Water
(WH-556F)
Pellets In The
Aquatic Environment
Sources And
Recommendations
A Summary
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INTRODUCTION
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, aesthetic, and
ecological impacts and can come from both land- and sea-based
sources. One type of debris that has become of particular
concern to EPA is the plastic pellet.
The Oceans and Coastal Protection Division (OCPD) of EPA's
Office of Wetlands, Oceans and Watersheds (OWOW) recently
conducted a comprehensive assessment of the sources, fate, and
effects of pellets in the aquatic environment to determine what can
be done to control and prevent their release to the environment.
The goals of the study were to:
• Summarize wheat Is known about the presence
and impacts of pellets In the aquatic environment,
• Identify and evaluate how pellets escape into the
environment, and
• Recommend ways to control or prevent future
pellet releases.
The study promotes EPA's national policy on pollution prevention,
which is based on the Pollution Prevention Act of 1990. EPA's
policy is to (1 ) reduce or prevent pollution at the source whenever
possible and (2) assist state and local governments and the
private sector in achieving
source reduction. The »@ne fype of debrfs that
EPA's policy by assisting COnco/n to EPA IS the
the plastics industry in plastic pellet "
implementing voluntary
pellet-control programs to reduce the release of pellets into the
aquatic environment. This brochure highlights EPA's report,
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Plastic Pellets in the Aquatic Environment: Sources and Recom-
mendations, which represents the first comprehensive assembly of
information regarding the presence and ecological effects of pellets
in the aquatic environment and is expected to become a basic
reference for EPA and industry.
WHAT Is A PLASTIC PELLET?
Plastic (resin) pellets
are the raw materials
that are melted and
molded to create plastic
products. Plastic may be
formed into pellets of
various shapes (e.g., spheri-
cal, ovoid, cylindrical), sizes
(ranging from 1 - to 5-mm
diameter), and colors (most
commonly clear, white, or off-
white). The wide variety of plastic
products produced internationally
has created a demand for many different polymers, or resins. An
estimated 60 billion pounds of resin, most of which is formed into
pellets, is manufactured annually in the United States. The most
commonly produced resins include polyethylene, polypropylene,
and polystyrene.
After being formed, the pellets are packaged and transported to
processors for molding into plastic products. At many points in
their creation, transport, and use, pellets may be spilled and carried
by rainwater and drainage systems into the aquatic environment.
Once in the environment, the pellets will either float or sink: pellets
that are heavier than water will sink to the bottom, and pellets that
are lighter than water will either float at the surface or become
suspended in the water column somewhere between the surface
and the bottom. The EPA study focuses primarily on pellets that
float.
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THE ENVIRONMENTAL PROBLEM: SOURCES,
FATE, AND EFFECTS
Historically, several sources of pellets in the aquatic environ-
ment have been suggested, including direct discharges and
improper wastewater disposal by the plastics industry; spillage
from trucks, railcars, and ships; improper use of pellets; and waste
disposal and sewer discharges by cities. The findings of the EPA
Harbor Studies Program and Combined Sewer Overflow (CSO)
Studies Program concluded that significant land-based pellet
sources exist and the plastics industry is a likely source of the
releases.
Pellets released by the plastics industry flow into the aquatic
environment by two routes.
• CSO and stormwater discharges—
Spilled pellets may be carried by rainwater into stormwater
drains, which in turn transport the water into municipal waste-
water systems. The pellets may then be discharged into the
aquatic environment through stormwater discharges or, where
the sewage and storm sewers are combined, through CSO
discharges.
• Dfr&ct spins Into th&aquahc environment—
Pellets may be spilled directly into waterways, such as during
cargo handling operations at ports or during cargo transport
at sea.
The presence of pellets in U.S. coastal waters was first reported in
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 Program) revealed widespread distribution
of plastic pellets in U.S. harbors located on the Atlantic, Pacific,
and Gulf coasts, and pellets were among the most commonly
found ftems in most of the harbors. Pellets were found in 13 out of
14 harbors sampled. The greatest number of pellets was found in
the Houston Ship Channel at Houston, Texas, where more than
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250,000 pellets were collected in one sample alone. Notably,
Houston has one of the greatest concentrations of plastics
industry facilities in the United States.
During its CSO Studies Program, EPA also found pellets in the
municipal wastewater systems of Philadelphia and Boston. For
example, pellets accounted for over one-half of the man-made
debris collected at one Philadelphia stormwater discharge. Pellets
were also found in samples collected from four sewage treatment
plants; based on the study findings, EPA has estimated that more
than 20,000 pellets per day may be present in the sewage treated
by one Philadelphia plant. The pellets are removed from the (
sewage during sewage treatment. The presence of pellets in 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 stormwater
discharges during rainy periods.
The persistence of a pellet in the aquatic environment may be
measured in years, depending on the resin type, the types and
amounts of additives, and the reactions of the resins and additives
to environmental processes (e.g., weathering, sunlight, wave
( } = Bpprcutlfnfite
<200)j number of
pellete collected
York Houston Tacoma Puerto Rteo Honol
Selected Harbors
Percent of pellets found in the total number of debris Items
collected in selected samples from the Harbor Studies Program.
ro
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action). Once in the environment, pellets may be transported by
stormwater runoff, rivers, and water currents to areas far away
from the source.
There are several documented accounts describing the ingestion
of pellets and other plastics by wildlife, most notably seabirds and
sea turtles; however, impacts or biological effects of the pellets
have not been clearly defined or demonstrated conclusively in
most wildlife. Seabirds ingest pellets more frequently than any
other animal, and approximately one-quarter of all seabird species
are known to ingest pellets. Pellets ingested by seabirds are
suspected to cause false
feelings of satiation (i.e., the "Pellets were
birds feel as if they have found in 13 out
may result in a decrease in sampled.
energy reserves and the
ability to survive adverse environmental conditions. Suspected
impacts on sea turtles, fish, and other aquatic life have been less
frequently reported and studied.
Although pellets may not be as aesthetically displeasing as other
items of debris, such as sewage and medical debris, the quanti-
ties present and the pellets' persistence in the environment are
cause for notice. One overseas investigator went so far as to
suggest that If high numbers of pellets continue to be deposited
on certain New Zealand beaches, someday people in that area
may be sunbathing on plastic-sand beaches instead of natural-
sand beaches.
THE PLASTICS INDUSTRY
The Society of the Plastics Industries, Inc. (SPI) has worked
with EPA to develop an understanding of operations within
the plastics industry and Identify potential sources of pellet losses
to the environment. SPI is the major national trade association
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of the plastics industry. Its membership consists of more than
2,000 companies that are responsible for approximately
75 percent of the $100 billion total sales of plastics and plastic
products in the United States. These companies supply raw
materials (e.g., pellets) and manufacture plastics and plastic
products for the plastics industry, in addition, SPI members
design, construct, and manufacture equipment and machinery
used by the plastics industry. EPA's recent study of plastic pellets
was completed with the voluntary cooperation and assistance of
SPI and seven companies in the plastics industry.
For the purposes of the study, the plastics industry was divided
into three major sectors.
• PGttet producers, which create the polymers, form the pellets,
and ship the pellets to contract packagers or processors.
• Peltet transporters/contract packagers, which are
intermediate pellet handlers. Transporters carry bulk ship-
ments between the industry sectors via railcars, bulk trucks,
and freight trucks. Contract packagers repackage bulk
shipments into smaller containers (e.g., bags and cardboard
boxes), which are shipped to processors.
• PoHet processors, which mold the pellets into user products.
To determine how pellets are released to the environment from
each of these three sectors, SPI arranged for each industry sector
to be visited by the study team. Seven companies (two produc-
ers, two transporters/contract packagers, and three processors)
were visited during the study.
STUDY FINDINGS
Several pellet release pathways were identified for each of the
three industry sectors described above. Most of the release
pathways were common to all three sectors, with only a few being
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unique to one or two sectors. The pathways may be categorized
into eight general areas where pellet releases are a problem.
7. Poor commun/coflon between industry management,
company management, and management of related
Industries (e.g., shipping industry). Not all company
managers have recognized the pellet problem and the need
to control pellet releases. Pellet spillage information, such
as the condition of packages and the receipt of unsealed rail
hopper cars, is shared between companies only occasionally.
2. Lack ot employee awareness and Inadequate training.
Employees are generally unaware of the environmental
effects of pellets and their own responsibility for controlling
pellet releases to the environ-
ment. For example, one major
release pathway is through
package damage caused by
improper operation of forklrfts
while moving pallets. Cargo
handlers may a] low pellets to
escape into the environment
because they are unaware of the
hazards of pellets.
3. Inadequate containment facffles and apparatuses.
Most companies have few or no cooling-, waste-, or storm-
water containment systems, including portable screens, in
place for controlling pellet releases to the environment.
Pellets that are present in these waters may be discharged
into municipal storm and sanitary sewers or into natural
drainage systems.
4. Careless routine operations. Whenever pellets are
handled, there is the potential for pellet spillage. Manual
pellet handling is more likely to result in spills than handling
by mechanical conveying systems (i.e., pneumatic systems
that move pellets by using air flowing through sealed pipes).
However, if pneumatic systems are not property maintained
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and closed, pellets may leak through openings in the
system. Pellets may also be released during the transfer of
damaged, unrepaired packaging,
5. Inadequate housekeeping practices. If pellets are not
quickly picked up after they are spilled, they may be scat-
tered and eventually released into the environment. Pellets
may be transported throughout interior and exterior areas of
a facility via shoes and clothing, vehicle tires, wind, and
stormwater runoff.
6. Easily damaged Of leaky packaging. Paper and card-
board packaging is easily damaged during transport and
handling and, in fact, may be designed to be easily broken
when loading molding machines. Damaged or teaky
packaging is a major source of pellet loss to the environ-
ment; valved, sett-sealing bags may not completely close,
thereby allowing pellets to leak from the opening.
7. Improper shipping practices. Improperly sealed rail
hopper car valves, poorly maintained transporting vessels,
and inappropriate cargo-handling practices may release
large numbers of pellets to the environment.
8. Lack of recycling. Some companies do not attempt to
recycle spilled pellets and, instead, dispose of the pellets
with other facility trash.
RECOMMENDATIONS
Existing Federal regulations provide a basis for controlling the
release of plastic materials, including plastic pellets, into the
aquatic environment. The recently revised National Pollutant
Discharge Elimination System permit program guidelines [40
CFR122,26(b)(12)] enable regulators and municipalities to impose
significant penalties on a company or sewage treatment plant
operator if pellets are present in its stormwater discharge in
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violation of its permit Although penalties alone will not
completely control the release of pellets, they can encourage
companies to Implement control measures. Ultimately, controlling
releases of plastic pellets into the aquatic environment is the
responsibility of the plastics industry.
In response to the early
findings of the pellet study and
ojher 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, SPI
initiated Operation Clean
Sweep, an industry-wide
education campaign aimed at
committing the plastics industry
to the total containment of
pellets. It is anticipated that
SPI and the industry will use
EPA's comprehensive study
along with campaign literature
and information to control
pellet releases from industry
sources to the aquatic environment.
Je:
Advertisement for the 1991 SPI
Operation Clean Sweep Campaign.
The release of pellets from pellet producers, transporters/contract
packagers, and processors can be controlled through actions
identified in the EPA study. Recommendations to the plastics
industry are the following:
• Adopt the SP11991 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
SPI's resin-producing members In response to the findings of
EPA studies. This code encourages source reduction activi-
ties to prevent releases, and suggests ways to recapture
spilled pellets.
D
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Educate employees and
train them to minimize
pallet spillage and loss.
Employees must recognize
their role in preventing
releases.
Install pellet containment
systems or use portable
containment apparatuses,
The use of inexpensive
portable screens or similar
devices can effectively control
pellets at the spill source.
Educate employees.
Institute pellet containment
activities during routine
plant operations. For example, cleaning pneumatic lines
into a portable screen before breaking connections will
minimize pellet loss through spillage.
• Recycle spilled pellets. By recy-
cling spilled pellets, the plastics
industry can recover revenue that
would have been lost by disposing of
them and can minimize pellet re-
leases to the environment during
trash disposal.
• Improve the quanty and fre-
quency of pellet spill dean-up
procedures. Frequent vacuuming and
broomsweeping collect pellets before
they escape into the environment.
• Use puncture-resistant packaging
and minimize the use of vatved
bags. The use of reinforced vaVetess
bags, such as polypropylene woven bags that are sewn shut, would
minimize pellet loss due to damaged or incompletely sealed packaging.
Recycle pellets.
10
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Inspect shipping vehicles (e.g., real hopper cars, bulk
trucks, freight trucks) before and after loading and
offloading of pellets. This action will prevent spillage from
leaking railcar and truck valves, and securing the valves with
tamper-resistant cable will discourage pellet loss due to vandaism.
Inspeci shipping containers before loading and after
offloading of pellets. Containers may be reseated or re-
paired before additional pellets are lost, and pellets may be
recovered instead of being released into the environment.
Inspect shipping vehicles.
Many of the recommended control mechanisms are currently
available and are being voluntarily implemented by some compa-
nies within the plastics industry. Most of the mechanisms, such as
employee education, portable screens, and improved housekeep-
ing, control pellet releases immediately at the source; these
mechanisms can be easily and inexpensively implemented.
Systems that direct spilled pellets into one containment area are
effective but are more expensive to implement.
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Environmental Inspection Checklist
Inspected by:
Date:
Time: Yes No
(1) Are all catch trays property placed under each shipping bay? Q Q
If no: How many are improperly placed?
How many are missing?
(2) Are bins properly placed under hopper cars being unloaded? [j| Q
If no: How many are improperly placed?
How many are missing?
(3) Are the screens over the drains dear of excess debris, Q Q
which could inhibit water flow?
(4) Is the roof dear of product? Q QJ
If no: Estimate amount of product on roof. Ib
(5) Are tracks free of pellets and/or powder?
If no: Identify location of any probtem(s).
(6) Are fences and drainage ditches free of plastic?
If no: Identify location of any problem(s).
(7) Is there any evidence of plastic being dumped into
trash compactors?
(8) Is all transfer equipment capable of keeping product from r"J r~j
spilling/being released into the environment?
If no: Identify equipment that requires attention.
(9) Are log books being maintained at each production line with
information about spills, actions taken, recommendations, etc.?
(10) Were any other potential problem areas identified during the [""] [~|
inspection? If yes: List specific problem areas.
Example of an Environmental Inspection Checklist developed to monitor
the effectiveness of routine maintenance procedures.
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