United States       EPA 842-S-93-001
Environmental Protection   August 1993
Office Of Water
       Pellets In The
Aquatic Environment
Sources And

A 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, 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,

 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.

    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


     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

 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

 •  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

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.

 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 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

 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.

    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

 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

      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.

    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

 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.
  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.

        Educate employees and
        train them to minimize
        pallet spillage and loss.
        Employees must recognize
        their role in preventing

        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.

     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.

                Environmental Inspection Checklist
Inspected by:	
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.