ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/1-77-004
Impact of Hyperion Wastewater
Treatment Plant Sludges
on the Marine Environment
he Draft Environmental Impact Statement,,
>geles Wastewater Facilities Plan,
Vo Iwne 3
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER, COLORADO
FEBRUARY 1977
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Environmental Protection Agency
Office of Enforcement
EPA-330/1-77-004
IMPACT OF HYPERION WASTEWATER TREATMENT PLANT
SLUDGES ON THE MARINE ENVIRONMENT
An NEIC review of the Draft Environmental Impact Statement,
City of Los Angeles Wastewater Facilities Plans
Volume 3
February 1977
National Enforcement Investigations Center
Denver, Colorado
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CONTENTS
INTRODUCTION .1
SUMMARY AND CONCLUSIONS 2
OVERALL ASSESSMENT OF THE EFFECTS
OF SLUDGE DISCHARGES OF THE MARINE
ENVIRONMENT 6
SPECIFIC COMMENTS ON THE DRAFT EIS . 15
REFERENCES 33
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INTRODUCTION
On December 27, 1976, the National Enforcement Investigations
Center (NEIC) received a request from the Director, Enforcement Division,
EPA Region IX for an evaluation of the impacts of sludge discharges from
the Hyperion Wastewater Treatment Plant (HTP) of the City of Los Angeles
on the marine environment. The request was two-fold:
1. Update a literature search previously prepared by NEIC for
Region IX regarding the marine impact of sludge discharges and
prepare an overall written assessment of these impacts; and
2. Review the draft Environmental Impact Statement (EIS), City of
Los Angeles Wastewater Facilities Plan, Volume 3, and prepare
a written assessment of its adequacy in dealing with the
marine impacts of the described project alternatives and the
adequacy of any conclusions drawn.
It became obvious in the early stages of the NEIC review of the
draft EIS that these items were interdependent and that information for
both could be developed concurrently. This review therefore incorporates
information to satisfy both items.
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SUMMARY AND CONCLUSIONS
Volume 3 of the draft EIS, City of Los Angeles Wastewater Facilities
Plan was reviewed by NEIC personnel with special emphasis placed on the
sections regarding the marine impacts of sludge discharge. Where appropriate,
select portions of Volumes 1, 2, 4 through 7, and the Executive Summary
of the draft EIS were also reviewed.
The majority of the data cited by the contractor in Volume 3 has
been assembled from research programs conducted by the Southern California
Coastal Water Research Project (SCCWRP). To independently evaluate the
cited data, NEIC reviewed numerous reports and technical papers published
by SCCWRP in recent years. A thorough literature review was also
conducted to obtain pertinent information regarding the effects of ocean
disposal of sludges in areas other than Southern California.
Based on this review of Volume 3 of the draft EIS and pertinent
technical literature, the following conclusions have been drawn regarding
the adequacy of Volume 3 and the practice of ocean discharge of sludge.
In general:
1. The contractor apparently has not utilized an unbiased approach
in the evaluation of available data and in the preparation of
Volume 3 of the draft EIS. Phraseology and visuals employed
throughout the volume are misleading and tend to depict a
favorable evaluation of current effluent and sludge disposal
practices at the HTP.
2. The contractor has formulated conclusions in this volume which
are based on a paucity of data. These conclusions are often
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in direct conflict with data or statements presented elsewhere
in the volume or in the published literature. The lack of
pertinent data makes it impossible to render a professional
technical judgement on the overall project assessment.
V
3. The contractor often dwells at length on obvious, well-known,
or relatively unimportant details while neglecting or under-
developing areas of acknowledged concern.
4. The contractor has referenced specific data within given data
sets to lend credence to discussions and conclusions made.
Other data within these data sets which do not conform with
the discussions and conclusions are ignored. Again, in order
to professionally judge the overall assessment of the project,
all relevant data must be considered.
5. The ultimate fate of heavy metals, chlorinated hydrocarbons,
and other potentially toxic substances contained in the sludge
discharged from the HTP is insufficiently evaluated.
There are considerable data in the literature to support a
hypothesis that a substantial portion of the toxic metals will
be entrained in the ocean waters on fine particulate matter
and ultimately dissolved into the water column. Once dissolved,
these metals are available for bio-accumulation in the food
chain.
6. There is no consistent trend throughout Volume 3 data evaluations
to allow a determination of the ultimate fate of sludge solids
discharged from the HTP 7-mile outfall and their effect on the
marine environment. In various sections of Volume 3, the
reader is alternately led to believe that the sludge
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a) "plunges" down a submarine canyon into a biologically inert
segment of the Southern California Bight; b) is carried to the
surface by buoyancy plumes and upwelling currents to provide
nutrients supportive of the California fishing industry;
c) settles rapidly in the immediate vicinity of the 7-mile
outfall, mixes with natural sediments, and remains inert
because of anoxic benthic conditions; d) settles rapidly in
the vicinity of the 7-mile outfall and is decomposed by
benthic organisms (in anoxic conditions?), or e) is dispersed
by natural currents throughout the Pacific Ocean.
7. The draft EIS inadequately evaluates the effects of the 5-
and 7-mile outfalls on the coliform bacteria concentrations
experienced in Santa Monica Bay. Very little data is given on
the actual ranges of coliform bacteria densities in the
effluents. Data pertaining to coliform bacteria concentrations
in the Bay water column are summarized only briefly in the
text or misleadingly presented in computer-derived isopleths
of concentration. The latter are terminated short of shore
contact so that the reader has insufficient data upon which to
evaluate the extent of coliform bacteria contamination.
Inaccurate conclusions have been reached in the EIS regarding
the survival rate of coliform organisms in the marine environment.
8. The draft EIS inadequately evaluates the extent of viral
contamination of the Bay from the 5- and 7-mile outfalls.
9. The entire section of Volume 3 devoted to "Biological Environment
and Artificial Impacts," Section II.D.3, which comprises some
172 pages, is very general in its presentation and contributes
little to the overall evaluation of the effects of the HTP on
the ecosystems of the Bay.
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10. Volume 3 neglects any discussion of the potential contributions
of the HTP outfalls to the development and propagation of
surface slicks within the Bay. There is significant published
literature available which correlates the existence of such
slicks with the HTP outfalls and establishes that such slicks
are effective concentrators of toxic substances and coliform
organisms. These surface films are often inadequately sampled
by conventional surface water sampling techniques. The films
have been shown to be transported shoreward by on-shore winds
and, as such, represent a potential health hazard.
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OVERALL ASSESSMENT OF THE EFFECTS
OF SLUDGE DISCHARGES ON THE MARINE ENVIRONMENT
ULTIMATE FATE OF SLUDGE DISCHARGES
The major problem associated with the ocean discharge of sludge
materials is that it is difficult to accurately determine the fate of
these materials in the hydrosphere. Sewage sludges are non-homogeneous
mixtures of solids and liquids, the solids having a range of particle
sizes from sub-micron colloidal material to macro-particles such as the
cigarette filters and Band-aids cited in the draft EIS (Vol. 3 p. II-
534). Sewage sludges discharged to the ocean generally have specific
gravities (as slurries) less than that of the receiving water and are
generally warmer than the body of water into which they are discharged.
Hence, the sludges tend to rise until mixing increases their density to
that of the receiving water.
A significant percentage of the heavy metals, chlorinated hydrocarbons,
and other potentially toxic substances which enter a treatment plant
ultimately accumulate in the sludge removed from the facility. The
percentage removal of these materials from the wastewater increases with
the degree of treatment applied to the wastewater.1 The majority of the
toxic materials present in sewage sludges have been shown to be associated
with the particulate fraction of the sludge.1'2'3'1*
The sludge parameters listed above are significant in the overall
evaluation of ocean discharge of these materials. Research conducted by
Chen et all on the particulate material contained in the sludges discharged
from the HTP 7-mile outfall indicates that the median size of particle
in this material is approximately lOpm. Research conducted by Rubey5
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indicates that the settling velocity of lOum quartz particles in distilled
water is approximately 3 x 10~2 cm/sec. This settling rate would be
considerably greater than the maximum rate for a sludge particle of this
size since sludge particles have a much lower specific gravity than
quartz and sea water has a greater density than distilled water. Both
of these factors would reduce the settling rate of lOym sludge particles
in sea water to substantially less than 3 x 10"2 cm/sec. Thus, any
upward movement of water greater than 3 x 10~2 cm/sec (0.05 ft/min)
would suspend the lOum and smaller particles and carry them toward the
thermocline or the surface.
These particles, once free of the plume buoyancy effects, would
settle to the bottom but at such a slow rate that they would remain in
the water column for several days, during which the heavy metals would
be going into solution.
The EIS and reports by SCCWRP question whether a significant number
of sludge particles would be incorporated into the sludge plume. It is
argued that a sewage sludge discharged on the ocean bottom at a substantial
depth through a submarine outfall will settle and accumulate in the
immediate vicinity of the outfall or tend to flow by density currents
down submarine canyon walls into deep, anoxic ocean canyons.
The upward velocity of fresh water when introduced into sea water
is considerably higher than the 3 x 10"2 cm/sec necessary to entrain a
significant fraction of the particulate component of a freshwater
sludge. This is evidenced both by the experience of divers in the
vicinity of fresh water outfalls in the sea, and the fact that when the
plume can reach the surface before its density is increased by mixing,
it actually "boils."
The above discussion supports the belief that, as a result of pi
buoyancy, the sludge particles rise toward the surface and, except for
ume
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the heavier components, settle to the bottom only after leaving the
ascending plume. Periodic upwelling currents from the deep canyons
would tend to reinforce these buoyancy effects and re-suspend sludge
materials which have managed to settle to the ocean floor. Sand falls
at the edges of submarine canyons would also tend to re-suspend the
sludge particles accumulated in the sediments by eddy action. The three
forces of plume buoyancy, upwelling currents and sand fall eddy action
are sufficient to suspend and re-suspend sludge particles in the ocean
waters.
The fact that sludge particles can be suspended i-n the ocean waters
is important; once they are dispersed in oxygenated waters, the toxic
materials associated with these particles are more readily available for
assimilation and biomagnification in the food chain. At least two
mechanisms are possible for this phenomenon: 1) direct use of the
sludge particles as food by marine biota, and 2) dissolution of the
toxic substances from the particles into the water column. It is the
latter mechanism which will be discussed in this report.
Heavy metals present in anaerobically digested sewage sludges are
in the reduced form, predominantly as insoluble metal sulfides.2'3
These sulfides are chemically inert materials when maintained in a
reducing environment such as in anoxic ocean sediments. However, the
metal-sulfide bond is reversible under oxidative conditions, resulting
in the formation of more soluble metal hydroxides. Research conducted
by Rohatgi and Chen2 on various sludges from the HTP considered the
leaching of metals from the sludge in oxygenated sea water. This work
has shown that the different heavy metals are released from the sludge
particles at varying rates under oxygenative, well-mixed conditions.
The data indicate a very rapid, initial leaching of some metals followed
by a slower but continuing dissolution. Such dissolution is especially
pronounced with respect to cadmium. The data indicate that approximately
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30% of the cadmium associated with sludge participate had dissolved into
the water phase within one hour. After five weeks of continued mixing,
about 95% of the cadmium had been dissolved. Zinc, nickel, lead, and
manganese demonstrated similar, though less dramatic,,dissolution
patterns. No data are presented by the authors on the behavior of
mercury. However, work by other researchers would indicate that mercury
should be similarly dissolved and/or methylated by sea water.
Rohatgi and Chen attribute the dissolution of heavy metals from
sludges to two possible causes:
1. The release of trace metals as bare ions as the result of
a) the oxidation of organic particles containing trace metals3
b) the oxidation of metal sulfides, and c) the surface desorption
of trace metals caused by high dilution ratio; and
2. Complexation of trace metals to form soluble complexes of
a) inorganic ligands such as Cl~3 and b) organic ligands, possibly
resulting from the oxidation of organic particulates.
Whatever the causative agent, the fact remains that heavy metals
such as Cd, Zn, Ni, and Hg will be solubilized from sludge particles in
oxygenated sea water, and, once solubilized, these metals are available
for assimilation by marine biota and biomagnification in the food chain.
Once in the food chain, these metals are potentially available to man.
The well publicized mercury and cadmium toxicity episodes in Japan, in
which numerous persons suffered specific physiological damage by eating
contaminated seafood, exemplify this potential problem area.6'7'8
Chlorinated hydrocarbons such as DDT and PCB's are also concentrated
in the solid fraction of sludges. It is well known that DDT is assimilated
and biomagnified by marine organisms and larger animals which prey upon
them. Irregularities in the eggshells, and, hence, the propagation of
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brown pelicans along the Southern California Coast has been directly
related to discharges of DDT into the waters of the Pacific Ocean.9
Although less is currently known about the ultimate fate of other
chlorinated hydrocarbons discharged into the aquatic environment,
evidence is rapidly accumulating that shows that PCB's and other highly
refractory chlorinated hydrocarbons are biomagnified in the aquatic food
chain.
Based on the discussions presented above, it is the NEIC opinion
that ocean disposal of sewage sludges should be prohibited for the
simple reason that there is no certain way to predict the ultimate fate
of known toxic substances contained in these sludges. Approximately
half of the toxic substances (by weight) contained in the discharges
from sewage treatment plants are contained in the sludges. These
materials are concentrated in a relatively small volume of material
which is amenable to other disposal practices. These alternatives
appear to be reversible, whereas ocean disposal is not.
DIRECT EFFECTS OF SLUDGE DISCHARGES ON AQUATIC COMMUNITY
Several investigations have been made concerning the direct effects
(as opposed to indirect effects such as biomagnification) of sludge
discharges on the aquatic community near these discharges.!0,11,12,13
It is generally accepted that benthic communities are altered by the
presence of sludge deposits near these discharge sites. Total biomass
has been noted to be enhanced in the immediate areas of the discharge
points, po.ssibly due to the large amounts of nutrients contained in the
sludge materials. However, species diversity is generally low with a
shift in pbpulations toward the more pollution-tolerant species, such as
polychaete worms, in the immediate discharge areas.
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Laboratory and field research has been conducted in an attempt to
determine the direct effects of specific materials contained in sludges
on various marine organisms.14!15 Samples of marine organisms from
sludge disposal areas and control areas have also been collected and
analyzed to determine if correlations could be made between sediment
contents and organism contents and/or organism irregularities.16»17»18
One such research project, conducted by SCCWRP personnel,16 implied
that fin erosion in the Dover sole is related to sludge discharges
although the exact mechanism of this effect is not clearly understood.
To date, research efforts have not proven conclusively that sludge
discharges have direct adverse effects on the marine community. This
type of cause and effect relationship is quite difficult to prove,
especially in a complex environment such as the marine community.
Potential synergistic effects of various substances are often impossible
to duplicate in the laboratory. The mobility of various organisms
compound the site-specific correlation problems. Environmental differences,
i.e. depth, temperature, current patterns, as well as variations in
sludge compositions hinder comparisons of data obtained from aquatic
environments which are widely separated geographically.
CONTRIBUTION OF OCEAN OUTFALLS TO SURFACE SLICKS
An important phenomenon associated with ocean outfalls, and one
which was totally ignored in the draft EIS, is that of the formation of
microlayers', i.e. slicks and films, on the ocean surface in the vicinity
of these outfalls. These slicks tend to concentrate coliform bacteria
and other organisms as well as toxic substances related to the materials
discharged at the outfalls. The slicks also form a protective environment
which supports the growth and reproduction of these organisms. The
slicks are then transferred shoreward by on-shore winds and potentially
pose a direct health hazard.
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Surface films in the marine environment were first found to be
effective concentrators of the persistent chlorinated pesticides and, as
such, could indicate the presence of pesticides when they were below
detectable levels in the surrounding water. Because of the high biological
^
activity associated with slicks and their occurrence 'throughout the
oceans, these findings were of considerable importance to the under-
standing of the distribution of pesticides in the marine ecosphere.
This research was supported by the Federal Water Pollution Control
Administration under Grant DIWP 0132601 and was published by Seba and
Corcoran.19
This and other investigations led to the recommendation by the
National Academy of Sciences - National Academy of Engineering20 -
that surface materials of municipal wastewater origin from marine
outfalls should be investigated. Their report noted that submerged
sewage plumes provided fleatables and surface films even though there
was no visual evidence that the plume was reaching the surface.
The Agency responded to this recommendation in several ways, including
two studies on HTP.21'22 It is not necessary to discuss in detail the
findings of these studies as the interim and final reports are available.
The essence of this work can be found in Paper No. 15 by Selleck in the
book, "Discharge of Sewage from Sea Outfalls."23 Selleck reported that
samples of floatables and surface films collected by a variety of
techniques over a three-year period always showed that materials from
the submerged HTP outfalls were reaching the surface, that they were
always contaminated with coliform bacteria, and that the median coliform
bacteria count varied from 3,000 to 150,000/m2.
During this same time, the Agency co-sponsored a dissertation at
the University of California at Berkeley by Ralf C. Carter.2" Carter
tagged surface films formed by the HTP discharges with dye, corn oil and
plastic pellets, and he was able to determine that these coliform-laden
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films moved toward the shore of Santa Monica Bay, sometimes even counter
to the wind. In the cases of both Selleck and Carter, all pollution
parameters were usually orders of magnitude higher around the HTP
outfalls than in control areas.
Another project by Harvey25 provides additional information on the
topic of surface films. In this study, the Island of Oahu, Hawaii was
thought to offer a nearly ideal location for the investigation of micro-
layer e;cology because there appeared to be very heavy organic pollution
near shore, but the world's cleanest ocean water just a few miles off
shore. The exact study site was Kaneohe Bay and Keehi Lagoon. Kaneohe
Bay, a large bay on the windward side of Oahu, is protected by extensive
coral reefs. Some of the reefs are relatively healthy but those toward
the east are either dead or dying from the effects of the high pollution
level. Keehi Lagoon is a heavily polluted lagoon connected by narrow
channels to Kaneohe Bay.
Samples taken directly from the film were more than 1,000 times as
high in bacteria and other pollution indicators (i.e. two marine micro-
organisms, a polymorphic flagellate, and a smaller colorless flagellate,
Rhynchomonas nasuta, that had been encountered in important numbers in
the polluted sea surface water off San Diego, California) as indicated
by standard surface sampling methods. It was discovered that the
prevailing wind sweeps the surface microlayer toward the shore at a
speed roughly proportional to wind velocity. The particulate matter in
the microlayer can become very concentrated downwind while the concen-
trations can decrease upwind.
EPA recently funded research26 on the water of Narragansett Bay,
Rhode Island. Lead, iron, nickel, copper, fatty acids, hydrocarbons,
and chlorinated hydrocarbons were found to be concentrated from 1.5 to
5° times in the top 100 to ISOvjm of Narragansett Bay waters, relative to
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the bulk water 20 cm below the surface. It was noted that the actual
concen',tration factor in many cases may well be greater than four orders
of magnitude, resulting in extremely high localized pollutant concentrations
in the surface microlayer.
Woodcock22 found that high concentrations of sea surface organisms
in the air were most likely the causative factor in human respiratory
irritation. Higgins28, following up on this finding, collected the
aerosol produced by bubbling air through sea water that contained
several, species of bacteria. The ratios of the recoveries of some of
the bacteria were higher than expected. Finally, Blanchard and Syydek29
were able to explain both conditions by demonstrating that air bubbles,
such as those produced in surf, would remove bacteria that concentrated
in surface film and, depending on bubble size, further increase the
bacterial concentration from one to three orders of magnitude.
In summary, the Agency has sponsored five diverse investigations
and there have been several other competent field studies, all of which
have shown that coliform bacteria do collect on the surface above
submerged outfalls, including HTP, and may represent a serious health
hazard.
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SPECIFIC COMMENTS ON THE DRAFT EIS
The following is a compilation of the NEIC comments on Volume 3
of the draft EIS, City of Los Angeles Wastewater Facilities Plan. The
comments are referenced to specific pages of Volume 3.
11-483, last paragraph - The statement that The Hyperion sludge
line discharges into this canyon (the submerged Santa Monica Canyon)
should be rephrased. This statement is misleading in that the
sludge line terminates near the edge of the canyon but the sludge,
which is at a density less than the density of sea water, tends to
rise to the thermocline or to the surface. Many of the suspended
slildge particles will be entrained in this rising plume and carried
upward into the overlying ocean. Thus, the statement could better
be made, Sludge is discharged into the Pacific Ocean at a position
near the edge of the submarine Santa Monica Canyon.
11-483, last paragraph - The use of the word plunges in the
sentence The head of the Santa Monica Canyon originates about 4-1/2
nautical miles southwest of Santa Monica and plunges almost due
west to a depth of 2,400 feet is misleading and sets an early tone
to the EIS that sludge discharged at the edge of this canyon slides
down the canyon to the anoxic depths of the Southern California Bight.
This theme is reinforced repeatedly in this volume. Examination of
submarine topography at the sludge discharge site on Figure II-D-2,
page 11-485 and Figure 11-21, page 11-536 indicates that the slope
of the Santa Monica Canyon is between 5 and 12% at the discharge
site (variation due to inaccuracies in locating the end of the
discharge pipe on these figures). It is questionable that 5 to 12%
slope's are accurately defined as plunging. The word "plunge"
should be eliminated from this sentence and elsewhere in the-EIS
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where it is used to describe the slope of these submarine canyons
or the action of the sludge as it is discharged from the outfall.
11-485, Figure II-D-2 - No legend is given to indicate the units of
N
water depth (assumed to be in fathoms). This deficiency occurs
wherever various overlays are used on this base map (e.g., Figure
II-D-3, p. 11-488, Figure II-D-4, p. 11-489, etc.).
11-490. first paragraph - Statements made here relative to the
mining of discharged materials throughout the Pacific Ocean by the
principle of advection highlight a very good reason to limit,
wherever practicable, the discharge of known toxic, bio-accumulated
materials such as mercury, cadmium, and chlorinated hydrocarbons.
11-490, last paragraph and 11-492. first full paragraph - The
occurrence of upwelling of deep ocean waters to the surface of
Santa Monica Bay is mentioned here. The fact that upwellings do
frequently occur in this area is indirectly confirmed by the
presence of phosphorite nodules in the sediments of the Santa
Monica Bay area. The presence of phosphorite is also indicative of
phos.phate supersaturation in these waters.
The occurrence of upwelling would tend to move suspended sediment
particles upward in the water column, increasing the residence time
of suspended sludge particles entrained in the rising sludge plume.
As discussed in a previous section, research by Rohatgi and Chen2
has shown that residence time has a material effect on the amount
of heavy metals solubilized from the sludge particles.
11-490 to 11-492. general - The discussion of thermocline stagnation
and upwelling in this section appears to be incomplete in that
there is very little mention of density buoyancy effects. Such
effects have probably been studied in greater detail. The theoretical
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literature indicates that the liquid portion, together with entrained
sludge particles, should rise a majority of the time.
11-494. first paragraph - The discussion implies^that wastewater
particles can be expected to be incorporated within sediments and
work their way to the deeper ocean by density currents. While it
is true that particles of glaucophane schist and phosphorite, etc.,
have a specific gravity considerably greater than that of ocean
water and tend to move as density currents, it is not true that the
lighter, flocculant sludge particles would be incorporated and
moved with the natural sediments. Assuming that there were a
downslope density current movement of particles, sand falls at the
edge of submarine canyons would probably result in sludge suspension,
allowing additional chance for leaching toxics from the sludge
sediments. This discussion ignores the problems of the buoyancy of
the liquid portion of the sludge discharge.
11-495. last paragraph - The dissolved oxygen of waters above 60
meters in depth is stated as being consistently greater than 4
mg/1. At depths of 300 to 700 meters, the DO is as low as 0.7
mg/1. Data probably exist on the dissolved oxygen concentrations
at a'nd slightly above the point of discharge of the 7-mile sludge
outfall. Much more water quality data on the overlying water
colutnn should be included. As has been discussed previously, the
dissolved oxygen in the overlying water column has an effect on the
amount of heavy metals solubilized from suspended sludge particles.
11-497, first paragraph - The discussion of heavy metal concen-
trations found in the waters of the area, as with that of other
water column data, is very limited. Also, no mention is made of
cadmium concentrations in these waters.
11-505 through 11-519 - The methods used in summarizing and presenting
data relevant to the Hyperion effluents are incomplete, misleading,
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and disjointed due to the interspersing of numerous tables, graphs
a'nd figures. Tabular summaries of effluent data appear to give
equal weight to all parameters at all effluent locations. No
thorough evaluation of the quality of this data is given. No
mention is made of the frequency of sampling for the individual
parameters and the potential for misinterpretation of "average"
values due to the sampling frequency. No discussion is given of
the range and statistical distribution of the data experienced at
these facilities. The text suggests that the marine environment
experiences the effects of the average concentrations of the
various substances in the discharges rather than the actual ranges
of concentrations.
In general, the text on these pages centers around the contributions
of the HTP discharges to the Southern California Bight relative to
other municipal discharges rather than their absolute contributions
to the Santa Monica Bay area. Since this EIS is specific to the
HTP situation, a much more thorough evaluation of the effluent
monitoring data is required.
L
11-510, Table II-D-4 - The present cadmium concentration of 1.27
mg/1 in the sludge would doubtlessly exceed the toxics standards
(Sec. 307, P.L. 92-500), when such standards are published. Upon
publication of the toxics standards (which may include prohibition
of discharge) the discharger will have up to one year to meet the
standards. The same would hold true for the present discharge of
0.15 mg/1 of mercury. Were this discharge to be from any industrial
activity, it would have been discontinued years ago under enforcement
actipns against the industrial dischargers.
11-511, Table II-D-5 - It is noted that the Hyperion sludge outfall
contains 47% of the total cadmium discharged by the Hyperion plant.
Similarly, the sludge contains 50% of the chromium, 50% of the
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copper, 39% of the mercury, and 58% of the zinc contained in the
total Hyperion discharge. This percentage of total toxic metals
loading can be kept out of the ocean and, hence, the potential for
bio-accumulation and harmful effects on man can be avoided.
II.-513 to 11-517 - The discussion of coliform bacteria in the 5-
an'd 7-mile outfall effluents and related concentrations in the
wa^er column near these outfalls is incomplete. The discussion of
Salmonella vs coliform bacteria concentrations is quite confusing.
Again, sampling frequencies are not discussed. Although mention is
made of Salmonella being found in the water column near the outfalls,
no specific information is given for the sampling location and
depth, nor the coliform bacteria concentrations found in these
samples.
11-517 to 11-524 - Here the report notes that the liquid portion of
the plume from the 7-mile outfall does rise into the ocean due to
salinity and temperature differences. Such a rising plume would
entrain much of the finer portion of the sludge solids, leaving
behind the "Band-Aids and cigarette filters" which are noted to
comprise the sludge deposit.
In view of the bacterial mortality noted on p. 11-521 and the lack
of surface slick sampling, the use of bacteria as an indicator of
plume rise is not entirely suitable. Other parameters should be
used to supplement these investigations. Data should have been
collected on zinc, cadmium and mercury in the water column. In the
absence of such data, turbidity, temperature, and dissolved oxygen
data should show, indirectly, the plume rise. The present use of
bacteria tends to underestimate the extent of plume rise and
spread.
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The bulk of this section is devoted to the discussion of dispersion
of the plume from the 5-mile HTP outfall utilizing coliform organisms
as tracers. Coliform bacteria data from a sampling grid in Santa
Monica Bay are used to develop computer-derived isopleths of
coliform bacteria concentrations at the surface and at 15- and 43-
meter depths. Again, no discussion is given of sampling techniques
or» the statistical variability of the data used. It is interesting
to note that the isopleths of Figure II-D-16 suggest that no
coliform bacteria discharged from the 7-mile sludge outfall. This
contradicts the statement of page 11-517 that coliform bacteria
counts in the sludge range from 21 to 60 x 106 MPN/100 ml. Thus,
one may conclude that no coliform bacteria from the 7-mile sludge
outfall ever reach even the 140-foot depth. It is also interesting
to note that the coliform bacteria isopleths, as computer projected,
often stop short of shore or bottom contact. It is thus impossible
for the reader to accurately evaluate the extent of coliform bacteria
pollution from these outfalls. Lastly, no units are given for the
coliform bacteria densities plotted in Figures II-D-15 and II-D-16.
II-.521, last paragraph - The discussion of bacterial die-off in sea
water is quite misleading, and the reference cited (Vind, et al,
1975)30 is not necessarily relevant to the HTP situation.
A brief study, based on six surface samples, in which Bact-Chek
disks of E. Coli. were sealed in polyethylene bottles or dialyzer
bags is described in Vind's work. The samples were charged with
autoclaved, filtered seawater, and suspended from weighted floats
at various depths in Santa Monica Bay. E. Coli. growth was less at
the surface stations (more or less depending on wave height). Such
conditions as these bear little resemblance to the HTP outfalls.
In any case, it is common knowledge among professionals in oceanic
microbiology that coliform bacteria mortality rate increases with
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21
increasing hydrostatic pressure (depth) in direct contrast to
Vind's results.31'32
On the other hand, there is much in the recent literature by many
competent researchers showing the occurrence of coliform bacteria
in surface waters. A discussion of coliform bacteria in surface
slicks has been thoroughly discussed in a previous section.
11-524, last full paragraph - The information concerning virus
i
concentrations in the environment near the HTP outfalls is incorrect.
Morris, Mearns, and Kim33 devote an entire chapter in the 1976
SCCWRP annual report to the research work they have conducted on
viruses discharged from the HTP outfalls. They found that HTP
discharged more than 10 plaque-forming units per day, that the
ratio of virus to coliform bacteria was 1 virus per 15 million
coil i form bacteria, that these viruses survived three to six times
longer than the bacteria and that they were readily taken up by
shellfish artificially suspended in the water column in the vicinity
of HTP outfalls.
11-524 last paragraph and 11-525 - The constituents of the 7-mile
outfall effluent as discussed here are not entirely accurate. It
is .stated that the effluent consists of 27% anaerobically digested
sludge, 21% waste activated sludge and 52% secondary effluent.
Aerobic digestion of waste activated sludge is practiced at the HTP
as documented in the NEIC report on compliance monitoring conducted
at the HTP in February 197531*, and recent conversations with HTP
personnel.35 The waste activated sludge can be recycled to the
primary sedimentation tanks and/or sent to the aerobic digesters,
depending on the selected plant operating mode. There is sufficient
aerobic digester capacity at the HTP to accommodate all of the
waste activated sludge.
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22
It should be noted that the HTP aerobic digestion capabilities are
not mentioned anywhere in the draft EIS.
It is important to understand that the waste activated sludge can
be aerobically digested rather than anaerobically digested along
with primary sludge as is indicated in the draft EIS. The method
of digestion may significantly alter the chemical nature of the
heavy metals available in the sludge. Specifically, cadmium and
zinc may be converted to relatively soluble hydroxides in aerobic,
oxidizing environments rather than the insoluble sulfides which
would be formed in anaerobic, reducing environments.
In the research conducted by Chen, et all on the various effluents
at the HTP, it was shown that between 30 and 64% of the total
cadmium and between 44 and 75% of the total zinc available in the
primary effluent were removed by secondary treatment. However,
when the dissolved concentrations of these metals in the primary
effliuent were compared with similar data in the secondary effluent,
it was found that the dissolved fractions for cadmium had increased
by between 90 and 230% and for zinc by between 64 and 130%. The
aerobic activated sludge process apparently solubilized a portion
of the cadmium and zinc associated with the particulate matter in
the primary effluent. Although Chen et all did not evaluate metals
solubilization in the HTP aerobic digesters, it is reasonable to
assume that further solubilization of metals from the waste activated
sludge occurs in these units. It is also reasonable to deduce that
the mixture of 27% anaerobically digested sludge, 21% aerobically
digested sludge, and 52% secondary effluent discharged through the
7-mile outfall will contain soluble heavy metal species such as
hydroxides as well as the insoluble sulfide species. This point
should be addressed in the draft EIS.
11-525 - The text on this page ends abruptly after three lines and
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23
in mid-sentence. It is not certain whether the text follows naturally
on page 11-527. If not, significant information pertaining to the
sludge constituents may be missing.
II.-527 - In the first paragraph the statement is made that The
liquid fraction (of the sludge)3 being warmer and less dense than
the surrounding sea water, undoubtedly rises in a plume in a manner
similar to the plume from the 5-mile outfall. The text continues
There have been no measurements that have indicated the disposition
and dilution of the plume3 however. This has two possible implications.
Have no measurements been taken, or have measurements which have
bee(n taken not indicated the disposition and dilution? This lack
of plume disposition information is the greatest weakness within
the available data reported and is the reason for considerable
doubt as to the disposition of much of the toxics present in the
effluent. Many of the finer suspended solid particles in the
sludge outfall would be entrained in the rising plume and would
remain in suspension throughout the plume rise, either to the
surface or the thermocline. No data are presented on specific
gravity, size distribution or settling rates of the sludge particles.
However, information does exist on this subject through work done
by Chen et aZ1. Data are presented on the size distribution and
metals concentrations in particles in the HTP primary and secondary
effluents and in the centrate from sludge centrifugtation. These
data indicate that more than 80% of all of the metals in the sludge
is attached to particles. It appears that the median size distribution
of the particles would be approximately 10pm. As discussed thoroughly
in a previous section, sludge particles of this size would settle
at slow rates and be easily affected by upward currents.
The last sentence of this paragraph ignores the effects of plume
buoyancy on fine sludge particles.
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24
The questions posed in the third paragraph on this page are pertinent
to the subject at hand. Unfortunately, the data presented in
subsequent pages of the EIS do not adequately answer these questions.
11-529 through 11-535 - Considerable text and graphic space are
devoted to the discussion of a series of single grab samples of
sediment obtained by SCCWRP from a 400-meter grid near the 7-mile
outfall. Concentration isopleths are computer drawn for various
sediment constituents such as the various heavy metals and volatile
solids [Figure II-D-20]. The contractor concludes from these
samples that Apparently the heavier grit and sand settles out near
the outfall, and the organic fraction floats out to between 700 and
13000 meters from the outfall before settling (11-534). The items
described as being present in the bottom and visible in
samples represent a very small portion of the total sludge, the
heavier portion. While it is true that this heavier portion might
set;tle to the bottom, the bulk of the sludge would tend to be
entrained in the rising sediment plume.
The computer isopleths of Figure II-D-20 tend to show sludge movement
and subsequent settling to the northwest from the discharge point.
This is consistent with previously cited ocean current data but is
perpendicular to the direction of movement which would result from
density current movements along the sloping bottom topography.
This is further evidence that sludge movement results from entrainment,
suspension and slow settling rather than from density current
movement.
In general, the computer-generated plots of concentration isopleths
in Figure II-D-20, as well as others on pages 11-537, 539 and 540,
are Difficult to interpret. Green numbers are difficult to read on
a shaded green background. Also, figure captions are typed over
data indices, making the latter indiscernible.
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25
The contractor accurately evaluates the accuracy of the data discussed
in these pages when, on page 11-529, he states that Because of the
tack of replicate samples and the large differences in concentration
of substances between sampling stations, the density gradients
displayed in Figures II-D-18, 19, and 20 should not necessarily be
c'onsidered accurate representations of the distribution of sludge
in the sediments. It should be noted that in the Summary of Findings
section of the 1976 SCCWRP annual report, the following discussion
pertaining to the 400 meter grid sampling program discussed in the
EIS appears: At three stations in the center of the sludge area,
the bottom materials smelled strongly of hydrogen sulfide, and the
metal and volatile solids levels were high. (On a trip in August
1976 this area seemed to have disappeared.) The full importance of
the latter statement is unknown at this point. It does, however,
emphasize that additional sampling and data analysis are required
before substantial conclusions regarding the 400 m. grid stations
can be reached.
11-551, first paragraph - Several statements recognize the importance
of re-suspension and, hence, indirectly admit the low specific
gravity of sludge. Such statements further argue for entrainment,
suspension, and movement of sludge particles by current action.
H-,551 and 552 - The discussions presented here allude briefly to
the problems of the remote sampling of sludge deposits. Actually,
the entire discussion is much too optimistic of the capabilities of
remote sampling of sludge, especially an extremely flocculant or
organic sludge such as this. Work by the NEIC and by other
diving samplers has shown that the conventional remote sampling
techniques are not adequate for representative sampling of organic
sludges. The shock waves from the lowering sampler are sufficient
to move much of the lighter fraction of the sludge before the
sampler reaches the bottom. Any attempt at mass balance based on
this1data is subject to great error.
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26
11-554 to 11-556 - The mass balance discussed in these pages, which
indicates an accountability of approximately 70% of the metals ever
discharged from the 7-mile outfall, is based on sediment trap data.
However, problems of re-suspension and secondary^trapping of sludge
by use of sediment traps were previously admitted. Re-suspension
and subsequent multiple counting tends to result in a higher percentage
of load accountability than is correct. Again, there are numerous
problems relative to attempting to core sample flocculant organic
sludges at this depth. The credibility of the presented mass
balance conclusions is thus suspect.
11-556, first and second full paragraphs - This discussion recognizes
the importance of sediment size distribution; however, in view of
suah importance, the absence of data is questionable. As was
previously discussed, many of the sediment particles could easily
be entrained and suspended for a period of several days, with
subsequent oxidation and leaching of metal sulfide particles.
11-657 to 11-563 - The entire discussion contained in these pages
on the statistical correlations of concentrations of substances in
the 7-mile sludge effluent and the sediment samples obtained near
the effluent outfall is muddled and convoluted. The contractor has
used assumptions without justifications and has apparently manipulated
the raw effluent and sediment data to obtain the correlations
desired. An apparent problem area in the data which could not be
explained was the PCB and DDT concentration discrepancies shown in
Table II-D-13, p. 11-559. As a result, these data are not further
discussed in these pages.
Thisientire discussion should be objectively revised and expanded,
or should be eliminated from the EIS.
I1-563 to 565 - The discussions in the subsection "Summary of
Chemical and Physical Inputs from HTP" contained in these pages are
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27
superficial and contain several statements which can be misconstrued
by the reader. Examples follow.
The term "settleable solids" in the second and tlVird paragraphs of
page 11-563, though technically correct, is used to imply that the
sludge consists of particles which settle rapidly under actual
conditions at the 7-mile outfall. The settleable solids data
quoted are obtained under laboratory conditions in quiescent water
columns or cones. Data obtained under these conditions cannot be
extrapolated to the buoyancy plume conditions experienced at the 7-
mile outfall.
The last paragraph on page 11-563 admits that more sediment core
data from the 7-mile outfall area are required (it could be argued,
not only more data but more accurate data are required). The last
sentence restates a highly questionable conclusion pertaining to
the accountability of the total sludge mass discharged from the
outfall, ... but a preliminary calculation indicates that a substantial
percentage of the settleable sediments from the 7-mile outfall may
still be in its vicinity.
The data on the graph on page 11-564 are not legible and, hence,
the graph is useless to the discussions.
11-565 - In the first paragraph, the statement is made: Conversely3
data from sediment traps suggests that much of the particulate-
ass'ociated metals may be transported out of the vicinity of the
outfall. As has previously been stated, such a conclusion would be
obvious based on the rising sludge plume and the subsequent entrainment
of the metal-bearing particulates.
The third paragraph on page 11-565 briefly summarizes the inadequacies
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28
of several data bases collected to date on the effects of the HTP
o'utfalls. These inadequacies are ample reason to suspend sludge
discharge from the 7-mile outfall and to seriously question the
effects of the effluent from the 5-mile outfall.
11-587. Table II-D-25 - It is very doubtful that all constituents
are the same in both the Dominguez Channel and Los Angeles River
Basins. Rather, it appears that the data indicate only the detectable
level in the runoff or that the data have been incorrectly entered
in the table.
11-592 through 11-764 - The report subsection "Biological Environment
and Artificial Impacts" is contained in these pages. The information
presented in this subsection is highly generalized and could be
us,ed for an EIS pertaining to any wastewater discharger to the
Southern California Bight. Data which are site-specific to the HTP
ou.tfalls and, for that matter, to the Santa Monica Bay in general,
are very sparse and diluted by the mass of general, non-specific
information presented.
Pages 11-759 to 11-764 contain a good synopsis of the adequacy (or
inadequacy) of existing data relevant to the effects of HTP effluents
on the marine environment. Inadequacies in sampling techniques,
laboratory analytical procedures, and taxinomic procedures are
highlighted. These pages should be closely scrutinized before the
reader even starts reading Volume 3. These pages should also be
emphasized in the EIS Executive Summary Volume.
11-594 to 11-595 - These pages address the bioaccumulation of
toxicants in the food chain and acknowledge the potential hazards
of this mechanism to man. There are, however, no data available to
examine biomagnification routes in the Santa Monica Bay.
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29
11-601, first full Paragraph - The statement is made that: Many of
the constituents of HTP sludge and wastewater effluent are released
in concentrations sufficiently great to have direct toxic effects
on marine organisms. If this is true, the data should be carefully
evaluated. The reader is directed to Table II-D-31 which reportedly
summarizes the effects of these constituents on invertebrates.
Table II-D-31 is subsequently referenced repeatedly for the next 93
pages. However, on page 11-602 the reader is told that Tabular
data for this table (Table II-D-31) is not available for this
issue - to be supplied at a later date. Without this table being
completed, it is impossible to evaluate the effects of the HTP
outfalls on certain marine organisms (plankton, benthic organisms,
nektonic invertebrates, etc.)
11-685 and 11-686 - Figures II-D-66 and II-D-67 were not in the
Volume 3 reviewed by NEIC. As a result, no comments can be made
regarding research conducted by SCCWRP on the uptake of PCB and DDT
by mussels.
II.-692, first Paragraph - The discussion here states that biological
uptake of heavy metals in benthos appears to be related to metals
dissolved or suspended in the water column. If this is true, then
why hasn't the problem of plume buoyancy been addressed and water
column data developed?
11-695, first paragraph - Discussions here indicate that constituents
in the HTP effluents are available in the effluents in concentrations
which are known to be detrimental to certain marine organisms.
Again, Table II-D-31 would be helpful here.
11-717 - Discussions here estimate the current impact of the marine
spo'rt fishery to be 12 million angler days for the entire state of
California. The contractor then multiplies this number by $2 to
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30
arrive at a sport value of $24 million for the state fishery. Yet
fable II-D-52 shows 2,875,000 angler days in 1970 for Los Angeles
County alone with an estimated value of $35,166,000. The Sport
Fishing Institute has studied this subject in depth for years but
n,o references are made to their competent work. -^A value of several
thousand dollars per acre could be assigned to Santa Monica Bay
(Sullivan, 1973)36 for sport fishery alone. Of course, other
recreational uses of water such as swimming, diving, boating,
skiing, picnicing, etc., add considerably to this average value.
When water becomes polluted, virtually all these values are destroyed,
but no such question is raised in these discussions.
11-721 to 11-732 - An extensive discussion is given herein on the
positive influences of the HTP outfalls on the stimulation of the
fishing industry of the Southern California Bight. A similar in-
depth discussion of the biomagm'fication of toxic substances would
balance this presentation.
11-765 through 11-779 - A synopsis of the conclusions developed in
Volume 3 is presented. Discrepancies in several of the conclusions
originally stated in the main text of the Volume are carried through
to this summary. However, in the summary, the reader is not privy
to data summaries, visuals, and text continuity with which to make
independent evaluations of the stated conclusions. Particularly
disturbing areas in this summary are as follows:
11-765, second paragraph - use of coliform bacteria data to
determine extent of plume travel with repeat of computer-
derived isopleths (Figure I-G-10) of coliform bacteria concen-
trations. The limitations of these items has been previously
discussed.
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31
11-767, first paragraph - discussion of sludge dispersion from
7-mile outfall. No mention of plume buoyancy and related
effects.
11-767. second paragraph - a repeat of conclusions based on
the single sample, 400-meter grid sampling program conducted
by SCCWRP in early 1976. Suggests that discharged sludge
stays near the 7-mile outfall.
11-772, second paragraph - analogy used to compare the pre-
ponderance of pollution-tolerant species noted near sludge
outfall with weeds found near roadsides is interesting, but
its relevance is questionable. Contractor continues in next
paragraph with discussion of aesthetics of environment near
outfall. Aesthetics may be minor problem compared to the
potential for bioaccumulation of toxic materials in these
pollution-tolerant species.
11-775, first paragraph - problem with Vind reference as
stated previously in this review.
11-775, last paragraph - Conclusion disregards significant
literature on surface slicks. Also, conclusion that viruses
reach shore in low concentrations is not supported by data.
11-776, third and fourth paragraphs - discussions concern only
fish caught near 5-mile outfall, not 7-mile outfall. Also, no
mention of statistical validity of fish data obtained.
11-777 through 11-779 - a repeat of extensive discussion of
beneficial effects of upwelling of nutrients without balancing
discussion of plume rise of heavy-metal-laden sludge particles.
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32
this entire summary section (11-765 to 11-779) is included verbatim
in the Executive Summary volume of the draft EIS. The discrepancies in
the conclusions noted here would be even more misleading to a reader who
has not been privy to a thorough review of Volume 3. -The reader would
thus be inclined to view the continued discharge of sludge to Santa
Monica Bay as a favorable alternative to the sludge disposal problem.
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