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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                                                                   8
 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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                                                                   10
 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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                                                                   11
      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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                                                                   12
      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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                                                                   14
 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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                                                                16
 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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                                                              17
 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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                                                              18
 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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                                                              19
 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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                                                              20
 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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                              REFERENCES
1.   Chen, K.  Y., C.  S.  Young, T.  K.  Jan, and N.  Rohatgi,  1974.   Trace
     Metals in Wastewater Effluents,  Jour. Water Poll.  Cont.  Fed., 46,
     p. 2,663.

2.   Rohatgi,  N. and K.  Chen, 1975.  Transport of Trace Metals by Suspended
     ^articulates on Mixing with Seawater,  Jour. Water Poll. Cont.
     Fed., 47, p. 2,298.

3.   Morel, F. M. M., J. C. Westall,  C. R. O'Melia, and J. J. Morqan,
     1975.  Fate of Trace Metals in Los Angeles County Wasteaater
     discharge.  Environ. Sci. Technol., 9, p. 756.

4.   Mitchell, F. K., 1974.  Evaluating the Impact of Sludge Discharge
     to Santa Monica Bay, California.  Proceedings of research symposium,
     ''Pretreatment and Ultimate Disposal of Wastewater Solids," Rutgers
     University, May 21  and 22, p. 417.

5.   Rubey, W. W., 1933.  Settling Velocities of Gravel,  Sand, and Silt
     Particles.  Amer. Jour. Science, 25, p. 325.

6.   Kurland,  L. T. et al, 1960.  Minamata Disease, World Neurol., 1, p.
     379.

7.   Irukayama, K., 1967.  The Pollution of Minamata Bay and Minamata
     Disease.   Advances  in Water Pollution Research, Proc. 3rd Intl.
     Conf. Water Poll. Res. Water Poll. Cont. Fed., Washington, D.C., 3,
     p. 153.

8.   Tsuchiya, K., 1969.  Causation of Ouch-Ouch Disease (Itai-Itai
     Byo) -  An Introductory Review.   Part 1 - Nature of the Disease,
     K,eio J. Med., 18, p. 181-194.  Part II - Epidemiology and Evaluation,
     Keio J. Med., 18, p. 195-211.

9.   Horn, W.,  R. W. Risebrough, A. Soutar, and D. R. Young, 1974.
     Deposition of DDE and Polychlorinated Biphenyls in Dated Sediments
     of the Santa Barbara Basin, Science, 184, p. 1,197.

10.  s|o. Calif. Coastal  Water Research Project (SCCWRP),  1973.  The
     Ecology of the Southern California Bight:  Implications for Water
     Quality Management."

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 11.   Chen,  C.  W.  and G.  T.  Orlob,  1972.   The Accumulation  and Significance
      of Sludge in San Diego Bay.   Jour.  Water  Poll.  Cont.  Fed.,  44,  p.
      1,362.

 12.   Waddington,  J.  I.  and  D.  W. Mackay, 1973.  Pollution  Control  in
      Estuaries and Inshore  Waters.   Water Poll. Control  (G.B.),  72,  p.
      441.

 13.   Rararas-Carayannis,  G., 1973.   Ocean Dumping  in-"the New  York  Bight:
      An Assessment of Environmental  Studies.   Tech.  Memo.  No.  39,  U.  S.
      Army Corps of Engineers,  Coastal  Eng.  Res. Ctr.,  Ft.  Belvoir.

 14.   Mearns, A.J., 1974.  Toxicity Studies  of  Chromium, Southern California
      Coastal Water Research Project  Annual  Report, p.  15.

 15.   Oshida, P. and  D.  J. Reish, 1975.   Effects of Chromium on Reproduction
      of Polychaetes.   Southern California Coastal  Water Research Project
      Annual Report,  p.  55.

 16.   SJierwood, M.  J.,  1976.  Fin Erosion Disease Induced in the Laboratory.
      Southern  California  Coastal Water Research Project Annual Report,
      p.  149.

 17.   Young, D.  R.  and  T.  K.  Jan, 1976.   Metals in Scallops.   Southern
      California Coastal Water  Research Project Annual  Report,  p. 117.

 18.   Heesen, T. C. and  D. J. McDermott,  1976.   DDT and PCB in Benthic
      Crabs. Southern  California Coastal  Water  Research Project Ann.  Rpt,
      p.  109.

 19.   Seba, D.  B.  and  E. F.  Corcoran, 1969.  Surface Slicks as  Concentrators
      of Pesticides in the Marine Environment.  Pesticides Monitoring
      Jour., Vol.  3,  p. 190-3.

 20.   National  Academy of Sciences/National Academy of Engineering,  1970.
      Waste Management Concepts for the Coastal Zones.  Washington,  D.C.,
      p. 45-47.

 21.  Significance and Control of Wastewater Floatables in Coastal Waters.
      Univ.  California, Richmond, San. Eng. Res. Lab.  1971.   EPA Grant
      16070FKO.

22.   The Significance and Control of Wastewater Floatables  in Coastal
     waters.   Univ. California, Berkeley, Hydr. San.  Eng.  Div.  1974
     EPA Grant R-800373.

23.   Selleck,  R. E.,  1974.  The Significance of Surface Pollution in
     Coastal Waters.   Discharge of  Sewage from  Sea  Outfalls,  A. L.  H
     Gameson,  Ed., Pergammon Press.   Supplement to  Progress in Water
     Tech.  Proc.,  Internet'1. Symposium,  London, 27 Aug., p.  145.

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 24.   Carter, R.  C., 1973.   Surface Pollution of Coastal Waters.   Dissertation
      Univ.  of California,  Berkely, 195 p.

 25.   EPA Project 16020 ELV, April  1971.  Investigation of Microlayer
      Collection  for Pollution Measurement.   Oceanic Institute,  Maimanlo,
      HW 96795.

 26.   Concentration of Trace Pollutants in Surface Layers.   University of
      Rhode  Island, Narraqansette,  June 1974.   EPA Tral'ning Grant WP252.

 27.   Woodcock, A.  H.,  1948.  Journal  of Marine Research,  Vol. 7, p.  56.

 28.   H'iggins, F.  B.,  1964.   Thesis.   Georgia  Institute of Technology.

 29.   B'lanchard,  D. C.  and  L.  Syzdek,  1970.  Mechanism for the Water-to-
      Air Transfer and  Concentration of Bacteria.   Science Vol.  170,  D.
      626-8.

 30.   Vind,  H.  P.,  J. S.  Muraska  and C.  W. Mathews,  July 1975.  The
      Survival of Sewage  Bacteria at Various Ocean Depths.   Civil  Engineering
      Lab.,  Naval  Construction Battalion  Center,  Tech.  Note  N-1396.   Port
      Hueneme,  20  p.

 31.   Dresnack, R., and J.  Chack, 1973.  A Rational Method for Assessing
      the Environmental Impact of Pollutional Loads in  the Ocean.  Proc.
      Inst.  Environ. Sci.,  Vol. 19, p.  59-62.

 32.   Williams, P.  M. and A.  F. Carlucci, 1976.  Bacterial Utilization of
      Organic Matter in the  Deep Sea.   Nature,  Vol. 262, p.  810-811.

 33.   Morris,  R. L., A. J. Mearns and J.  Kim, 1976.  Viruses and  Bacteria
      in  Coastal Waters and  Shellfish.  So.  Cal. Coastal Water Research
      Project Annual Report.   El Segundo, p.  97-103.

 34.  Report on Compliance Monitoring at the Hyperion Wastewater Treatment
     Plant,  Los Angeles3  California.  March 1975.  Prepared by NEIC for
      EPA  Region IX.

 35.   Personal communication with Mr. G. P.  Callahan, Asst. Chief Engineer
     Hyperion Treatment Plant, Feb. 4, 1977.

36.  Sullivan, C.  R., 1973.  Economic and Social Significance of Sport
     F^sh^ng   Am. Inst.  Chem. Eng. Apr.  23,  Nat. Conf. on Complete
     Water Use:  Industry's Opportunity, Washington, D. C.

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