0ho/oaify,
(uiMfjf (citnhf, and Mi? ({<{y of r. EPA Region 9
I toan^t - San Franciscc
iSEi
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ACKNOWLEDGEMENTS
We appreciate the cooperation of the Patuxent Wildlife Research Center in
releasing unpublished data on DDT and PCB residues in brown pelicans. In
addition, the cooperation of the permittees and the invaluable aid of the
researches listed in the bibliography is gratefully acknowledged. Finally,
we wish to thank Tom Kremer for editing, and Rhonda Spears and Ann Gleason
for typing the report.
Environmental Protection Agency
Region 9
lib Fremont Street
San Francisco, California 94105
Prepared by: Gregory Baker
Deborah Graham
Janet Hashimoto
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TABLE OF CONTENTS
Page
ACRONYMS and ABBREVIATIONS 1
SUMMARY 2
1 INTRODUCTION 5
1.1 Requirements of the Endangered Species Act. ... 5
1.2 Relationship to the 301(h) Actions 6
1.3 Objectives 8
2 PROPOSED FEDERAL ACTIONS 9
2.1 NPDES Program Overview 9
2.2 301(h) Program Overview ... ..... 10
2.3 301(h) Actions to Date 13
3 ENDANGERED SPECIES 15
4 ENVIRONMENTAL FACTORS AFFECTING PELICAN REPRODUCTION . 18
4.1 Chlorinated Hydrocarbons 18
4.2 Other Factors 27
5 WASTEWATER DISCHARGE CHARACTERISTICS 31
5.1 County Sanitation Districts of Los Angeles County 31
5.2 City of Los Angeles Hyperion Treatment Plant. • • 38
5.3 County Sanitation Districts of Orange County. . . 43
6 REGIONAL SOURCES OF DDT and PCBs 49
6.1 External Sources 49
6.2 Persistence of Input from Historically
Contaminated Sediments 54
7 PROBABLE EFFECTS OF 301(h) ACTIONS 59
8 RECOMMENDATIONS 62
BIBLIOGRAPHY 64
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ACRONYMS and ABBREVIATIONS
BOD
Biochemical Oxygen Demand
CBP
California brown pelican
CLA
City of Los Angeles
CSDOC
County Sanitation Districts of Orange County
CWA
Clean Water Act, or FWPCA
DDT
1,1,l-trichloro-2,2-bis(p-chlorophenyl) ethane
DFG
California Department of Fish and Game
EPA
Environmental Protection Agency
ESA
Endangered Species Act
FWPCA
Federal Water Pollution Control Act, or CWA
HERS
Hyperion Energy Recovery System
JOS
Joint Outfall System (LACSD)
JWPCP
Joint Water Pollution Control Plant (LACSD)
LACSD
County Sanitation Districts of Los Angeles County
MER
Mass Emission Rate
MGD
Million Gallons Per Day
NPDES
National Pollutant Discharge Elimination System
PCB
Polychlorinated Biphenyl
RWQCB
California Regional Water Quality Control Board
SCB
Southern California Bight
SWRCB
California State Water Resources Control Board
TICH
Total Identifiable Chlorinated Hydrocarbons
301(h)
Section 301(h) of the Clean Water Act
TSCA
Toxic Substances Control Act
TSS
Total Suspended Solids
USFWS
United States Fish and Wildlife Service
WRP
Water Renovation and Reclamation Plants
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SUMMARY
This report assesses the potential impacts of three separate permit
actions by the Environmental Protection Agency. The County Sanitation
Districts of Los Angeles County (LACSD), the City of Los Angeles Hyperion
Treatment Plant (CLA), and the County Sanitation Districts of Orange
County (CSDOC) have each applied for a modification to their NPDES waste-
water discharge permits, pursuant to Section 301(h) of the Clean Water
Act. The permits place limits on the wastewater discharges to the ocean
which contain trace amounts of toxic residues - DDT and PCBs in particular
- which affect the productivity of the endangered California brown pelican.
The discharge limitations that would be required under a 301(h) modified
NPDES permit are, in the case of these three municipal wastewater
dischargers, proposed to be at least as stringent as discharge levels
currently being achieved, and certain facilities have planned improvements
which will further improve the quality of their wastewater discharge. A
301(h) modification will officially alter, for a period of 5 years, the
requirement that all dischargers attain a secondary level of wastewater
treatment. At the end of the 5 year period the permittee would either
apply for another 301(h) modified permit or be required to construct the
additional facility improvements necessary to provide secondary treatment
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of wastewater. The results of the monitoring program conducted pursuant
to the conditions of the initial 301(h) modified permit would form one of
the bases for determining whether the issuance of a second 301(h) modified
permit is justified.
Limits on the discharge of toxic compounds are derived from the Federally
approved water quality standards contained in the California Ocean Plan,
scheduled for revision this year. These limits are independent of the
level of treatment required under the Federal Clean Water Act. All
three facilities in question are currently meeting the Ocean Plan limits
on chlorinated hydrocarbon emissions; nevertheless, the construction of
secondary treatment facilities would result to some degree in a further
reduction of toxic pollutants emitted to the ocean.
Significant improvements have been made in the quality of wastewater
discharges since the 1960s, when DDT discharged to the ocean had a critical
impact on the reproduction of brown pelicans breeding off the coast of
Southern California. Although some of the reduction of DDT and PCB
emissions is attributable to improvements in the treatment facilities,
the bulk of it is due to control of the sources of these toxic substances,
and to Federal and State bans on their use.
Since 1970, brown pelican productivity has improved dramatically but
not sufficiently to merit its removal from the U.S. Fish and Wildlife
Service's endangered species list. Current PCB concentrations do not
appear to be responsible for the continued low reproduction rates.
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While chronic DDT problems persist, there are several other environmental
factors affecting pelican productivity which have increased in relative
importance. The major block to full recovery of the species now appears
to be inadequate food abundance.
The diversity and complexity of factors affecting both pelican productivity
and the distribution and persistence of chlorinated hydrocarbons throughout
the aquatic ecosystem make it impossible to determine a definitive
wastewater effluent concentration that would correspond to a maximum
allowable body burden of DDT in brown pelicans. The persistence of DDT
and PCB contamination in pelicans appears to be caused chiefly by the
general persistence of these substances in ocean sediments, on land, and
in the atmosphere, since wastewater inputs have decreased substantially
without a corresponding decrease in the concentration of these substances
in aquatic organisms and secondary consumers such as the pelican.
The incremental improvement in toxics removal that would be realized
under full secondary wastewater treatment is likely to have neither a
noticeable effect on levels of contamination in brown pelicans, nor a
significant impact on their viability. The issuance of Section 301(h)
modified permits for the three dischargers would therefore be unlikely
to affect the productivity and continued existence of the California
brown pelican. Recommendations for improving our understanding of the
influences of wastewater discharges on the brown pelican are proposed in
the final section of this report.
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1. INTRODUCTION
Requirements of the Endangered Species Act
The Endangered Species Act was enacted to provide a means whereby
the ecosystems upon which endangered species depend may be conserved
to provide a program for the conservation of such endangered species
and to take appropriate steps to achieve the goals of several inter-
national treaties and conventions. In furtherance of the purposes
of the Act, Federal departments and agencies are required to use
their authorities to conserve endangered and threatened species.
Section 7 of the Act states:
Each Federal Agency shall, in consultation and with the
assistance of the secretary, insure that any action
authorized, funded, or carried out by such agency ...
is not likely to jeopardize the continued existence of
any endangered species or threatened species.
The procedures for interagency consultation on endangered species
are set forth in 50 CFR Part 402. These regulations limit the
requirement of preparing a biological assessment to construction
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or carried out by a Federal agency which.... is designed primarily
to result in the building or erection of man-made structures such
as dams, buildings, roads, pipelines, channels, and the like" (50
CFR 402.02). Notwithstanding this limitation, Federal agencies
still have an obligation to review all their actions for effects on
endangered and threatened species, and may use the biological assessment
to assist in determining the need for formal consultation pursuant
to Section 7(a) of the ESA, whether or not the action is a construction
project.
1.2 Relationship to Issuance of 301(h) Modified NPDES Permits
In September 1979, the City of Los Angeles, the County Sanitation
Districts of Los Angeles County, and the County Sanitation Districts of
Orange County applied for 301(h) modifications to their NPDES permits
for the discharge of pollutants from their municipal sewage treatment
.plants (a description of this permit action is provided in Section
i
2 of this report).
In 1980 the National Marine Fisheries Service and the U.S. Fish and
Wildlife Service provided EPA lists of endangered species present
in the areas affected by the proposed 301(h) actions. Through
subsequent informal consultation, NMFS concluded that issuance of
the 301(h) modified NPDES permits would not adversely affect any of
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the endangered species for which they are responsible. USFWS came
to a similar conclusion for one of the species they listed, the
light-footed clapper rail (Rallus longirostrls levipes); however,
they could not conclude that there would be no adverse effect on
the California brown pelican (Pelecanus occidentalls californicus)
from the issuance of the 301(h) modified NPDES permits, due to
insufficient data on the effects of sewage discharge on pelican
reproduction (letter from William Sweeney, USFWS to Ron DeCesare,
EPA, May 14, 1982).
USFWS cited two issues for which they have insufficient data to
assess the impact of the 301(h) actions on the California brown
pelican:
1. Is the current problem of chronic eggshell thinning a manifestation
of past DDT accumulations in the marine ecosystem or a manifestation
of current emmissions (or both)?
2. If there is a correlation between current pesticide loads and
eggshell thinning, what is the maximum pesticide effluent concentra-
tion that will provide for the minimum acceptable levels of
pelican productivity?
In addition to these two issues, USFWS questioned the effectiveness
of existing water quality standards in protecting the needs of the
California brown pelican.
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1.3 Objectives
As a result of the outstanding concerns of the USFWS, the EPA decided
to perform a biological assessment of the impacts of issuing 301(h)
modified NPDES permits to CLA, LACSD and CSDOC on the California
brown pelican. This report summarizes the information gathered in
the assessment and provides information on the probable impacts of
the referenced actions, both individually and cumulatively.
In order to inset the objectives of the assessment, the following
methods were employed:
1. Scientific literature pertaining to pesticide and PCB contamination
of the marine ecosystem and, in particular, the brown pelican
was reviewed.
2. Scientists currently working in the field were contacted to
obtain unpublished data and professional opinions on the subject.
3. Information on the quality of past, present, and projected
wastewater discharges from the three municipal treatment plants
was compiled and analyzed.
4. Possible mitigation measures and specific biological monitoring
requirements were investigated.
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2. FEDERAL ACTIONS
2.1 National Pollutant Discharge Elimination System (NPDES)
The NPDES program was created by Section 402 of, the Federal Water
Pollution Control Act (FWPCA, later the Clean Water Act or CWA)
Amendments of 1972. The Act makes it illegal to discharge a pollutant
from a point source to the Nation's waters without an NPDES permit.
The permit includes effluent limitations and, if applicable, compliance
measures, schedules, and monitoring or reporting requirements legally
binding on the permittee. NPDES permits are issued by EPA or a state
delegated permitting authority by EPA. Under the provisions of the
1972 Act, publicly owned treatment works (POTWs) were to achieve
effluent quality reflective of a secondary level of sewage treatment by
(5301(b)(1)(B)).1
In 1977, Congress made several changes to the FWPCA, the most signifi-
cant change for the purposes of this assessment being the addition
of Section 301(h).
^Federal Regulations at 40 CFR 133.102 define secondary treatment according
to the following criteria (measured as a 30-day average): no more than
30 mg/1 B.O.D., no more than 30 mg/1 suspended solids, pH between 6 and
9, and a removal efficiency of 85%.
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2.2 Section 301(h) of the Clean Water Act
The requirement of secondary treatment for POTWs was one of the
areas of greatest controversy regarding the 1972 amendments. The
Act mandated uniform minimum requirements on all POTW discharges
whether the discharges were into a lake, estuary, river, or ocean.
The 1972 amendments included a requirement that a national commission
study the impacts associated with carrying out the amendments. The
commission's report included the following finding:
If reasonable precautions are followed, large volumes of
municipal wastewaters can be discharged into some open
coastal waters without undue damage to man's interest or to
the ecological balance and productivity of coastal waters.
The public is misinformed about the extent of ocean pollution
and the damage to marine life by municipal wastewaters,
generally believing the situation to be much worse than
scientific studies show.
Municipalities on the West Coast argued that secondary treatment is
unnecessary to protect marine waters. They alleged that less-than-
secondary discharges will not cause ecological perturbations.
Thus, Section 301(h) was enacted as part of the 1977 Amendments to
the CWA. This action authorizes EPA to issue NPDES permits modifying
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municipal discharges to marine waters If the discharge complies
with the 301(h) criteria specified in the Act. The Construction
Grant Regulations (40 CFR 35.2005) were amended on May 12, 1982 such
that wastewater treatment at levels commensurate with 301(h) ocean
discharge waivers may qualify as Best Practicable Waste Treatment
Technology (BPWTT). BPWTT is defined as the most cost effective
technology that can treat wastewater in publicly owned or individual
wastewater treatment works.
The applicant must show that their proposal will comply with the
seven criteria of Section 301(h) regarding: 1) applicable water
quality standards; 2) impact on public water supplies, balanced
indigenous population, and recreation; 3) monitoring discharge
impacts on marine biota; 4) impacts on requirements applicable to
other point and non-point sources, 5) pre treatment; 6) nonindustrial
toxics source control; and 7) increase in discharge.
The State of California administers an approved NPDES permit program
for discharges to waters within State jurisdiction. NPDES permits
are issued by the State through the Regional Water Quality Control
Boards (RWQCB). Authority to grant a waiver and issue a modified
NPDES permit under Section 301(h) of the Act is, however, limited to
the EPA. Concurrence by the State on the issuance of a modified
permit is required by Section 301(h). The EPA Region 9 Water Management
Division Director and the California State Water Resources Control
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Board Executive Director have entered into an agreement (Memorandum
of Agreement, 9/22/82) in order to most efficiently coordinate efforts.
Thus, to the extent possible, NPDES permits and State Waste Discharge
Requirements which include 301(h) modified limitations will be issued
jointly by the EPA and the appropriate RWQCB.
The processing of a Section 301(h) waiver application consists of
the following actions:
1. Filing of a complete application;
2. Comparison of the application with criteria set forth in regulations,
from which a technical evaluation report Is prepared;
3. Preparation of a recommendation and tentative decision document
for the Administrator by an EPA Task Force consisting of representation
by the Office of Water and Waste Management, Office of Research and
Development, and the appropriate Regional Office;
4. Announcement of the tentative decision by the Administrator;
5. Issuance of a notice of a draft NPDES permit and Waste Discharge
Requirements with modifications or notice to deny the application,
by the EPA Regional Administrator and RWQCB Executive Officer;
6. Conduct of public hearings where necessary to address public interest;
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7. Issuance of a Section 301(h) modified NPDES permit and Waste Discharge
Requirements or issuance of a denial of the application by the
appropriate Regional Administrator (EPA) and Executive Officer
(RWQCB);
8. Processing of appeals, in accordance with procedures defined in
EPA regulations (40 CFR Part 124, Subpart E).
2.3 Section 301(h) Actions to Date
The history and status of the 301(h) applications for LACSD, CSDOC, and
CLA are summarized below.
LACSD CSDOC CLA
Application 9/13/79 9/13/79 9/13/79
Draft Technical Evaluation 3/81 3/81 2/81
Report
Tentative Decision Document 11/30/81 11/30/81 11/30/81
Public Notice of Draft Permit and - - - 8/3/82 -
Fact Sheet
Public Hearing _ _ _ 9/10/82 - - -
Letter of Intent to Revise
Application 1/10/83 1/10/83 1/10/83
Revision Due 11/25/83 11/25/83 11/25/83
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After concluding consultation with the U.S. Fish and Wildlife Service
and public hearings on these 301(h) actions the next step would be
for EPA and the appropriate RWQCB to issue a draft NPDES modified
permit and Waste Discharge Requirements, provided that the final
decision is to grant the 301(h) modified permit. If the intent is to
deny a variance, a public notice of that proposed action would precede
the final decision.
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3. ENDANGERED SPECIES
Within the brown pelican species (Pelecanus occidentalis) there are six
recognized subspecies (Wetmore 1945) one of which, the California brown
pelican (P.O. californlcus), is the subject of this report. The breeding
habitat of the California brown pelican generally ranges from the Channel
Islands off Southern California as far southward as Isla Tres Marias off
Nayrit, Mexico. The subspecies is distributed in five breeding units
which are geographically separate but not Isolated. One such unit is
known as the Southern California Bight (SCB) population and Inhabits the
Channel Islands and the islands along the northwest coast of Baja California
south to Isla San Martin (Figure 1). This breeding unit currently represents
about 6 percent of the total £.0. californlcus population. Other breeding
units of the California brown pelican have not suffered the colony-wide
reproductive failures experienced by the SCB population (Gress and Anderson,
in preparation).
The largest brown pelican colonies in the SCB are those found on the
Anacapa and Los Coronados Island groups (each consisting of three small
islands). Breeding colonies also occur less regularly on other islands
in the SCB. The number of pairs breeding in the SCB from 1969 through
1981 ranged from 339 to 3510 (ibid.).
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In order to breed successfully, the California brown pelican requires
nesting grounds that are free from predators and human disturbance and an
adequate supply of food within its normal 30 to 50 kilometer foraging range.
The duration of the pelican breeding season is about 18 weeks, and during
this period pelicans feed almost exclusively on northern anchovies
(Engraulis mordax) (Anderson et al. 1980). Thus, a constant availability
of anchovies during the breeding season is crucial to the maintenance of
a sustainable pelican population.
The brown pelican was classified as endangered by USFWS in 1970 In response
to widespread pollution related reproductive failures in the 1950's and
1960's. The subspecies JP._o. californlcus received further protection in
1971 when it was designated as endangered by the State of California.
Since then, levels of chlorinated pesticides and PCBs in the near shore
marine environment have been significantly reduced, with a corresponding
improvement in brown pelican reproductive success. In spite of the
improvement, the pelican reproductive rate in the SCB is still below normal.
According to the California Brovm Pelican Recovery Plan (Gress and Anderson,
1982), a mean reproductive rate of 0.9 to 1.1 young fledged per nesting
attempt, typical of rates observed in Florida and the Gulf of California,
would be indicative of a stable, self-sustaining population. Since
1974, CBP productivity has generally ranged from 0.6 to 0.9 young per
nest attempt (Table 1). It is possible, but highly unlikely, that the
historical productivity of the SCB colonies was typically low.
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33
31
Scorpion Rock ('72:74-75)
* SBIC'
Anacapa ^
Islands «
(pre-'69-'80)
80)]
C*
* w*
O
53
as
Los MT_
Coronados ^
(pre-'69-80)
N\.
Ialas Todos Santos^
(pre-'20s)
*
T
v*
r
O
I
^ -
km
50
100 150
Isla San Martin v .
( 69,'71- '72, *74)
120
118
Figure 1. Map of the Southern California Bight area showing the locations
of present and past brown pelican nesting colonies. Dates in
parentheses below each location are the years when these colonies
have been active. Santa Barbara Island is abbreviated as "SBI."
Narrow arrows indicate major water circulation patterns in the
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Table 1. Yearly mean population data for brown pelicans nesting
in the Anacapa Island area (West Anacapa Island,
Scorpion Rock, and Santa Barbara Island) and on
Isla Coronado Norte from 1969 through 1981.
(taken from Gress and Anderson, 1982) ,
Anacapa Area
Los Coronados
Est. No.
No. Yng.
Product-
Est. No.
No. Yng.
Product-
1
2
1
2
Year
Pairs
Fledged
ivity
pairs
fledged
ivity
1969
750
4
0.005
375
0
0
1970
552
1
0.002
175
4
0.02
1971
540
7
0.013
110
35
0.32
19723
261
57
0.22
250
150
0.60
1973
247
34
0.14
350
100
0.29
3
1974
416
305
0.73
870
880
1.01
19753
292
256
0.88
339
407
1.20
1976
417
279
0.67
473
487
1.01
1977
76
39
0.51
263
216
0.82
1978
210
37
0.18
265
62
0.23
1979
1258
980
0.78
960
920
0.96
19803
2244
1515
0.68
758
350
0. 46
1981
2946
1805
0.61
564
310
0.55
Estimates represent a compromise between maximum numbers present, numbers
of nests constructed, reproductive behavior, and appearances of secondary
sexual characteristics.
Expressed as number of young fledged per pair. Data for years 1969-1974
are from Anderson et al. (1975), for 1975-1980 from Anderson and Gress
(1982a) and Gress and Anderson (1982).
Nesting occurred on Scorpion Rock in 1972 (112 nests; 31 young), 1974
(105 nests; 75 young), and 1975 (80 nests; 74 young) and on Santa
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Several reasons for the inability of the population to stabilize are
discussed in the Recovery Plan, including fluctuations in anchovy biomass
within foraging range of Anacapa Island, the persistence of chlorinated
pesticides in the SCB, and human disturbance during the breeding season.
Determining the extent to which continued poor pelican productivity is
attributable to wastewater discharges from the three major Southern
California municipal sewage treatment plants is the objective of this
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4. ENVIRONMENTAL FACTORS AFFECTING
CALIFORNIA BROWN PELICAN REPRODUCTION
4.1 Chlorinated Hydrocarbons
4.1.1 Regulatory Background on DDT and PCBs
DDT
Agricultural and commercial usage of DDT became widespread in the
U.S. after 1945. During the years prior to its cancellation
almost 1.4 billion pounds of DDT were used domestically. After
1959 DDT usage in the U.S. declined significantly, as a result of
increased insect resistance, the development of more effective
alternative pesticides, growing concern over adverse environmental
effects, and increasing government restrictions on DDT use.
Several government committee reports issued in the 1960s recommended
a phasing out of the pesticide. Various environmental organizations
such as the Environmental Defense Fund became increasingly active
in initiating lawsuits leading to the restriction of DDT use at
both local and Federal levels.
In 1957, the USDA prohibited the spraying of DDT in specified
strips around aquatic areas on lands under its jurisdiction, and
began to phase out all use of the pesticide in 1958. In 1964 the
Secretary of the Interior issued a directive restricting DDT use
on Interior lands. USDA cancelled DDT registrations for certain
uses nonessential to human health in the late 1960s.
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Soon after the transfer of responsibility for Federal regulation
of pesticides to the Environmental Protection Agency in December
of 1971, and under court order following a suit by the Environmental
Defense Fund, EPA issued cancellation notices for all registrations
of products containing DDT, pending a public hearing and final
resolution. Final cancellation of all remaining crop uses of DDT
was announced by the EPA Administrator on July 7, 1972. DDT use
in California had already been banned by the State in 1971.
Since the Federal ban, emergency use of the pesticide has been
possible on a case by case basis.
The Montrose Chemical Corporation in Torrance, California was the
sole remaining domestic manufacturer of DDT after 1971 (domestic
production of the pesticide for foreign export was unaffected by
DDT domestic use bans). Montrose has continued to manufacture DDT
through 1982, but plans to discontinue production by the Spring
of 1983 (Montrose personnel, ,pers. comm.).
Coincidentally, the DDT ambient water quality criteria for protecting
freshwater and marine aquatic life, developed in 1980 by EPA using
the lowest maximum permissible tissue concentration of DDT and its
metabolites, are based on studies of DDT's effects on the brown
pelican.* The Federal criterion for DDT is 0.001 ug/1. Presently,
^The Federal water quality criteria are not enforceable standards, per se;
rather, they present data and guidance on the environmental effects of
pollutants, which may be used to derive regulatory requirements. At
present there are no Federal water quality standards for DDT or PCBs.
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there is no State standard in the California Ocean Plan specific for
DDT; rather a fixed, undiluted effluent limit of 0.002 mg/1 was
established in 1972 for the total concentration of identifiable
chlorinated hydrocarbons (TICH).* This level was developed by
the State on the basis of small residues typically found in treated
domestic wastewater (Klapow, et al, 1979).
In 1978 the Ocean Plan was revised, and the T1CH parameter was
replaced by the Total Concentration of Chlorinated Pesticides and
PCBs, consisting of a more strictly defined list of constituents.^
DDT and PCBs typically account for the bulk of the chlorinated
hydrocarbons measured in the effluents from the three facilities
discussed in this report. More recently proposed revisions to the
Ocean Plan call for the compounds listed in the current plan to
receive individual limits (State Water Resources Control Board,
1983). Under this proposal, the individual limit for the 6-month
median of total DDT diluted effluent concentration would be set at
^Total Identifiable Chlorinated Hydrocarbons are measured by summing the
individual concentrations of DDT, DDD, DDE, aldrin, BHC, chlordane,
endrin, heptachlor, lindane, dieldrin, polychlorinated biphenyls, and
other identifiable chlorinated hydrocarbons.
^Total chlorinated pesticides and PCBs are measured by summing the
individual concentrations of DDT, DDD, DDE, aldrin, BHC, chlordane,
endrin, heptachlor, lindane, dieldrin, and polychlorinated biphenyls.
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0.001 ug/1. A draft EIR on the proposed changes to the Ocean
Plan has been circulated and a public hearing was held on April
21, 1983. Final adoption of a new Ocean Plan is still several
months away.
PCBs
Between 1929 and 1977, about 1.4 billion pounds of PCBs were
produced in the United States. Of this total, an estimated 150
million pounds are thought to be present in the environment, and
another 750 million pounds still in service in electrical equipment.
Not until the late 1960s did it become evident that PCBs were an
ubiquitous pollutant in the global environment.
The Food and Drug Administration promulgated regulations in 1972
prohibiting the use of certain PCB-containing materials and equipment
in animal feed, human food, and food packaging materials. That same
year Monsanto, the major U.S. manufacturer of PCBs, limited sales to
manufacturers of transistors and capacitors (i.e., closed systems).
Monsanto ceased manufacturing PCBs in 1977. Small quantities of PCBs
may still be produced currently as unintentional byproducts of other
chemical processes.
The enactment of the Toxic Substances Control Act of 1976 placed
additional specific restrictions on the use of PCBs. Section 6(e)(2)(A)
of TSCA prohibits the manufacture, processing, distribution in commerce,
and use of PCBs after January 1, 1978, in other than a totally enclosed
manner. Prior to the enactment of the TSCA, the EPA's regulatory
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authority over PCBs had been limited to contamination of water from
point sources under the Clean Water Act of 1972. EPA promulgated a
rule under Section 307(a) of the CWA on February 2, 1977 (42 FR 6532-6556)
banning the discharge of PCBs into navigable waters by electrical
transformer and capacitor manufacturers.
For PCBs the EPA ambient water quality criterion to protect salt
water aquatic life is 0.003 ug/1 as a 6-month average. PCB emissions
are presently limited by the State of California under the Total
Chlorinated Pesticides. The undiluted effluent concentration of 0.002
mg/1 mentioned in the preceding DDT discussion is the limit which
applies. Under the proposed revisions to the Ocean Plan, the individual
limit for the 6-month median of PCB diluted effluent concentration
would be set at 0.003 ug/1.
4.1.2 Effects of Chlorinated Hydrocarbons on the California brown pelican
DDT
Research on probable causes of reproductive problems in brown
pelicans was initiated in 1969 in response to surveys which
indicated that the SCB population was declining. High levels of
chlorinated pesticide had previously been linked to reproduction
failures in predatory birds (Stickel, et al, 1966) and seabirds
(Hickey and Anderson, 1968). Eggshell thinning in peregrines was
first noted in the early 1960's by Derek Ratcliffe of the British
Nature Conservancy, and similar observations were made subsequently
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In the United States. Pesticides were a suspected cause, and
experiments performed at the Patuxent Wildlife Research Center
confirmed a relationship between abnormal decreases in eggshell
thickness and doses of DDT fed to kestrels.
Pelican eggshells are thinned as a result of DDE* inhibition of
calcium ATPase, an enzyme which promotes the active transport of
calcium ions across the avian shell gland from the blood to the
developing shell (Miller, et al, 1975). In addition to eggshell
thinning there may be other toxicological effects of DDE inhibiting
normal pelican reproduction. Chlorinated hydrocarbons are thought
to depress the estrogen level in birds through the induction of
liver enzymes, resulting in late breeding or an inability to lay
more eggs after early clutches are destroyed (Peakall, 1970).
Studies indicate a non-linear relationship between DDE levels and
eggshell thickness (ibid.). Thus, a given decrease in DDT input
into the environment may not result in a proportional improvement
in the eggshell thickness and reproductive rate of birds, all
other considerations being equal. Nor does there appear to be a
definitive threshold level of DDE in birds below which no eggshell
thinning has been observed; however, levels below which reproduction
is unimpaired have been determined in studies on the eastern
brown pelican, P.O. carolinensls (Blus, 1982).
^DDE is one of the predominant metabolites of DDT, produced through
-------
The eastern brown pelican was the victim of severe pesticide
contamination and decreased productivity not unlike that experienced
by the California brown pelican in the late 1960s and early 1970s.
An intensive study was conducted in South Carolina from 1971 to
1975 during which sample eggs collected from marked nests of
brown pelicans were analyzed for organochlorine residues, and
those residues correlated to the success of individual nests (ibid.).
A nest was classified as successful if at least one downy young
survived long enough to leave the nest.
Statistical analyses demonstrated a significant relationship between
DDE residues and reproductive success of the eastern brown pelican.
The critical level of DDE associated with substantial impairment
of reproduction was calculated to be 3 ppm (expressed on a fresh
wet weight basis), although the calculation was complicated by
the intercorrelation of DDE effects with the effects of other
organochlorines present. One method of analysis performed indicated
that there are only slight effects of DDE on reproduction when residues
are below the critical level, but nest success decreased decidedly
where residues exceeded the critical level. This quasi threshold
level for DDE effects on reproduction may appear to contradict an
earlier statement that even minute DDE residues thin eggshells;
however, there are several other modes of action through which DDE
may affect reproduction. In fact, improved eastern brown pelican
productivity did not temporally coincide with increased eggshell
thickness (Blus, pers. comm.). Eggshell thickness did increase
-------
Nevertheless, eggshell thinning was the primary cause of reproductive
failure in the Anacapa Island brown pelican colony in the late 1960s
and early 1970s. In 1969, nearly 300 nests on West Anacapa Island
were examined and only 12 contained intact eggs (Risebrough, et al
1971). Shells sampled that year had a mean thickness 50% less than
normal. DDE residues in pelican eggs from 1969 averaged 853 ppm
lipid basis, which corresponds roughly to a wet weight value of 43
ppm - an order of magnitude greater than residue levels found in P.p.
Carolinensis in the early 1970s (Table 2).
Concurrent with a decrease of DDT discharges to the ocean waters off
Southern California in the early 1970s, a dramatic decline in pelican
egg contamination and eggshell thinning was observed (Anderson, et
al, 1977). Reproductive success subsequently improved, and then
stablized around 1974 at a level still below what is believed to be a
normal level of productivity. Present DDE contamination has been
characterized as a chronic problem as opposed to the acute situation
of 1969 (Gress and Anderson, in preparation). Residue levels appear to
have stablized around 5 ppm, still higher than the critical level
of 3 ppm derived by Lawrence Blus in the studies on eastern brown
pelicans.
PCB
PCBs do not appear to induce eggshell thinning in wild birds (Blus,
et al, 1971), but PCBs and dieldrin were linked to abnormally late
breeding in ringdoves, and a failure to lay eggs after early clutches
-------
had been lost (Peakall, 1970). Parental behavioral changes, such as
reduced nest attentiveness, have been among suspected effects of PCB
residues (Anderson et al, 1975); however, more recent studies at
the Patuxent Wildlife Research Center conducted on mallards and
screech owls have failed to link PCB dietary dosages of 25 ppm
and 3 ppm, respectively, to interference with reproductive success
(U.S. Fish and Wildlife Service, Fisheries and Wildlife Research,
1978).
The studies described in the previous section pertaining to the
eastern brown pelican provide perhaps the best model for evaluating
the effects of PCB contamination on brown pelican reproduction.
Although PCB residues as high as 18.6 ppm were found in the eastern
brown pelican, no statistically significant correlation between PCB
residues and reproductive success was found.
PCB residues in California brown pelican eggs have declined since
1969, though not as dramatically as DDT residues (Table 2). Current
PCB levels found in eggs are well below the maximum levels (as high
as 18.6 ppm) found in eastern brown pelican eggs collected from
successful nests in South Carolina (Blus, 1982).
Biomagnification
DDT and PCBs are water insoluble and adhere readily to sediments
and organic particulates. Phytoplankton assimilate the organo-
-------
TABLE 2. Mean annual organochlorine residues in brown pelican eggs frcm
Anacapa Island, in ppm wet weight (souroes: Anderson et al, 1977;
Harry M. Ohlendorf, USFWS, personal coraminication).
Year1
Sample Size
DDE
Total DDT
PCB2
1969
28
42.65
45.35
10.0
1973
4
8.75
9.1
2.153
1974
39
4.85
4.85
7.3
1975
4
5.65
5.65
6.0
1979
—
7.4
7.6
3.6
1980
—
3.6
3.7
1.2
1981
—
5.1
5.2
1.2
1. Residue values for the years 1969-75 are oonverted from ppm lipid-basis
values presented in Anderson et al, 1977, assuming a 5% egg lipid
oontent. Values for the years 1979-1981 are preliminary estimates based
on data for which analysis is still incomplete, and may not be represen-
tative of actual residues. Therefore, these residues are not rigorously
comparable to earlier years. Final data will be presented in a report by
USFWS that is currently in preparation.
2. 1969 PCB residues are from Risebrough (1972) and were quantified on the
basis of Arochlor 1254. The 1973-1975 PCBs were quantified on the basis
of Arochlor 1260. Therefore, these residues are not rigorously ocmparable.
A correction factor of 2.15 (Risebrough and deLappe, 1972) was applied
to the data, but no statistical test was made.
-------
of these compounds, they accumulate and are biomagnified at higher
trophic levels. The brown pelican is a secondary consumer, its
chief prey being the planktotrophic and lipid rich northern anchovy.
Biomagnification factors for organochlorine residues from fish to
brown pelican eggs are believed to be within the range estimated
for similar species, on the order of 50 to 100 fold (Blus, 1982),
although lower factors have been observed (Blus et al, 1977).
Table 3 lists mean residues of DDT and DDE in anchovies from various
studies conducted in Southern California coastal and harbor waters.
The migration of anchovies complicates the interpretation of biomag-
nification from fish to pelican eggs, and residues vary substantially
depending on the sample location. The mean residues for the 1980-81
sample are still much higher than the 0.014 ppm mean value measured
in Atlantic menhaden (Brevoortia tyrannus) regurgitated by eastern
brown pelicans in 1975 (Blus et al, 1979). A more systematic approach
to monitoring pesticide residues in anchovies around the SCB would
provide information useful in improving our understanding of the
sources of pelican contamination.
4.2 Other Factors Affecting Pelican Productivity
Pollutants no longer appear to be the major factor limiting CBP
productivity. Since about 1974, the variability of food supplies
during the breeding season has become the most important limiting
-------
Table 3. Mean residues of DOT and DDE in Anchovies off the Southern
California Coast (concentrations in ppm wet weight).
Year1
Total DDT
DDE
1969
4.27
3.24
1970
1.40
0.84
1971
1.34
0.87
1972a
1.12
0.74
1972b
2.182
1973
0.29
0.18
1974
0.15
0.12
1975-77
0.30
1979
0.122
1980-81
0.047
1. Data for the years 1969, 1970, 1971, 1972a, 1973, and 1974 are
taken from Anderson et al, 1975; The 1972b data are from Stout
and Beezhold, 1981; data for the years 1975-77 are frcm USEPA,
1980c, Appendix B; the 1979 data are frcm Mearns and Young, in
Coastal Water Research Project Biennial Report, 1979-1980 (Basoom,
1980); the 1980-81 data are from Shaffer in Coastal Water Research
Project Biennial Report, 1981-82 (Basoom, 1982).
2. These values are derived from anchovies sampled in Los Angeles
-------
UJ
§200
<
o
z
3
CD
|
O
<
X
o
H
<
o
>
o
z
100
0
150
100
50
-L
ANCHOVY
PELICAN
U.S.
FISHERMEN
15 P
o
=3
O
1.0 |
0L
0.5
<
o
—i
UJ
a.
'71 '73 '75 '77 '79
TEAR
rs » 0.885
p < 0.01
100 200
SCB ANCHOVY ABUNOANCE EST.
Figure 2. A. Changes in anchovy biomass estimates (abundance) from 1971-1980
(km^ of school surfaoe area) as related to changes in brown
pelican productivity (fledging rates) in the Southern California
Bight (Anacapa and Los Coronados).
B. Reduction fishery harvest of anchovies by U.S. fishermen from
1971-1980 expressed in metric tons x 10^.
C. Correlation of Southern California Bight overall estimates of
anchovy abundanoe using same units as above) and brown pelican
productivity; The curve was fitted by eye. The "x" represents an
anomalous year (1972-1973).
Source: Anderson and Gress. 1982. Brown Pelicans and the Anchovy
-------
factor influencing pelican breeding success (Gress and Anderson, 1982).
Inadequate anchovy abundance at critical periods during the breeding
season has been blamed for nest abandonment and chick mortality.
In 1979 through 1981, there was a general pattern of good food
availability early in the breeding season followed by food shortages
in mid-season coinciding with widespread nest abandonment and starvation
of young (Gress, 1981). Nest abandonment rates in 1980 and 1981
for the Anacapa Island colony were 50% and 53%, respectively.
Fluctuations in pelican productivity in recent years appear to
correlate well with variations in anchovy abundance (Figure 2).
Shortage of food supplies is believed to be caused by variable
oceanographic conditions and the cyclic nature of the pelagic anchovy
population (Godfrey an Fondahl, 1982). There is experimental verifica-
tion of synergistic adverse effects of food shortage and DDE on
avian reproduction (Keith, 1978), thus suggesting that critical DDE
residues may be lowered during periods of food shortage (Blus, 1982).
Human disturbance to breeding colonies and foraging pelicans, though
not considered a primary cause of endangerment at present, has the
potential to more seriously Impact population stability. The recent
mutilation of several birds has gained media attention (L.A. Times,
October 16, 1982), as has the accidental hooking of pelicans by
recreational and commercial fishermen. Breeding colonies are
disrupted by photographers and educational groups visiting the
island, and by loud noises from low flying aircraft and boats.
These Interferences can result in nest desertion and even complete
-------
colony abandonment (Gress and Anderson, 1982). Nevertheless,
mortality caused by direct Interactions with humans does not presently
account for a significant depression in the CBP productivity.
Offshore oil development could potentially have a serious impact on
pelican breeding. Although the 1969 Santa Barbara oil spill had
little impact on brown pelicans breeding on Anacapa Island, new
leases, exploration, and development near Anacapa Island could
seriously affect the birds should there be a major spill. Natural
seeps in the Santa Barbara Channel are also capable of polluting
foraging habitat near the nesting colonies.
In summary, CBP productivity is affected by several environmental
factors ranging from pollution to variations in food availability.
This makes it difficult to develop a direct correlation between the
minimum acceptable pelican productivity and concentrations of
chlorinated hydrocarbons in municipal wastewaters discharged to the
ocean, as requested by USFWS.^ Given a relationship between municipal
sewage input and levels of chlorinated hydrocarbons in the benthic
environment surrounding the ocean outfalls, there is still a need to
^Actually, past observations suggest that the overall mass emission rates
of pollutants are better indicators of the degree of environmental impact
than are concentrations of pollutants in wastewater (Mearns and Young, 1978).
-------
accurately represent the biomagnification of these substances through
the food chain and factor in other constraints (e.g., food availability)
on pelican productivity. The synergism between pollution effects
and malnutrition would further complicate this model.
Attempts have been made to correlate effluent DDT emissions required
to reduce the scale of contamination below a specified level, using
biomonltoring techniques (Mearns, 1982). Using data from the
California mussel watch program and the LACSD effluent monitoring
program, one observes an apparent first order relation between the
mass emissions of DDT and the length of coastline which has been
impacted thereby (figures 3, 4, and 5). The use of mussels to provide
feedback on the suitability of discharge limitations is discussed
further in the last section of this report.
-------
4 40 "lb LOG10
TRANSFORMED
400- DATA
16500 "lo RAW DATA
15000 -
r 10,000
-5,000
360-
13500 -
% 3 20-
I
w 2 80-
12000 -
Q.
O.
-1,000 s
00500 -
o
1971
1971
9000 -
2 40-
7500 -
o»
6000 -
9 200-
o
9
CT>
-100
I WINTER 1978
1971
"50
4500 -
160"
WINTER 1977 I
3000 -
WINTER 1977
1.20"
WINTER 1978
1500 -
MAJOR
POINT SOURCE
"10
000 -
0 -
300
O 30
90 120 150 180 210
DISTANCE S E OF POINT CONCEPTION. Km
Figure 3. Decline of DDE contamination in intertidal mussels (Mytilus spp.) along 300 km of the
Southern California coast, 1971 through 1978. The LACSD joint outfall system is located approximately
-------
25000 -i
oc
<
UJ
>-
cc
UJ
GL
CO
2
<
a:
o
o
20000 -
15000 -
10000 -
5000-
320 n
240 -
C
160-
D
80 -
0 -
I I I 1 1
1970 1972 1974 1976 1978 1980
Figure 4. (a) Annual change in total DDT mass emission rates from major
Southern California ocean outfalls, 1971 through 1979. (b) Changes in
length of coastline bearing mussels contaminated by DDE, 1971 through 1978.
Four levels of contamination, in ppb dry weight, are: (A) >50, (B) 2100,
-------
E
280 i
210-
140-
70-
o-
Q.
3001
250-
200-
7 = 151 (loginx)-372
® / ,u 150 H
100-
50-
b.
7 = 124 (log10x)-254
a
2.8 3.2 3.6 4.0 4.4
LOG10 DDT EMISSIONS, Kg y"
4.8
i 1 1 1 r~
2.8 3.2 3.6 4.0 4.4
LOG10 DDT EMISSIONS, kg y'
4.8
Figure 5. Relation between lengths of Southern California coastline bearing mussels contaminated by DDE
and corresponding log^Q-transformed sewage-borne mass emission rates for the same year. The two concen-
-------
5. WASTEWATER DISCHARGE CHARACTERISTICS
5.1 County Sanitation Districts of Los Angeles County
The Los Angeles County Sanitation Districts Joint Water Pollution Control
Plant (JWPCP) is located in Carson, California near San Pedro Bay and the
Palos Verdes Peninsula. The service area for this treatment plant consists
of twenty-four sanitation districts in the urbanized Los Angeles Basin.
The districts extend south and west from the San Gabriel - mountain
foothills to the Palos Verdes Peninsula, bounded to the east by San
Bernardino and Orange Counties, to the west by the cities of Glendale
and Los Angeles and to the south by San Pedro Bay. These districts form
the network called the Joint Outfall System (JOS) which includes six
treatment plants and four submarine outfalls. The location and service
area are described in Figure 6.
There are two treatment subsystems in the JOS: A coastal facility known
as the Joint Water Pollution Control Plant and five inland water renovation
and reclamation plants (WRP's). The five WRP's provide advanced secondary
treatment for approximately 23% of the total JOS flow. The treated
effluent from the WRP's is either reused or reclaimed. The JWPCP serves
as a terminus for this trunk sewer system and provides advanced primary
treatment for 77% of the total system flow.
-------
The five WRP's consist of the Pomona Water Reclamation Plant, the Whittier
Narrows Water Reclamation Plant, the San Jose Creek Water Reclamation
Plant, the Los Coyotes Water Reclamation Plant and the Long Beach Water
Reclamation Plant. The treatment processes for the JOS plants and their
1979 design capacities are described in Table 4.
The undigested solids removed in these treatment processes are discharged
back to the trunk sewers and transported to the JWPCP for treatment and
disposal. It is estimated that 3,210 lbs/day of solids are contributed
to the JWPCP for each million gallons per day of upstream treatment.
The JWPCP was constructed in 1927 and began operation as an activated
sludge secondary plant in 1928. The plant was converted to a primary
plant and has operated as a primary or advanced primary treatment facility
since 1947.
In 1970 the system was upgraded to an advanced primary plant by adding
the following to the primary treatment system: a system for adding polymer
to the primary sedimentation tanks, a system for treating flows generated
during digester cleaning operations, an upgraded and expanded solids
dewatering facility and a primary effluent screening system. All of the
above improvements were operating by 1977. A summary of the current
-------
CALIFORNIA
Los
Angeles
Los Angeles
County
SCALE
MILES
JOINT WATER j
POLLUTION
CONTROL PLANT /
PALOS
VERDES
PENINSULA
JJ^ITES POINT San Pedro Boy
118® 20'
Pi9ure 6 "
-------
TABLE 4. Treatment Prooesses for the LACSD Joint Outfall System Plants
Plant Type of Treatment
System
Pcmona water
Reclamation Plant
Whittier Narrows
Water Reclamation
Plant
San Jose Creek Water
Reclamation Plant
Los Coyotes Water
Reclamation Plant
Long Beach Water
Reclamation Plant
JWPCP
Activated Carbon
Dial-Media or Activated
Carbon Tertiary
Dual-Media or Activated
Carbon Tertiary
Dual-Media Tertiary
Dual-Media or Advanced
Filtration Method, to
Enhance Reuse
Advanced Primary
Flow, MGD Design
Capacity
10
15
62.5
37.5
25
-------
TABLE 5
DISCHARGE REQUIREMENTS NPDES PERMIT CA0053813 - COUNTY SANITATION DISTRICTS
OF LOS ANGELES COUNTY (JOINT WATER POLLUTION CONTROL PLANT)
NPDES EFFECTIVE DATE - 6/27/77
EXPIRATION DATE - 6/10/82
Based on a design flow of 385 M3D Effluent Limits for discharge
serial Nos: 001, 002, 003, 004, and 015.
DISCHARGE LIMITATIONS
30-DAY 7-DAY DAILY
COMPLIANCE DATE
CONSTITUENT
UNITS
AVE
AVE
MAXIMUM
July 1, 1977*
BOD5 20°C
mg/1
Kg/day
lbs/day
30
43,700
96,300
45
65,540
144,500
87,400
192,600
Suspended
Solids
mg/1
Kg/day
lbs/day
30
43,700
96,300
45
65,540
144,500
87,400
192,600
* The date for compliance has been extended by Regional Board Order #77-116.
Full compliance is to be achieved by January 31, 1985 and a report of com-
pliance is due February 15, 1985.
not to be
exceeded
more than
30-DAY 10% of the DAILY
COMPLIANCE DATE CONSTITUENT UNITS AVE time. MAXIMUM
July 1, 1978 Total mg/1 .002 .004 .006
identifiable Kg/day 2.91 5.83
chlorinated lbs/day 6.42 12.8
hydrocarbons
July 1, 1978 B-15 - The concentration in marine sediments of sub-
stances listed in 'item A-3 (includes TICH) shall not
be significantly increased above that present under
natural conditions.
July 1, 1977 The final receiving water toxicity concentrations shall
-------
The current JWPCP is an advanced primary treatment system and has a
design flow of 385 MGD. It consists of the following treatment processes:
bar screening, aerated grit removal, primary sedimentation with polymer
addition and anaerobic digestion of primary sludge and digested sludge
dewatering via centrifugation. The sludge from the treatment plant is
composted or hauled to a landfill for disposals Because of the lack
of sludge dewatering facilities and disposal options some of the sludge
is dewatered with very inefficient equipment and a high solids centrate
is also mixed with the effluent and discharged to the ocean. The disposal
of LACSDs sludge was the subject of the Los Angeles/Orange County
Metropolitan Area (LA/OMA) Sludge Management Program EIS/EIR (U.S.E.P.A.,
1980c). As a result of the EIS/EIR, LACSD is currently designing facilities
to dehydrate and thermally process a portion of their sludge, with the
remainder being composted and landfilled.
The effluent from the JWPCP is pumped through two tunnels under the Palos
Verdes Hills to be discharged to the coast near Whites Point for ocean
disposal. The outfall consists of four different outfall pipes, one 60
inches in diameter, one 72 inch diameter pipe, one 90 Inches in diameter
and one 120 inch diameter pipe.
The 60 inch diameter outfall pipe was constructed in 1937. It is 5,000
feet long and discharges at a depth of 110 feet. The diffuser consists of
42 outlet ports drilled into the pipe for 384 feet of the length. This
outfall is used for emergency purposes only.
-------
The 72 inch diameter outfall was constructed in 1947. The diffuser is
located 6800 feet offshore at a depth of 165 feet. In 1953 a 648 foot
wye shaped diffuser was added to this outfall. It is currently used only
during peak flow periods at the plant.
The 90 inch pipe was added in 1956 and is located at 33°42'82'"N latitude
and 118°29'14"W longitude. The diffuser is a 2,400 foot wye shaped
structure with 100 ports. Each port is 6.5 to 7.5 inches in diameter.
It currently discharges 8,000 feet offshore at a 210 foot depth. This
outfall has been used continuously since 1956.
The 120 inch outfall pipe was constructed in 1965 and is located 33°41'52"
N latitude and 118°19,27"W longitude. This diffuser is a 4,400 foot
ellshaped diffuser with one leg parallel to shore. There are 740 discharge
ports on the diffuser, each one is 2-3 inches in diameter. The discharge
takes place 12,000 feet offshore at a depth of 190 feet.
Full secondary treatment at the Joint Water Pollution Control plant would
be necessary to meet the current NPDES permit requirements described in
Table 5. The LACSD had originally planned to reach full secondary
treatment at the JWPCP via a series of three 100 MGD modules called stages
I, II and III. Full secondary treatment at the JWPCP would be provided
with the completion of stage III. Stage III has a design capacity flow of
300 MGD with an additional 150 MGD of wastewater treated and reclaimed
at the.upstream reuse and reclamation treatment plants. Stage III would
-------
provide secondary levels of treatment via the activated sludge process
followed by secondary clarification. The waste activated sludge would
be treated via dissolved air floatation, anaerobic digestion, dewatering
and final disposal*
The LACSD is currently requesting a variance from the secondary treatment
requirements of the Clean Water Act pursuant to section 301(h). The
treatment facilities proposed in the 301(h) permit application would
essentially be those facilities planned for stages 1 and II. This proposal
would provide secondary treatment for 200 MGD and advanced primary treatment
for 100 MGD. Thus, the total design discharge would be 300 MGD rather
than the current limit of 385 MGD. The remaining wastewater flow would
be treated and reclaimed upstream of the JWPCP.
Stages I and II have been under construction at the JWPCP since 1977
and are scheduled to be completed this year. Secondary treatment would
consist of activated sludge followed by secondary clarification. Waste
activated sludge will be treated via dissolved air floatation and anaerobic
digestion. The facilities needed for handling the sludge generated by
the operation of these two stages are not complete. Centrifuges for
dewatering waste activated sludge and primary digested sludge are planned
to be operational in 1985. The LACSD will be unable to provide ultimate
sludge disposal until 1987 when the sludge handling alternative is scheduled
to be on line.
-------
The proposed 301(h) discharge limits for the JWPCP are summarized in
Table 6. Table 7 summarizes the influent and effluent characteristics
at the JWPCP since 1971.
There have been two approaches used by the LACSD to reduce the total
pollutant mass discharged from the JWPCP: improved treatment efficiency
and the control of pollutant volumes at their sources. With respect to
the latter, the County Sanitation Districts adopted a Wastewater Ordinance
on April 1, 1972 and amended it July 1, 1975 and July 1, 1980 in order
to regulate sewer construction, sewer use and industrial wastewater
discharges, pursuant to the responsibilities and authorities delegated to
the Districts under Section 4766 of the California Health and Safety Code.
Section 102 of the Districts Wastewater Ordinance regulates among other
things the quantity and quality of discharged wastes and the degree of
waste pre treatment required. Section 103 states that wastes that will
cause certain detrimental effects in the sewerage system will be prohibited.
Section 406 of the ordinance lists the specific wastes which are prohibited
due to their detrimental effects on the sewerage system. No specific
numerical limits are given for these wastes in the ordinance; however,
specific numerical limits are given in the Districts' Phase I Source
Control Document, adopted in 1975. Industrial users of the sewerage
system are required to comply with these Phase I standards through
Industrial Wastewater Discharge Permit requirements. The first compliance
date was set for January 1, 1977 for all Phase I limits. The Phase I
limit on industrial users for total identifiable chlorinated hydrocarbons
is "essentially none."
-------
TABLE 6
County Sanitation Districts of Los Angeles County - JWPCP discharge
limits (frcm the Tentative Decision Document for the LACSD 301(h)
waiver, November 30, 1981).
Based on a flew rate of 300 million gallons per day
Effluent Characteristics Discharge Limitations
Units
BOD
mg/1
90
kg/day
102,000
lbs/day
225,000
SS
mg/1
90
kg/day
102,000
lbs/day
225,000
pH
-------
TABLE 7
JWPCP - Influent And Effluent Characteristics
Year
Flow Rate
M3D 1
Suspended Solids
mg/1 2
Influent Effluent
BOD 2
mg/1
Influent
Effluent
Total DDT
ug/1
Influent Effluent
PCB 5,6
ug/1
Influent Effluent
TICH 5,6
ug/1
Influent Effluent
1970
371
—
—
1971
372
3973
325
384 3
328
33.7
43.9
19.0
10.1
54
54
1972
351
416
293
319
307
14.8
13.4
9.28
7.6
25
22
1973
359
518
289
357
244
7.30
7.5211
4.82
2.67
12
10
1974
347
460
276
314
213
3.95
3.05
21.9
12.5
20
15
1975
342
484
278
302
209
1.67
2.17
3.94
2.73
5
5
1976
353
424
282
306
229
2.03
1.79
2.37
2.34
4
4
1977
330
463
220
334
220
2.12
1.58
2.70
1.81
4
3
1978
345
448
219
324
204
<2.807
<2.067
1.707
<1.097
<4,677
<3.28
1979
367
435
195
322
204
2.147
C1.387
0.917
0.697
2.897
<2.19
1980
374
442
176
335
208
1.667
1.057
0.837
0.657
3.037
1.91
1981
364
442
167
322
202
1.548
0.837
0.967
0.547
4.09®
2
1982
363
4444
1604
3234
205
0.899
0.529
0.529
0.339
1.539
2
1 Annual mean of the average daily flows.
2 Annual nean.
3 Average of 6 mo. worth of data.
4 Average of 8 nos. worth of data.
5 Frcm Concentrations of Mass Flow Rates of Trace Constituents in the Joint Outfall System 1971-1976
Norman Ackerman Project Engineer Monitoring Section - County Sanitation Districts of Los Angeles
Annual Mean Value.
6 PCB data for JWPCP prior to January 1975 are of questionable accuracy and probably should be disregarded, as should
the PCB fraction of the TICH data. Prior to 1975, questionable chromatographic peak were reported as either inter-
ference or PCBs, based on technician judgement. An improved analytical procedure was adopted in 1975 which resolved
the problem of interference. For further dicussion, see the LACSD report entitled, Control of Plychlorinated
Bihpenyls in the Sanitation Districts of Los Angeles County by Chooq-Hee Rhee.
7 Water Quality Characteristics - Statistical Summary of 1980 Joint Water Pollution Control Plant - CSDEA Report No.
WQCB02.
8 1981 Monitoring Results - JWPCP - Chlorinated Hydeocarbons - Chlorinated Hydrocarbon Monitoring Program - Annual
Mean Values.
9 JWPCP Chlorinated Hydrocarbon Monitoring Program - Raw Influent and Final Effluent August 3, 1982 - Annual nean
values.
10 Effluent samples are taken 100 yards downstream frcm the effluent punp station. Effluent has had two minutes of
sampling.
-------
During the past a number of improvements were made to the JWPCP to reduce
the mass emissions of suspended solids. TICH emissions have, however
declined to a greater extent than the suspended solids. This is likely
due to a combination of factors including source control, a gradual
flushing of residues from the sewer trunk lines, and restrictions on the
use of DDT and PCBs. Improved removal efficiency with respect to BOD and
suspended solids is anticipated with the planned treatment facilities and
further removal of DDT and PCBs can be expected as this improved treatment
efficiency is provided.
It is anticipated that increased removal of PCBs will take place in the
upgraded facilities because PCB removal efficiency through a wastewater
treatment system is reported to be comparable but slightly less than the
corresponding removal efficiencies for susupended solids and BOD (U.S.E.P.A.,
1977c). DDT behaves similarly in the aquatic environment and therefore
is also expected to be comparable (U.S.E.P.A., 1979). Table 8 summarizes
the present and estimated removal efficiencies for the JWPCP under existing
conditions, under partial secondary treatment as proposed in the 301(h)
application, and under full secondary treatment.
Using these estimated removal efficiencies, the mass emission rates are
predicted in Table 9. It is important to note, however, that the projected
removal efficiences given in Table 9 would not be achieved until alternatives
to the ocean disposal of sludge are implemented.
-------
TABLE 8. Existing and Estimated Overall Removal Efficiencies
IACSD Joint Water Pollution Control Plant
301(h)
Parameter Existing Advanced Primary Partial Secondary Full Secondary
Treatment^ Treatment Treatment
%
%
%
BOD
40
763
943
SS
55
843
963
DDT
33
654
81.5 + 4.52
PCB
33
654
81.5 + 4.52
TICH
33
654
81.5 + 4.52
1. Estimated frcm 1977-1982 data obtained from Table 7.
2. U.S. Environmental Protection Agency. 1977. PCB Removal in PubliclyHDwned
Treatment Works. Criteria and Standards Division, Offioe of Water Planning and
Strategy, EPA Report No. EPA-440/5-7-77.
3. County Sanitation Districts of Los Angeles County. 1979. Joint Water Pollution
Control Plant Application for Modification of Secondary Treatment Requirements
for Publicly Owned Treatment Works Which Discharge into Marine Waters; Volume 3,
Part F, pg. Axx-1.
4. Assumes 200 MGD at 81.5% removal (see #2 above) and 100 MGD at 33% removal (see
-------
TABLE 9 - JWPCP Current and Projected Mass Emission Rates
Its/day (kg/day)
Parameter Current NPDES Existing Treatment 1 301(h) Partial
Effluent Limits (advanced primary) 2° (200 MGD 2°)
Full 2°
(300 MGD 2°
treatment)
Flow MGD
385
363
300
300
BOD-30 day
Avg.
96,300
(43,681)
620,621
(281,513)
217,3732
(98,600)
48,4884
(21,994)
TSS-30 day
Avg.
96,300
(43,681)
484,387
(219,717)
224,1792
(101,687)
36,2284
(16,433)
TICH
6.42
(2.91)
6.05
(2.74)
1.343
(0.61)
0.693
(0.31)
Total DDT
Total PCB
N/A
N/A
1.57
(0.71)
0.9
(0.41)
0.783
(0.35)
0.463
(0.21)
0.403
(0.18)
0.233
(0.11)
1 See table 7 for concentrations and flow rates.
2 The mass emissions were developed using LACSD projections based on influent
BOD concentrations of approximately 375 mg/1 and an influent suspended solids
concentraion of approximately 560 mg/1.
3 The mass emissions for TICH, DDT and PCB were obtained by using the current
influent concentration and projected flow rate of 300 MGD.
4 The mass emissions have been calculated using the existing influent BOD and TSS
-------
5.2 The City of Los Angeles Hyperion Treatment Plant
The City of Los Angeles sewerage service area encompasses approximately
600 square miles which includes most of the City of Los Angeles (Figure 7).
The major wastewater treatment facility is the Hyperion Treatment Plant.
The City also operates the Los Angeles-Glendale Water Reclamation Plant
located in Griffith Park and the Terminal Island Treatment Plant located
on Terminal Island. The CLA is currently constructing the Tillman Water
Reclamation Plant in the San Fernando Valley. The solids handling
facilities for the Glendale and Tillman Water Reclamation Plants will be
provided for at the Hyperion Treatment Plant.
The City first started discharging wastewaters into Santa Monica Bay at
Hyperion in 1894. In 1925 a new submarine outfall was extended into the
ocean for one mile and a screening plant was built at Hyperion. " The
plant was first upgraded to a secondary treatment facility in 1950.
A twelve foot diameter one mile outfall was also constructed at this
time. In 1955 the existing plant was expanded to a capacity of 420 MGD.
A five mile effluent outfall and a seven mile digested sludge outfall
were also constructed but not placed into operation until 1961.
The existing Hyperion sewage treatment facility (HTP) basically consists
of pre treatment, primary and secondary treatment, sludge treatment and
then discharge to Santa Monica Bay. Primary treatment consists of bar
-------
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-¦-** 1 *¦ • v -¦ kp.-J,v®SI^^S3L
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AREAS POTENTIALLY
TRIiUTARY BY
CRAV1TY FLOW
LOS AN«ELI3-OLENOALE
WRP SERVICE AREA
S^i:
* /"tS3Sl ¦ ¦ ir
SERVICE AREA 80UN0ARIE
I ,
¦SURSANK WATERH
RECLAMATION PLANT
m
^-TflS AN8CLES - SLE NOAL C WATER
RECLAMATION PLANT
HYPERION SERVICE AREA
HYPERION TREATMENT
¦plantH
rmn:
0=
J terminal islano treatment
TERMINAL ISLANO TH
PLANT SERVICE AREA
r» ,..i . » -fVS
Figure 7 - WASTEWATER TREATMENT FACILITIES ¦*-
PLANNING AND SERVICE AREAS
TERMINAL ISLANO
-------
screening grit removal and primary sedimentation. Secondary treatment
is accomplished by means of the conventional activated sludge process
followed by sedimentation. Currently all wastewater receives primary
treatment and about one-third of the primary treated wastewater receives
secondary treatment.
The settled solids, grease and other floatable material is conveyed to
the plants sludge digestion and treatment facility. All of the sludge
from primary treatment and one half of Che sludge from secondary treatment
is anaerobically digested. The remainder of the secondary sludge is
aerobically digested. After screening the sludge is mixed with secondary
effluent and discharged to Santa Monica Bay.
The HTP has three ocean outfalls. The one-mile long, twelve foot diameter
line is now maintained for emergencies only. It is a gravity line having
eight discharge ports at a depth of 45 feet. The primary and secondary
treated effluent is discharged through the five-mile long 12 foot diameter
outfall. The discharge point is identified as latitude 33 degrees 54
minutes 45 seconds N, longitude 118 degrees 31 minutes 15 seconds W.
The outlet of this five-mile outfall consists of two identical 4,000
foot long diffuser legs.
The diluted digested sludge is discharged through the seven-mile long 20
inch diameter outfall. The discharge point is described as latitude 33
degrees 55 minutes 35 seconds N, longitude 118 degrees 33 minutes 15
seconds W., and takes place at a depth of 320 feet. The permitted
effluent limitations for these discharge points is described in Table 10.
-------
TABLE 10
Discharge Permit Requirements
City of Los Angeles-Hyperion Wastewater Treatment Plant
EPA NPDES Permit No. CA 01009991; California Regional Water Quality
Control Board Los Angeles Region Order no 75-100.
Effective Date: ^Ssptember 17, 1975
Expiration Date: December 17, 1979 - California Regional Water
Quality Control Board Los Angeles Region-Order No. 77-84
FOR DISCHARGE SERIAL NUMBER 001 - (1 mile outfall) based on a design
capacity of 100 MGD
Discharge Limitations
Parameter
Units
30-Day
Average
7-Day
Average
Daily
Maximum
B0D5 20°C?
lbs/day
mg/1
25,000
30
37,500
45
50,000
Suspended
Solids
lbs/day
mg/1
25,000
30
37,500
45
50,000
PH
range
6.5-9.0
Total 3
Identifiable nig/1 0.002 0.004
Chlorinated
Hydrocarbons
(Based on a
design capacity
of 420 MGD effluent
From the discharge of 001 and 002)
1
The conditions of an expired permit continue in force under 5 USC
section 558(c), Administrative Procedures Act, until the effective
date of a new permit if 1) the permittee has submitted a complete
application for a new permit and 2) the EPA does not issue a new
permit on or before the expiration date of the previous permit.
2
The arithmetic mean of the BODS and suspended solids values, by
weight, for effluent samples collected in a period of 30 con-
secutive calendar days shall not exceed 15 percent of the arith-
metic mean of the values, by weight, for influent samples collected
at approximately the same times during the same period.
3
-------
TABLE 10 (continued)
Discharge Permit Requirements
EPA NPDES Permit No. CA0109991
City of Los Angeles-Hyperion Water Pollution Control Plant
Discharge Serial Nos. 002 and 003
Effective Date: October 19, 1982
Expiration Date: July 31, 1985 for 002 and July 1, 1985 for 003
Discharge Serial No. 002 (5-mile outfall) - Based on a design capacity
of 420 MGD
Effluent
Characteristics
BOD5 20 C
Suspended
Solids
PH
Total
Identifiable
Chlorinated
Hydrocarbons
Units
lbs/day
mg/1
lbs/day
mg/1
range
Units
lbs/day
mg/1
30-Day
Average
Discharge Limitations
7-Day
Average;
Instantaneous
Maximum
648,000
185
280,000
80
788,000
225
350,000
100
290
170
6.0 std. units - 9 standard units
Discharge Limitations
6 mo.
Avq.
11
0.003
Daily
Max.
Instantaneous
Maximum
14
0.004
0.01
Discharge Serial No. 003 - (7-raile outfall)
Discharge Limitations
Total
Identifiable
Chlorinated
Hydrocarbons
Total
Solids
Units
lbs/day
mg/1
lbs/day
mg/1
30-Day
Ave.
0.1
0.002
900,000
18,000
Daily
Max.
0.2
0.004
-------
The treatment system as it has been proposed in the 301(h) application
will consist of: a) the existing primary treatment system plus four new
primary sedimentation tanks; b) the existing activated sludge secondary
treatment system upgraded to handle 150 MGD of primary effluent instead
of 100 MGD; c) the existing secondary sedimentation system plus ten new
secondary clarifiers; d) all necessary appurtenances and channels;
e) the existing effluent pumping plant and outfall system. All of the
waste activated sludge from this system would be thickened and anaerobically
digested, either separately or in combination with the primary sludge.
Since the 301(h) modified permit will include a schedule for discontinuing
the ocean discharge of sludge, the digested primary sludge and waste
activated sludge will be mechanically dewatered and then dehydrated.
The dehydrated sludge is to be used for energy recovery (U.S.E.P.A.,
1980c).
The 301(h) discharge limitations which have been proposed are described
in Table 11. The application for a variance from secondary treatment
*
requirements is only being sought for the effluent discharge line number 002
(5-mile outfall). The sludge discharge line, 003, currently must meet
the NPDES permit limits shown in Table 10. In addition, the City of Los
Angeles is required to cease the discharge of sludge by July 1, 1985
under consent decree No. CV-77-3047 as amended April, 1982 (see Section 6.1).
The emergency outfall, 001, will remain subject to the current NPDES
limitations.
-------
Table 11
City of Los Angeles-Hyperion Waste Water Treatment Plant discharge limits
for discharges serial number 002. (Fran the Tentative Decision for the
CLA Hyperion PCTCW) 301(h) waiver, November 30, 1981.
Based on a flow rate of 350 million gallons per day
Effluent Characteristics Discharge limitations
BOD 125 mg/1
TSS 68 mg/1
-------
The conversion of the HTP to a full secondary treatment facility would
involve upgrading the existing secondary activated sludge system to a
high rate oxygen activated sludge system. The remaining portions of the
treatment system would remain the same as they are currently but would
have to be upgraded to Increase the total plant efficiency. Sludge
handling for the Hyperion plant with full secondary treatment would be
an expanded version of the energy recovery facilities designed for partial
secondary treatment under 301(h).
The 1981 data in Table 12 shows that the TICH limit of .003 mg/1 from the
discharge serial number 002 was being met. More recent discharge monitoring
reports indicate that the October and November 1982 TICH discharge
concentrations were 0.0001 mg/1 and 0.00013 mg/1 respectively In the
effluent (City of L.A., 1982).
As with Los Angeles County, improved treatment efficiency should result
in greater removal of chlorinated hydrocarbons. In addition, since the
City of Los Angeles began thuir Industrial pre treatment program in 1975
significant reduction in chlorinated hydrocarbons in the influent to the
sewage treatment plant have been evident. The control of the influent
should continue to play a significant role In the effluent quality.
The estimated removal efficiencies associated with the planned improvements
at the Hyperion treatment plant are shown In Table 13. These are based
on the effluent discharge only and do not consider the sludge discharge.
-------
It is assumed that the influent concentration for BOD, SS, DDT and PCB
will remain at the current levels. The predicted removal percentages
for TICH, DDT and PCB are based on a flow weighted average of primary
and secondary removal through the Hyperion facility for the 301(h) waiver
treatment level.
Estimates of the mass emissions for present, 301(h), and secondary
treatment levels are summarized in Table 14. The estimates project a
future decrease in the mass emissions with Improved treatment facilities.
Table 14 does not include statistics for the sludge outfall, but further
emission reductions would be realized upon cessation of the sludge
discharge.
-------
TABLE 12
Discharge Characteristics
City of Los Angeles - Hyperion Wastewater Treatment Plant
Yi.-ar
How Kate
WJ)
onfall Niiihers
001 002 003
Suspended solids'*
ny/1
Intl. Effl.
001 002 003
BOO6
mg/I
Intl. Effl.
001 002
Tnfl.
Total DOT1'2'4
ug/1
Effl.
001 002
Total po»1#3.4
ug/1
Infl.
00}
Effl.
001 002
001
Intl.
TICH®"'
ug/1
Effl.
TET"
TSJT
~0Ol
1970
341
4.87
261
8.0
73
8700
245
6.0
119
0.66
5.5
0.35
135
197)
337
4.69
273
7.0
78
8000
261
8.0
116
0.10
2.38
0.95
38.5
1972
330
4.62
285
10.0
80
8600
256
a.o
97
0.39
6.75
—
197 3
339
4.82
257
9.0
81
8S00
24S
9.0
98
1.59
0.66
3.94
2.40
2.00
25.4
2.7
3.1
33.1
1974
338
4.70
262
8.0
83
8400
258
10.0
121
0.89
0.72
2.55
0.44
0.36
3.3
1.8
0.5
1.4
7.4
1975
4.96
345
4.29
269
34.0
110
9200
249
30.0
121
0.93
0.04
0.88
3.13
0.89
0.04
1.57
3.4
2.2
1.9
6.1
27.5
1976
<1
359
4.10
274
4.0
77
9900
253
7.0
127
1.26
0.29
1.35
7.05
1.29
2.15
3.30
36.0
3.0
2.9
5.4
46.6
197/
0.17
319
4.60
290
6.0
61
9100
300
10.0
146
0.03
0.04
0.18
1.39
1.45
3.70
2.07
17.6
1.5
3.9
2.4
20.1
1978
0.26
341
4.b0
262
4.0
66
8400
285
7.0
148
0.24
0.09
0.18
2.15
1.31
0.99
1.07
9.4
1.7
1.3
1.4
13.2
1979
0.76
349
4.79
259
4.1)
75
7500
259
9.0
144
0.14
0.08
0.18
0.89
1.25
0.61
0.60
9.3
1.5
o.a
0.9
10.6
1980
2.8
363
4.84
252
11.0
77
7200
281
1.0
158
0.03
0.10
0.08
1.04
0.24
0.25
0.66
6.5
0.4
0.4
0.8
8.1
1981
0.04
369
4.70
249
17.0
77
7100
286
42.0
169
o.oe
0.03
0.06
0.58
0.92
0.44
0.76
3.1
1.1
0.6
0.B
4.6
' Analyses i>ui formed In Hyperion effluent discharges Serial Nob, 001 (l-nille) 002 (S-alle) and 003 (7-mile)
covering Uie | period Jy70 through 1981. Analyses previous to 1973 were performed by four separate laboratories
tiiui KM) rc-bulls were especially subject to largo fluctuations.
2 loujl 151 yr is interpreted to mean Llie sum total o£ the isomers of DOT and Its related canpounds, as followat
cn'imr, pp'mr, np'nno, pp'uno, op'noE and pp'uoe.
3 l-cu analyses included ArocJor 1242 only in 1970f 1242, 1254, and 1260 in 1971j 1242 only In 1972 through 1975j arid
1242 ai*i 1254 since January of 1976. "therefore best results are 1976 onward.
4 I I nut ot UulecLihi lity tor eacli lsaiar of DOT is 0.02 vg/lt for FCU iscnor 0.1 ug/1 for discharge serial nunbers
1)1)1, 002 and raw influent. Limit of detectibility tor each iscmer of DOT is 0.2 ug/1 and for PCBs 1.0 ug/1 for
dibdiarije serial nmiiter 003 (7-raile outfall).
5 lota yenerated hy tlto I..A. City Hyperion laboratory - contained in the annual reports sufcmtlled to the State ot
California itdjional water Quality control board, Los Anjeles Region. The concentrations measured tor discharge
atrial 003 aio total solids, raLhur than suspended solids.
-------
TABLE 13
Existing and Estimated Overall Removal Efficiencies -
Wastewater Treatment Plant
Hyperion
Existing Avanced Primary
Treatment (%)
Partial Secondary Treatment
(150 MGD Secondary) 301(h) (%)
Full Secondary
Treatment (%)
BOD
407
562
854
SS
697
756
854
TICH
30l
525
81.5 + 4.53
DDT
30l
525
81.5 + 4.53
PCB
30*
525
81.5 + 4.53
1 A removal efficiency assumed.
2 Developed from the current influent BOD concentration and the BOD effluent
limittation in Table 10.
3 PCB's Removal in Publicly - Owned Treatment Works - Criteria and Standards
Division, U.S. EPA July 19, 1977, EPA 440/5-77-017.
4 EPA full secondary definition, 40 CFR . Part 133.
5 The estimates for TICH, DDT and PCB removal efficiency are based on weighted
averages of primary and secondary removal. Assumes 150 MGD at 81.5% removal
and 200 MGD at 30% removal.
6 Water Quality Control Plan for Ocean Water of California - Adopted and
effective 1978 - State of California, State Water Resouroes Control Board.
7 Developed frcm the 1981 discharge characteristics for discharge serial number
-------
TABLE 14. Hyperion Wastewater Treatment Plant
Current and Projected Mass Emission Rates
lbs/day (kg/day)
301(h)! pun 2°2
Parameter Current NPDES Existing Treatment Treatment Treatment
Effluent Limits (100 MGD 2°) (150 MGD 2°) (350 MGD 2°)
Flow 420 369 350 350
BOD-30 day 648,000 520,090 367,326 125,225
Avg. (293,932) (236,069) (166.619) (56,802)
SS-30 day 280,000 236,069 181,707 109,024
Avg. (127,008) (107,487) (82,422) (49,453)
TICH 14.0 2.46 1.40 0.44
(6.35) (1.12) (0.64) (0.20)
DDT N/A 0.18 0.11 0.04
(.083) (0.05) (0.02)
PCB N/A 2.33 1.28 0.40
(1.06) (0.58) (0.18)
1 Flow rate per 301(h) application. The current influent concentrations
were used.
-------
5.3 County Sanitation Districts of Orange County
The County Sanitation Districts of Orange County (CSDOC) serve an area
of approximately 200,000 acres and a population of approximately 1.6
million in northeastern Orange County. The service area is divided up
into seven individual districts which collectively operate separate
interceptor sewers and pump stations. The existing sewerage facilities
consist of 500 miles of major interceptor sewers 30 pump stations and
two large regional treatment plants which collect and treat the sewage
from some 23 cities and unincorporated areas. The two regional treatment
facilities are known as Plant No. 1 and Plant No. 2. Plant No. 1 is
located in Fountain Valley California and Plant No. 2 is located in
Huntington Beach, California. Figure 8 is a map depicting the service
area.
The concept of an Orange County Sanitation District Joint Outfall system
began in 1921. Construction of trunk sewers, a screening plant and an
ocean outfall was started in 1923 and placed into operation in the spring
of 1924. The ocean outfall was extended in 1927 to a distance of 3,000
feet into the ocean.
A primary treatment plant was constructed in 1941 in Fountain Valley and
served a population of 103,000 people. Some of these facilities are
still in existence as part of Plant No. 1. In 1951 a second primary
treatment facility, Plant No. 2, was constructed in Huntington Beach.
-------
This plant had a design flow capacity of 18 MGD and included a new 7,000
foot long outfall, 78 inches in diameter. This outfall replaced the
3,000 foot outfall constructed in 1927 and discharged the combined effluents
from the two primary treatment plants. In 1963 Plant No. 1 was expanded
to a 15 MGD trickling filter secondary treatment plant. In 1973 an
additional 46 HGO of secondary activated sludge treatment was added.
Plant No. 1 presently treats 60 MGD. Influent flow to Plant No. 1 enters
the headworks and passes through mechanically cleaned bar screens, aerated
grit chambers and primary sedimentation basins. Twenty million gallons
per day of this primary effluent is treated by the trickling filter
process. The remaining primary effluent flows to an activated sludge
plant along with a portion of the effluent from the trickling filter
plant. The effluent from the activated sludge process is then settled
in secondary clarifiers. Final effluent from Plant No. 1 is transported
to Plant No. 2 or diverted to the Orange County Water Districts Factory
"21" for tertiary wastewater treatment and ground water injection.
Waste Activated sludge from Plant No. 1 is thickened in air floatation
thickeners. Thickened sludge is then pumped to anaerobic digesters and
digested. Digested primary sludge is presently dewatered by centrifugation
and disposed of via truck hauling to a composting facility. Centrate
from the certrifugation of sludge flows to Plant No. 2. Belt presses
will be used for dewatering digested sludge beginning sometime in January
of 1983.
-------
LOS
AN6ELE3
COUNTY
SAN BERNARDINO
COUNTY
pa
i
INDICATES PROJECT AREAS
INDICATES SERVICE AREA
l~°"" »•"
VICIMfTT MAP
RIVERS OE
COUKTT
SAN DIE80
COUNTY
SCALE m MILES
LOCATION MAP—ORANGE COUNTY
Figure 8
-------
Plant No. 2 is a 160 MGD average flow primary treatment facility.
Wastewater treatment at Plant No. 2 consists of mechanical bar screens
and primary sedimentation. New secondary treatment facilities, utilizing
the pure oxygen activated sludge process, are currently under construction.
This new secondary treatment facility will treat 75 MGD of the primary
effluent and is expected to start up in mid-1983.
Raw sludge from the primary settling basins is collected and piped to
the anaerobic digesters. Digested sludge is dewatered via belt presses.
It is then composted and hauled to a landfill. EPA and the State are
currently developing a joint EIS/EIR on the Facilities Plan for the
ultimate sludge management program. Several alternatives including co-
combustion, landfill, and composting are being examined. Figure 9
summarizes the treatment scheme for both Plant No. 1 and Plant No. 2.
The combined effluent from Plant No. 1 and Plant No. 2 is then discharged
to the Pacific Ocean.
CSDOC has three possible discharge points. The primary point, discharge
serial number 001, extends 23,800 feet offshore of the mouth of the
Santa Ana River. Discharge number 001 is a 120 inch diameter outfall
with a 6000 foot diffuser. Discharge serial number 002 is an emergency
discharge point and extends 7,200 feet offshore of the mouth of the
Santa Ana River. Discharge 002 is a 78 inch diameter outfall with a 1,000
foot diffuser. Discharge serial number 003 is also an emergency discharge
point discharging to the Santa Ana River (001 and 002 are regarded as
dischargers to the Pacific Ocean).
-------
In 1977 the CSDOC was issued an NPDES discharge permit jointly by the
California Regional Water Quality Control Board, Santa Ana Region and
the United States Environmental Protection Agency, Region 9. The permit
is summarized in Table 15. The Federal secondary limitations of 30 mg/1
of suspended solids and 30 mg/1 of biochemical oxygen demand were Incorporated
into the permit. California's Ocean Plan limitations on toxic materials
were also incorporated in this permit.
The secondary treatment levels were to be accomplished by July 1, 1977 as
mandated by PL 92-500. Because this deadline could not be met, the state
and the EPA agreed upon an enforcement compliance schedule. The new
compliance dates are also given in Table 15.
The CSDOC is also requesting a variance from these secondary treatment
requirements of the Clean Water Act pursuant to Section 301(h). The
treatment facilities proposed in the 301(h) application for Plant No. 1
and No. 2 are essentially the same as those described for the existing
facilities but include the addition of 75 MGD of pure oxygen activated
sludge treatment at Plant No. 2, scheduled to begin operation in 1983.
The CSDOC based the application for modification of secondary treatment
requirements on an effluent flow of 227 MGD (annual average). The draft
301(h) permit is summarized in Table 16 for the discharge from Plant No.
1 and Plant No. 2.
Full secondary treatment at Plant No. 1 and Plant No. I was planned and
described in the 1979 facilities plan for the CSDOC. The total treatment
capacity for both Plants No. 1 and No. 2 for the year 2000 was described
-------
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CSDOC TREATMENT PLANT NO.2
-------
TABLE 15. Authorization to Discharge Under the National Pollutant Discharge
Elimination System (NPDES)
CA0011604 - County Sanitation Districts of Orange County
Effective Date: August 22,1977
Expiration Date: June 1, 1982 - The Ccmpliancer date for the treatment
levels discribed below was extended to
January 1, 1983 per order number 77-125.
Based on a design flow of 227 MGD.
Effluent Limitations for discharge serial Nos. 001, 002 & 0031.
Parameter
Biochemical
Oxygen Demand
SS
pH
Total Identifiable
Chlorinated Hydra-
Carbons
Units
30-Day
&vg-
7-Day
Avg.
kg/day 26,000 39,000
lbs/day 57,000 85,000
mg/1 30 45
kg/day 26,000 39,000
lbs/day 57,000 85,000
mg/1 30 45
Shall not exoeed 9.0 or be less than 6.0.
kg/day 1.7
lbs/day 3.8
rng/1 0.002
Daily
Maximum
3.4
7.6
0.004
1 The use of discharge serial No. 002 or 003 is prohibited except under
-------
TABLE 16
Permit No. CA0110604 - County Sanitation Districts of Orange County - Plant No. 1
and Plant No. 2 Draft NPDES Permit Requirements Waiver of Secondary Treatment
Requirements
NPDES No. CA0110604 - Based on a design flow of 242 MGD
Effluent Characteristics
Discharge Limitations
Units
30-Day
Average
7-Day
Average
6-Month
Medium
Carbonaceous BOD
kg/day
91,600
137,000
lbs/day
202,000
302,000
mg/1
100
150
Suspended Solids
kg/day
87,000
131,000
lbs/day
192,000
289,000
mg/1
95
143
Total Identifiable
Chlorinated Hydrocarbons
kg/day
lbs/day
mg/1
1.8
4.0
-------
as 285 MGD. This has since been changed to 314 MGD. The ultimate capacity
at Plant No. I is to be limited to 175 MGD while the remaining capacity
is to be provided by Plant No. 1 or upstream reclamation plants. This
plan was developed to meet the secondary treatment levels described in
the current NPDES permit.
Plant No. 1 would utilize the existing 20 MGD trickling filter process
to reduce the loading to the activated sludge process. The activated
sludge process would be converted to pure oxygen activated sludge.
Solids handling at Plant No. 1 would consist of anaerobically digesting
the primary and trickling filter sludges. The waste activated sludge
would be thickened via dissolved air floatation and then digested. The
digested sludge would then be dewatered at Plant No. 2 via belt filter
presses. The dewatered sludge would be trucked to the Coyote Canyon
landfill for processing and disposal.
Full Secondary treatment at Plant No. 2 would consist of 175 MGD of pure
oxygen activated sludge preceded by primary sedimentation. Secondary
clarification would follow the activated sludge process. Primary and
waste activated sludge from Plant No. 2 would be thickened prior to
anaerobic digestion via dissolved air floatation. Anaerobically
digested sludge would be dewatered in solid bowl centrifuges and then
transferred to a landfill.
-------
The current effluent quality from Plant No. 1 and Plant No. 2 is summarized
in Table 17. The effluent limit of 0.002 mg/1 for TICH is currently
being met. Since no improvements to the treatment facilities have occurred
from 1973 to 1982, any observed improvements in the effluent quality are
largely atributable to decreased concentrations in the Influent.
The influent has been controlled since 1976 when the District's present
sewerage use ordinance was established. Quantity and quality limitations
were placed on all wastewater dischargers to the sewer which would adversely
affect either the sewerage systems or the effluent quality. The limit
placed on the total identifiable chlorinated hydrocarbons is 0.02 mg/1.
It is expected that future additions of secondary treatment at plant 1
and plant 2 will also act to improve the effluent quality by improving
the removal efficiency of those facilities. The existing and estimated
removal efficiencies are summarized in Table 18. The treatment efficiencies
estimated here are also dependent upon the ability of the CSD0C to continue
to dispose of their sludge by means other than ocean disposal. Assuming
the influent concentration remains the same as the existing Influent
concentration, the predicted average daily mass emissions can be calculated
for the 301(h) treatment level and the full secondary treatment level.
Table 19 is a summary of the present and predicted mass emissions. The
estimates in Table 19 are developed from the removal efficiencies given
in Table 18.
-------
TABLE 17
Influent and Effluent Characteristics
County Sanitation Districts of Orange County - Plant No. 1 and Plant No. 2
Suspended Solids1'3 BOD1'3 Total DDT1'2 Total PCB1'2 TICH1'2
Influent
mg/1
mg/1
ug/1
ug/1
ug/1
Year
Flow Rate
Influent
Combined
Influent
Combined
Influent
Combined
Influent Combined
Influent
Combined
MGD4
#1
#2
Effluent
#1
#2
Effluent
#1 #2
Effluent
#1
#2 Effluent
#1
#2
Effluent
1970
133
1971
140
300
230
150
280
220
180
1972
147
300
220
150
280
210
170
1973
155
280
220
160
190
210
180
3974
171
300
240
150
190
220
170
3.89
14.72
1975
177
390
270
120
240
250
180
0.69
1.75
12.02
1976
181
410
350
140
290
300
200
0.16
2.69
2.73
1977
185
490
420
130
340
350
200
0.03
1.08
7.60
1978
193
600
460
140
390
320
160
1.70
1.76
1979
202
410
400
150
250
260
150
0.01 0.02
0.04
2.0
1.51
2.0
2.11
1.53
1.95
1980
212
300
230
130
250
220
150
0.02 0.02
0.01
3.3
3.60
2.8
3.32
3.62
1.40
1981
221
270
230
220
220
150
2.6
3.97
1.57
2.60
3.97
1.57
1982
222
220
230
] 16
260
230
150
0.04
0.01
4.10
1 2.65
1.8
4.20
3.15
1.93
1 Summary of Influent and Effluent Quality Data, County Sanitation Districts of Orange County, Director of Operations.
Suhmitted to EPA on December 2, 1982.
2 Influent is sampled 1 to 2 times per year. Effluent is sampled 1 to 2 times per month. All samples are 24-hour
composites. Values are averages of 12 months of data fran the County Sanitation Districts of Orange County, Director
of Operations.
3 24-hour composite, 30 samples per month.
4 Daily readings. Years 1970 to 1976 are taken from the CSDOC 1979 Facilities Plan. Years 1977 to 1982 are taken frcm
-------
TABLE 18. Existing and Estimated Overall Removal Efficiencies
County Sanitation Districts of Orange County
Parameter Existing Treatment1
%
301(h)
Partial Secondary
Treatment
%
Full Secondary
Treatment
%
TICH
PCB
DDT
SS
BOD
45
46
48
38
762
753
61.24
61.24
61.24
855
855
81.5+ 4.56
81.5+ 4.56
81.5+ 4.56
1. Estimated frcm 1982 data obtained from Table 16, using the mean of the influent
values for Plants #1 and #2.
2. Assumes influent BOD = 269 mg/1; percentage removal for BCD fromm an average
combined effluent for BOD and SS. Taken fran the CSDCC 301(h) application, Part
F, Calculation of Effluent Quality.
3. Water Quality Control Plan for Ocean Waters of California. 1978. State Water
Resources Control Board, Sacramento, California.
4'. The estimates for TICH AND PCB removal efficiency are based on weighted averages
of primary and secondary removal. Assumes 135 MGD at 32% removal and 92 MGD at
81.5% removal. DDT removal was assumed to be the same as TICH removal, since no
references were available on DDT.
5. 40 CFR Part 133.
6. U.S. Environmental Protection Agency. 1977. PCB Removal in Publicly-Owned
Treatment Works. Criteria and Standards Division, Office of Water Planning and
-------
TABLE 19 - CSDOC Mass Emission Rates Lbs/day (Kg/day)
Parameter
Flow-MGD
BOD-30 Day
Average
TSS-30 Day
Average
TICH
DCff
PCB
Current NPDES
Limi ts
227
57,000(26,000)
57,000(26,000)
3.8(1.7)
N/A
N/A
301(h) Partial
Existing Treatment (60 MGD (Seoonday Treatment)
Secondary Treatment) (135 MGD Secondary)
222
277,722(125,974)
214,771(97,420)
3.5(1.6)
0.0185(.008)
3.3(1.5)
242
122,223(55,440)!
106,491(48,304)!
2.64(1.19)2
0.028(.012)3
2.42(1.09)2
Full Seaondary2
Treatment (242
MGD Secondary)
242
81,437(36,940)
68,116(30,897)
1.11(0.50)
0.01(0.005)
1.02(0.46)
! Mass emission based on influent BOD concentration of 2690 mg/1; SS influent
concentration of 335 mg/1 and estimated removal efficiency in Table 17.
2 Using the current influent concentration for mass emission calculation and estimated
renoval efficiency in Table 17.
3 Influent concentration used for DDT mass emission rate was frcm current influent
concentration to Plant Number 1 only. The 301(h) value exceeds the existing value
-------
6. COMPARISON OF REGIONAL ORGANOCHLORINE INPUTS
6.1 External Sources of DDT and PCBs
In assessing the probable Impacts of the Issuance of the proposed
301(h) modified NPDES permits on the California brown pelican, it is
useful to evaluate the Importance of sewage discharges as sources of DDT
and PCBs relative to other modes of organochlorine input to the
Southern California Bight. Seven input routes were investigated
in an EPA report entitled, A Synoptic Survey of Chlorinated Hydrocarbon
Inputs to the Southern California Bight (Young et al., 1975, 1981).
The routes investigated were municipal wastewater, direct industrial
discharge, vessel antifouling paints, harbor flushing, surface runoff,
dry aerial fallout, and ocean current advection. We have expanded
this discussion to include an evaluation of accidental spills and
storm water runoff from the Montrose Chemical Corporation property.
In addition, a separate discussion of sewage sludge discharged from
the Hyperion treatment plant's 7-mile outfall is included. In this
assessment, current advection is assumed to provide no net transport
of chlorinated hydrocarbons into the SCB.
Table 20 provides a comparison of the relative magnitude of several
external organochlorine sources. Although data for DDT sources other
than municipal wastewater are less comprehensive than municipal wastewater
data, it appears that the major input routes for DDT and PCBs are
aerial fallout and municipal wastewater. Figure 10 is a diagram
representative of the distribution of chlorinated hydrocarbons in
the coastal environment.
-------
Municipal Wastewater and Sludge
This was the dominant source of chlorinated hydrocarbon input to the
SCB through the early 1970's. Although DDT emissions were not monitored
prior to 1970, LACSD estimates that an average of 211-212 kg of DDT
were discharged daily by the JWPCP for the years 1956 through 1970
(Tetra Tech, Inc., 1981). Although this estimate is speculative
(Jukes, 1982), it represents about 10 times the amount of pesticides
estimated to be carried into the Gulf of Mexico by the Mississippi
River (Butler, 1969). Since the implementation of measures to reduce
this input (discussed in Section 5 of this assessment), the municipal
wastewater input of DDT and PCBs has declined dramatically. DDT
continues to decrease at a rate of 20 to 30 percent per year. The
smajor source is the JWPCP, and LACSD speculates that continued DDT
emissions result from residual deposits remaining in the sewer trunk
lines from pre-1971 inputs. Overall PCB emissions have not changed
significantly since 1979.
In addition to its sewage effluent discharge, the City of Los Angeles
Hyperion Treatment Plant presently discharges approximately 140
dry tons per day of digested sludge through a seven-mile ocean outfall.
The average annual emissions of DDT and PCBs from this outfall for
the period 1972 - 1979 were 25 kg and 132 kg, respectively (Bascom,
1980). Based on the January 1983 Hyperion discharge monitoring
report, TICH emissions have declined to approximately 25 kg/year.
-------
TABLE 20 - Summary of Chlorinated Hydrocarbon Inputs to the Southern California
Bight (Adapted from Young, 1981).
fcg/yr
Route
Year
Total DDT
Total PCB
Muni.
Wastewater^
1971
21,700
8,730
It
II
1972
6,540
19,490
II
II
1973
3,830
3,390
II
II
1974
1,570
5,420
ii
II
1975
1,150
3,070
II
II
1976
970
2,820
II
II
1977
780
1,560
II
II
1978
1,050
590
II
fl
1979
728
1,466
II
II
1980
644
1,129
II
II
1981
474
1,250
II
tl
1982
292
1,085
EACSD
(301(h) Scenario)
128
77
CSDOC
II II
4
398
CIA
II II
18
212
LACSD
(full secondary
66
40
soenario)
CSDOC
II II
2
158
CLA
II II
6
66
Industrial Discharge
1973-74
40
100
Antifouling Paint
1973
1
1
Surface Runoff2
1971-72
100
190-280
Surface Runoff2
1972-73
320
250-830
Aerial Fallout^
1973-74
1,800
1,800
Accidental Spills
N. A.
N. A.
Harbor Flushing
~~~
25
50
1 Refers to the sum of wastewater inputs originating frcm the five major
municipal wastewater dischargers to the Southern California Bight:
LACSD, CLA (includes sludge discharge), CSDOC, City of San Diego, and
City of Oxnard. LACSD, CLA, and CSDOC account for approximately
85% of the total DDT and PCB emissions.
2 Does not include measurements of surface runoff frcm Montrose Chemical
Corporation to Los Angeles Harbor via the Daningues Channel.
3 Aerial inputs since 1973 appeared to be decreasing at an average rate
-------
Figure 10. Schematic depiction of the fate and distribution
of chlorinated hydrocarbons in the coastal envir-
onment (taken from Cox, 1972) .
AIRBORNE
RUNOFF-
AIR-SEA INTERFACE
SOLUTION
ADSORBED TO ^
PARTICLES
PHYTOPLANKTON
+ DETRITUS—^
SEWAGE
—PYCNOCLINE
SEDIMENTATION
BENTHOS
SECONDARY
CONSUMERS
SURFACE-FEEDING
SECONDARY
CONSUMERS
MIXED LAYER
200PLANKT0N +
PLANKTOTROPHIC
-------
Hyperion's discharge of sewage sludge Into the ocean has been a water
quality concern for many years and the subject of an EPA enforcement
action since 1977. An agreement was reached with the City of Los
Angeles in 1980 resolving litigation that had been pending before the
U.S. District Court for the Central District of California. This
consent decree requires that the City terminate the ocean discharge
of sludge before July 1, 1985 by constructing and operating alternative
sludge management facilities. The City's current NPDES permit also
requires the cessation of the sludge discharge by the sane date.
During the development of the LA/OMA Sludge Management Program (USEPA,
1980c), the City of Los Angeles selected the Hyperion Energy Recovery
System (HERS)) which involves the Carver-Greenfield dehydration
process and thermal processing of sludge for volume reduction and
energy recovery. The EPA has consulted with the USFWS and the National
Marine Fisheries Service on the effects to endangered species of
ceasing the sludge discharge and constructing the HERS facilities
(biological opinions dated 16 January 1979, is October 1980, and 20
August 1982).
Aerial Fallout
Aerial fallout is now thought to be the predominant route of
organochlorine entry to the ocean waters off of Southern California,
although there are no recent studies available to update Young's
-------
studies conducted in the mid 1970's. Aerial fallout measurements
were conducted using a glass plate collection technique developed
by Vance McClure of the National Marine Fisheries Service. The
greatest inputs were found to occur off the densely populated Los
Angeles Orange County Basin. DDT fallout was found to be heaviest
in the vicinity of the Montrose Chemical Corporation and a sanitary
landfill which previously received DDT wastes from the Montrose
plant. The aerial DDT sources probably include fugitive dust from
the manufacturing process as well as dust from the surrounding
property (soil and storm runoff analyses have indicated high DDT
levels) and from the sanitary landfill. Fallout rates of both DDT
and PCBs are slowly decreasing.
Industrial Discharges and Antifouling Paints
Direct industrial discharge (i.e., wastes from industries which
discharge directly to the ocean rather than through a municipal
treatment plant) was found to be a relatively insignificant source
of DDT and PCBs, as were vessel antifouling paints. The latter was
probably a significant source of PCBs prior to the 1971 nationwide
restrictions on the use of PCBs, which had been employed as plasticizers
in paints.
Harbor Flushing
High PCB contamination in coastal harbors prompted researchers to
investigate the possibility that significant levels of PCBs might be
moving from the harbors to the open ocean during periods of tidal
-------
flow. On the basis of analyses of water samples taken from the mouths
of San Pedro, Newport, and San Diego Harbors, it was determined that
the maximum net transport of total DDT and PCBs from the harbors to
the adjacent ocean waters was relatively insignificant. This study
did not consider the transport of DDT and PCBs via sediment drift or
harbor dredging operations utilizing ocean disposal sites.
Surface Runoff
In most coastal areas, surface runoff constitutes the major source of
pesticide contamination to the coastal ecosystem; however, surface
runoff in arid and densely populated Southern California is less
significant than fresh water discharge from sewers. Based on the
analysis of water samples taken from the mouths of four major drainage
channels - the Los Angeles River, the Santa Clara River, the Santa
Ana River, and Ballona Creek - Young concluded that surface runoff
was only a secondary contributor of ocean DDT and PCB contamination.
In arriving at an estimated total input for all surface waters, the
results of water quality sampling in these four major channels were
applied to other drainages. No sampling appears to have been performed
at a potential hot spot: the Dominguez Channel which receives storm
water runoff from the Montrose Chemical Corporation property.
There is reason to suspect that DDT continues to be transported
into Los Angeles Harbor via surface runoff collected from the Montrose
property. Soil samples from around the Montrose site have indicated
-------
a high degree of DOT contamination, and recent Mussel Watch data
show an increase in total DDT accumulated by mussels in L.A. Harbor
(Jim Steele, California Department of Fish and Game, personal communi-
cation). L.A. Harbor mussels contain DDE concentrations nearly
three times greater than mussels from a coastal station near the
JWPCP outfall, suggesting continued inputs (Martin, et al, 1982).
The California Department of Fish and Game has received anonymous
phone calls reporting DDT spills witnessed during the onloading of
sacks of DDT for shipment in the Port of Los Angeles. The reports
claim that the spilled contents of broken sacks have been swept into
the water by longshoremen. DFG has not been able to verify this
information (Jim Steele, DFG, personal communication). Montrose
completely dismantled their DDT manufacturing facilities early this year.
As a result of an investigation by EPA Region 9 personnel (Simanonok,
1983), it was determined that surface runoff from the Montrose property
contained significant concentrations of DDT. The runoff is eventually
discharged to Los Angeles Harbor. On May 10, 1983 the EPA issued an
administrative order to Montrose to cease and desist from further
discharging and to submit a sampling and clean-up plan for the site
and surrounding property.
6.2 Continuing Contribution of Historical DDT Reservoir in Ocean Sediments
The relative importance of the continued manifestation of earlier
DDT discharges from Los Angeles County's outfall which remain in
bottom sediments around the outfall was one of the primary concerns
-------
raised by U.S. Fish an Wildlife Service in their May 14, 1982 letter.
Although the results of past studies cannot provide a definitive ratio
for DDT released from bottom sediments and DDT released from continuous
municipal discharge, certain qualitative conclusions can be drawn
from available information.
The low water solubility of DDT (1.2 ppb) promotes its uptake by
sediments, other particulate matter, and living organisms. Dimond
et al (1972) describe a striking example of DDT persistence in
sediments for a period up to 10 years after only one application of
the pesticide. A 1974 study of DDT in sediments around the major
Southern California sewage outfalls found that between 180 and 250
metric tons of the pesticide are contained in the upper 30 centimeters
of a 48 square kilometer area around the JWPCP outfall system
(McDermott et al, 1974). Pesticide contamination of sediments around
the other outfalls is 3 to 4 orders of magnitude lower (Young et
al, 1976).
LACSD discusses the sediment contamination in detail in their 301(h)
application. The seabed accumulation of solids under several levels
of sewage treatment was projected to determine the optimal means of
reducing the availability of the large DDT reservoir in the sediments.
LACSD concludes that partial secondary treatment may be as effective
as, or more effective than, full secondary treatment or even zero
-------
discharge in suppressing contaminants on the ocean bottom. This
conclusion is based on models and historical data that indicate that
solids discharged under existing conditions - less contaminated
than a decade ago due to improved source control and treatment -
effectively bury the more contaminated sediments. Removal of these
solids under full secondary treatment or total elimination of settleable
solids may result in the gradual erosion and exposure of the DDT
contaminated sediments, according to the LACSD analysis.
Studies on DDT uptake in marine fishes in the Southern California
Bight have found that, despite the major decreases in DDT and PCB
emissions after 1971, elevated'levels of DDT and PCBs have persisted
in bottom and, to a lesser degree, in water column feeding fish.
For the period from 1970 to 1977, data suggests an overall decrease
of total DDT residues-in water column feeders by a factor of three,
while bottom feeding fish experienced no measurable decrease (Smokier,
et al, 1979). Since wastewater emissions of total DDT during this
same period dropped by a factor of 30, Smokier proposes that the
DDT sediment reservoir is the likely source of persistent contamination
to organisms. More recent monitoring data provided by the LACSD
indicate a slow decline of DDT levels in bottom feeding fish.
Biomonitoring studies utilizing inter tidal mussels (Mytilus californlanus)
have been useful in characterizing water column contamination in
coastal waters, under the California State Mussel Watch Program.
Mussel biomonitoring was also performed around the major Southern
-------
California wastewater outfalls in a trial study from 1974 to 1976
(Young, et al, 1981). Specimens were placed at five different depths
from surface to bottom on a special taut-line buoy system suspended
above the outfalls.
The results from the experiment performed in the summer of 1974 at
the JWPCP outfalls showed a direct relationship between uptake of
DDT and PCBs and proximity of the mussels to the contaminated bottom
sediments and to the wastewater plume which, during the summer
months, is largely trapped beneath the thermocline. To further
examine this effect, the experiment was repeated in the winter season
(January 1976) when no significant thermocline develops and the
wastewater plumes are capable of rising to the surface. The winter
experiment was also expanded to include the Hyperion 7-mile sludge
outfall and the CSDOC outfall off Newport Beach.
The significant finding of this second study was that the steep
vertical gradients in DDT and PCB uptake levels seen during the
summer experiment were greatly reduced. Whereas bottom specimen
concentrations had exceeded those at the surface by a factor of 10
in the presence of a thermocline, corresponding concentrations observed
in the winter experiment for the JWPCP and CSDOC outfalls generally
agreed within a factor of 2, with middle depth specimens often
containing concentrations equal to or exceeding those measured in
bottom mussels. The Hyperion sludge outfall maintained a strong
correlation between depth and concentration, probably as a result of
the high solids content of the sludge.
-------
Young concludes that the results of the buoy experiments indicate
in contrast to other studies referenced above that the wastewater
plume rather than the contaminated bottom sediments is the source of
chlorinated hydrocarbon uptake in aquatic organisms; however, the
possibility that conditions which cause the wastewater plume to
rise might also resuspend contamination from the bottom sediments
is not discussed. These experiments have not been duplicated since
1976, although the concentration in LACSD's wastewater effluent has
declined during this period from 1.79 ug/1 to 0.47 ug/1.
The general consensus among researchers is that it is not possible
to accurately trace the sources of the DDE still found at chronic
levels in pelican eggshells, in spite of our present understanding
of the pelican food web, the dynamics of DDT and its derivatives,
and advances in biomonitoring. In Section 8 of this report, we
propose measures which could be undertaken by the permittees to help
improve our understanding of the situation.
-------
7. PROBABLE IMPACTS OF 301(h) ACTIONS
In assessing the probable Impacts of the proposed 301(h) permit actions
on the California brown pelican and comparing these Impacts to those
likely to occur under the no action or full secondary treatment scenarios,
it is necessary to make several assumptions regarding future environmental
conditions in Southern California* If one assumes that the character of
wastewater influent and treatment removal efficiencies (both theoretical
and empirical) remain the same,* and that wastewater flows increase
according to present projections, then a rough comparison between the
mass emissions of DDT and PCBs under the three scenarios may be calculated
(Table 21). The accuracy of these projections is limited not only by the
aforementioned assumptions, but also by the inherent imprecision of the
monitoring data for substances present in such low concentrations and
measured monthly. Although the actual numbers presented in Table 21 may
^Studies have shown the chlorinated hydrocarbon removal efficiency to
vary with the concentrations in the influent to treatment plant (USEPA, 1979).
This variable is not considered here due to the scarcity and lack of
precision of the monitoring data used to generate Table 21.
-------
lack accuracy, they nevertheless demonstrate a likely relationship between
the scenarios: the 301(h) scenario lies somewhere between the status
quo and emissions achievable under full secondary treatment* At issue is
whether the difference between chlorinated hydrocarbon emissions under
full secondary treatment and under treatment commensurate with the proposed
301(h) permits is significant where the brown pelican is concerned.
Based on the information reviewed during the course of this assessment,
it is unlikely that the incremental decrease in emissions that would be
realized under full secondary treatment would have a noticeable effect on
brown pelican productivity in the Southern California Bight. There are
several considerations which lead to this conclusion:
1) DDT and PCB emissions are steadily declining in spite of the fact
that little improvement in treatment facilities has taken place in
recent years. Regulatory bans, source control measures, and the
gradual flushing of the sewer lines appear to be more significant
factors than the efficiency of the treatment plants in removing these
substances.
2) The persistence of DDT in bottom sediments appears to overshadow the
input from external sources. The release of DDT from these sediments
is likely to continue for the foreseeable future.
3) Other external sources of DDT and PCBs, such as aerial dispersion and
surface runoff, appear to be more significant then current wastewater
inputs.
-------
Table 21. Projected mass emission characteristics for LACSD, CSDOC, and
L.A. City, in kg/yr. Precision is limited, since values are based on
data from tables 8, 13, and 18 and do not consider potential variations
in wastewater flow and influent characteristics.
1982 301(h) Full Secondary
Conditions Scenario Scenario
DDT 259 128 66
LACSD
PCB 150 77 40
DDT
CSDOC
PCB 548 398 158
DDT
30
18
LA City
PCB
387
212
66
DDT
292
150
74
Total
PCB
1085
687
-------
4) Several factors unrelated to DDT contamination significantly impact
on the productivity of the brown pelican in Southern California.
Variables such as food availability and human disturbances make it
impossible to develop a direct correlation between pollutant levels
and reproductive success.
In conclusion, although there is insufficient information for tracing the
pathway of the DDT residues in pelicans to the ultimate source, it is
likely that the persistence of the contaminant in ocean and harbor
sediments is the major reason for its persistence in pelicans. Recommenda
tions for improving our understanding of this question are proposed in
the final section of this report.
-------
8. RECOMMENDATIONS
As a condition to receiving variances from secondary treatment requirements,
each discharger is required to have an extensive monitoring program to
evaluate the impact of the discharge on the marine biota, demonstrate
compliance with applicable water quality standards, and measure toxic
substances in the discharge (40 CFR 125.62). The details of the proposed
monitoring programs for LACSD, L.A. City/HyperIon, and CSDOC have not
been finalized, but each program would contain provisions for the analysis
of wastewater Influent, wastewater effluent, sediments, and ocean water
quality; and surveys of benthic infauna, fish, and macroinvertebrates.
In addition, LACSD is proposing a 1 year pilot biomonitoring program
utilizing mussels suspended at several depths in the outfall regions.
The following measures are recommended for inclusion as additional
requirements for 301(h) permit issuance, and may form a basis for resolu-
tion of concerns regarding endangered species:
1) Chemical analyses of ocean water samples taken in 1972 and 1973 showed
concentrations of DDT in excess of the EPA criterion for saltwater
aquatic life, which had been derived on the basis of studies of DDT's
effects on brown pelicans. More current data on DDT levels in the
-------
ocean and harbor waters of the Southern California Bight should be
generated by the proposed 301(h) permittees to aid in tracing the
sources of DDT and its derivatives which persist in the California
brown pelican population.
2) Periodic analyses of chlorinated hydrocarbon concentrations should be
performed on plankton samples from the sewer outfall regions and from
control stations in the Southern California Bight to determine whether
the wastewater discharges constitute a significant source of
contamination relative to other non-point sources such as aerial discharge.
3) There is only scattered data on DDT levels in pelican food sources.
Given our present understanding of chlorinated hydrocarbon biomagnifi-
cation through the food chain, a comprehensive program of monitoring
DDT residues in anchovies would provide valuable information regarding
the sources of contamination.
4) A biomonitoring program utilizing mussels suspended at several depths
in the outfall regions should be developed by all of the dischargers.
These programs would provide valuable information on the sources and
scale of pollutant effects attributable to wastewater discharges.
5) The closure and dismantling of the Montrose DDT manufacturing facility
should be closely monitored by EPA or the State Department of Health
Services to minimize releases of DDT. The surrounding property should
be examined to determine whether significant residual contamination
poses a serious problem.
-------
BIBLIOGRAPHY
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L.R. Deweese, and W.G. Edgecomb. 1975. Brown Pelicans: Improved
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Joint Water Pollution Control Plant Application for Modification
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Works Which Discharge into Marine Waters; 3 Volumes. LACSD,
Whittier, California.
-------
County Sanitation Districts of Orange County. 1979. Application
for NPDES Modification, Clean Water Act of 1977 Section 301(h); 3
Volumes. CSDOC, Fountain Valley, California.
J.L. Cox. 1972. DDT in Marine Plankton and Fish in the California
Current. CalCOFI Report, 16: 107-111.
J.B. Dimond, A.S. Getchell, and J.A. Blease. 1972. Accumulation
and Persistence of DDT in a Biotic Environment. J.Fish. Res.
Board of Canada, 26: 1877-1882.
Food and Drug Administration. 1972. Final Environmental Impact
Statement, Rule Making on Polychlorinated Biphenyls. Department of
Health, Education and Welfare, Washington, D.C.
R. Ghirelli, F. Palmer, R. Severeid, T. Spielman, and M. Jung.
1982. Draft Polychlorinated Biphenyls (PCBs) Report. State
Water Resources Control Board, Sacramento, California.
A.M. Godfrey and L.V. Fondahl. 1982. Biological Assessment: Pos-
sible Impacts of the Hyperion Energy Recovery System on the El
Segundo Blue Butterfly, the California Brown Pelican, and the Calif-
ornia Gray Whale. U.S. Environmental Protection Agency, Region 9,
San Francisco, California.
F. Gress. 1981. Reproductive Success of Brown Pelicans in the
Southern California Bight, 1980. State of California, the Resources
Agency, Department of Fish and Game. Job Progress Report, Job
V-ll.l (July 1981).
F. Gress and D.W. Anderson. 1982. The California Brown Pelican
Recovery Plan (Draft). U.S. Fish and Wildlife Service, Portland,
Oregon. In Preparation.
T.H. Jukes. 1982. DDT in the Sewers. Science, Vol. 218, 29 Octo-
ber 1982.
L.A. Klapow and R.H. Lewis. 1979. Analysis of Toxicity Data for
California Marine Water Quality Standards. Journal of the Water
Pollution Control Federation, Vol. 51, No. 8.
J.O. Keith. 1978. Synergistic Effects of DDE and Food Stress on
Reproduction in Brown Pelicans and Ring Doves. PhD dissertation,
Ohio State University.
J.S. MacGregor. 1974. Changes in the Amount and Proportions of
DDT and its Metabolites, DDE and DDD, in the Marine Environment
off Southern California. Fishery Bulletin: Vol. 72, No. 2.
M. Martin, D. Crane, T. Lew, and W. Sato. 1980. California Mussel
Watch: 1979-1980, Part II, Synthetic Organic Compounds in Mussels,
Mytilus cali fornianus and M_j_ edulis, Along the California Coast
and Selected Harbors and Bays. Water Quality Monitoring Report
80-8, State Water Resources Control Board, Sacramento, California.
-------
M. Martin, D. Crane, T. Lew, and W. Seto. 1982. California Mussel
Watch: 1980-1981, Part III, Synthetic Organic Compounds in Mussels,
M. californianus and M_^ edulis, From California's Coast, Bays and
Estuaries. Water Quality Monitoring Report 81-11TS, State Water
Resources Control Board, Sacramento, California.
D.J. McDermott, T.C. Heesen, and D.R. Young. 1974. DDT in Bottom
Sediments Around Five Southern California Outfall Systems. Southern
California Coastal Water Research Project, Long Beach, California.
D.J. McDermott, D.R. Young, and T.C. Heesen. 1975. Polychlori-
nated Biphenyls in Marine Organisms Off Southern California. South-
ern California Coastal Water Research Project, Long Beach, Calif-
ornia.
A.J. Mearns and D.R. Young. 1978. Impact of Nearshore Development
on Open Coastal Resources. 23-47 _In J.N. Baskin, M.D. Dailey, S.N.
Murray, and E. Segal (eds.), the Urban Harbor Environment, Poc.
First Symposium. So. California Ocean Studies Consortium, Harbor
Plaza, Long Beach, California.
A.J. Mearns and T. O'Conner. 1982. Biological Effects Versus Pol-
lutant Inputs: the Scale of Things. Interagency Workshop on Meaning-
ful Measures of Water Pollution Effects, Pensacola Beach, Florida.
In Press.
D.S. Miller, A. Seymour, Jr., D. Shoemaker, M.H. Windsor, D.B.
Peakall, and W.B. Kinter. 1975. Possible Enzymatic Basis of
DDE induced Eggshell Thinning in the White Pekin Duck, Anas
platyrhychos. Bull. Mt. Desert Isl. Biol. Lab.
H.M. Ohlendorf, R.W. Risebrough, K. Vermeer. 1978. Exposure
of Marine Birds to Environmental Pollutants. U.S. Department of
the Interior, Fish & Wildlife Service, Wildlife Research Report 9.
D.B. Peakall. 1970. Pesticides and the Reproduction of Birds.
Scientific American, Vol. 222, No. 4.
R.W. Risebrough, B.W. deLappe, E.F. Letterman, J.L. Lane, M.
Firestone-Gillis, A.M. Springer, and W. Walker II. 1979.
California Mussel Watch: 1977-1978, Volumes I and III. Water
quality Monitoring Report 79-22. State Water Resources Control
Board, Sacramento, California.
S. Simanonok and E. Pimentell. 1983. U.S. Environmental Pro-
tection Agency Region 9, Toxics and Waste Management Division,
Investigation Report: CERCLA Investigation, Montrose Chemical
Corporation; Report No. C(83)E002. U.S. EPA, San Francisco, CA.
P.E. Smokier, D.R. Young, K.L. Gard. 1979. DDTs in Marine
Fishes Following termination of Dominant California Input: 1970-
1977. Marine Pollution Bulletin, Vol. 10, pp. 331-334.
-------
Southern California Coastal Water Research Project. 1978. The
Effects of the Ocean Disposal of Municipal Waste. SCCWRP Summary
Report, Long Beach, California.
State Water Resources Control Board. 1978. Water Quality Control
Plan - Ocean Waters of California. Sacramento, California.
V.F. Stout and F.L. Beezhold. 1981. Chlorinated Hydrocarbon
Levels in Fishes and Shellfishes of the Northeastern Pacific
Ocean, Including the Hawaiian Islands. Marine Fisheries Review,
Vol. 43, No. 1.
Tetra Tech, Inc. 1981a. Technical Evaluation of Application for
Modification of the Requirements of Secondary Treatment, Hyperion
Treatment Plant, City of Los Angeles. Tetra Tech, Inc., Bellevue,
Washington.
Tetra Tech, Inc. 1981b. Technical Evaluation of County Sanitation
Districts of Los Angeles County Joint Water Pollution Control
Plant Section 301(h) Application for Modification of Secondary
Treatment Requirements for Discharge into Marine Waters. Tetra
Tech, Inc., Bellevue, Washington.
Tetra Tech, Inc. 1981c. Technical Evaluation of the County
Sanitation Districts of Orange County, California, Section 301(h)
Application for Modification of Secondary Treatment Requirements
for Discharge into Marine Waters. Tetra Tech, Inc., Bellevue,
Washington.
U.S. Department of the Interior, Fish and Wildlife Service.
1978. Fisheries and Wildlife Research. Washington, D.C.
U.S. Environmental Protection Agency. 1975. DDT - A Review of
Scientific and Economic Aspects of the Decision to Ban Its Use as
a Pesticide. EPA Report No. EPA-540/1-75-022.
U.S. Environmental Protection Agency. 1977a. CSDOC Wastewater
Management Program, Environmental Impact Statement/ Environmental
Impact Report. EPA Region 9, San Francisco, California.
U.S. Environmental Protection Agency. 1977b. The Joint Outfall
System Facilities Plan of the Sanitation Districts of Los Angeles
County, Environmental Impact Statement/ Environmental Impact
Report. EPA Region 9, San Francisco, California.
U.S. Environmental Protection Agency. 1977c. PCB Removal In
Publicly-Owned Treatment Works. Criteria and Standards Division,
Office of Water Planning and Strategy, EPA Report No. EPA-440/5-7-
77.
U.S. Environmental Protection Agency. 1979. Water Related
Environmental Fate of 129 Priority Pollutants; Vol. I. EPA Report
No. EPA-440/4-39-029a.
-------
U.S. Environmental Protection Agency. 1980a. Ambient Water
Quality Criteria for Polychlorinated Biphenyls. Criteria and
Standards Division, Office of Water Planning and Standards, EPA
Report No. EPA-440/5-80-088.
U.S. Environmental Protection Agency. 1980b. DDT Ambient Water
Quality Criteria. Criteria and Standards Division, Office of
Water Planning and Standards, EPA Report No. EPA-440/5-80-038.
U.S. Environmental Protection Agency. 1980c. Proposed Sludge
Management Program for the Los Angeles/Orange County Metropolitan
Area, Draft Environmental Impact Statement/Environmental Impact
Report. EPA Region 9, San Francisco, California.
A. Wetmore. 1945. A Review of the Forms of the Brown Pelican.
Auk. 62: 557-586.
D.R. Young. 1975. A Synoptic Survey of Chlorinated Hydrocarbon
Inputs to the Southern California Bight - Annual Progress Report.
EPA Grant R801153.
D.R. Young, T.C. Heesen, and D.J. McDermott. 1976. An Offshore
Biomonitoring System for Chlorinated Hydrocarbons. Marine
Pollution Bulletin, Vol. 7, No.8.
D.R. Young, D.J. McDermott, and T.C. Heesen. 1976. DDT in
Sediments and Organisms Around Southern California Outfalls.
Journal of the Water Pollution Control Fed., Vol. 48, No. 8.
D.R. Young, T.C. Heesen, G.N. Esra, and E.B. Howard. 1979. DDE-
Contaminated Fish Off Los Angeles Are Suspected Cause in Deaths
of Captive Marine Birds. Bull. Environ. Contam. Toxicol. 21, 584-
590.
D.R. Young, T.C. Heesen, D.J. McDermott. 1981. Synoptic Survey
of Chlorinated Hydrocarbon Inputs to the Southern California
Bight, Volumes I and II. EPA Report No. EPA-600/3-81-031a&b.
RESEARCHERS CONSULTED
Daniel W. Anderson, University of California, Davis, CA
Lawrence Blus, U.S. Fish and Wildlife Service, Corvallis, OR
Franklin Gress, University of California, Davis, CA
Richard Klingbeil, Department of Fish and Game, Long Beach, CA
David Lenhart, U.S. Fish and Wildlife Service, Portland, OR
Michael Martin, Department of Fish and Game, Monterey, CA
Alan Mearns, NOAA Office of Marine Pollution Assessment, Seattle, WA
Harry M. Ohlendorf, U.S. Fish and Wildlife Service, Davis, CA
Norman Richards, U.S.E.P.A., Gulf Breeze, Florida
Henry Shaffer, Southern California Coastal Water Research Program,
Long Beach, CA
James Steele, Department of Fish and Game, Long Beach, CA
Virginia Stout, National Marine Fisheries Service, Seattle, WA
David Young, Dames and Moore, Los Angeles, CA
-------
COMMENTS"AND RESPONSES
-------
SPEED-letter
K. P. LINDSTROM & ASSOCIATES
1177 BROWNWYK DRIVE
SACRAMENTO, CALIFORNIA 95822
(916) 447-5893
To Date April 8, 1983
Mr. Greg Baker s ht 301^ Brown Pelican Biologica
U. S. Environmental Protecttorr- duojecT TT7T—"Tr
Agency, Mail Code-W-5-1 Assessment
215 Fremont street
San Francisco, CA. 94105
Enclosed is some background information on the present discharger
position with regard to the use of mussels for monitoring the
water column in the vicinity of deep ocean outfalls. This will help
clarify the recommendations which, are being suggested in the 301(h)
hiologica1 assessment which will soon be sent out for review.
Kris
^1 . 1 -1 ¦—- ¦V'j'rs g'j»ivr ? ' ''SIV, '"»f? ""'wj1 '^r»7'»r"'w 'a
- • - »- -- ' - -*•*'. -J ^ .-t W - ... A.,* 1 .i«- . s t .. .* .1
-------
Cw"kv-^. cho
£v£>'v»vOfct-€oj 4$ &Lll ^ier-c.<
Response to
EPA Tentative 301(h)
Ocean Waiver Decision
and Proposed Revised
Monitoring Program
County Sanitation Districts
of Orange County.California
-------
IN SITU BIOASSAYS USING MUSSELS
In the District's original application, it was proposed
that mussels be used for in situ bioassay monitoring of the out-
fall discharge in and around the ZID. The purpose of the in situ
bioassays are to: (1) measure the bioaccumulation of toxic pol-
lutants by a marine organism and (2) measure any adverse effects
such as death, abnormalities, and physiological stresses caused
by the discharge.
The California State Water Resources Control Board (SWRCB)
and the U.S. Environmental Protection Agency (EPA) have estab-
lished research and monitoring programs which use bay (Mytilus
edulis) and the California coastal (M^ californianus) mussels for
the first aforementioned purpose. In 1977 the SWRCB established
a State Mussel Watch (SMW) Program. The SMW has monitored the
bioaccumulation of selected trace metals and organic compounds
along the embayments and coast of California. Several SMW annual
reports describing the results have been published. In brief sum-
mary are some major points on the use of mussels for monitoring
toxic pollutants and biological responses:
1. Resident and transplanted mussels are good accumulators
of certain trace metals, pesticides, petroleum compounds, and
PCBs. Correlations between certain metals have been shown. How-
ever, the effectiveness of mussels in bioaccumulating the remaining
list of EPA priority pollutants is unknown.
The analytical methodology for detecting and quantifying
-------
compounds in tissue are developmental and require an intercalibration
program with specialized research facilities for quality results.
Chromatograms with "unidentified peaks", which represent unidenti-
fied hydrocarbons, were found in mussels from all of the SMW
stations. It is not known if these "unidentified peaks" are
environmental pollutants or toxic substances.
3. The SMW studies had fouling problems with the transplanted
mussels. In fact, some of the samples were believed to be of
"somewhat questionable value". It is thought that fouling by
small barnacles and mussel spat limits the organism's ability to
obtain enough of the surrounding water, thereby limiting feeding
and growth. The technique of transplanting mussels needs to be
refined to reduce the fouling problem.
4. To obtain valid trace metal bioaccumulation data, the
transplanted mussels were collected after six months' exposure.
This period was selected to ensure that chemical equilibrium of
the trace metals in the mussels was attained.
5. There is a need to investigate the influence salinity
exerts on trace metal concentrations in mussel tissues.
6. The use of transplanted mussels to monitor environmental
pollutants is promising but work needs to be continued in
refining the field and laboratory procedures.
7. And, lastly, the bioaccumulation of certain toxic
pollutants by mussels does not indicate adverse biological
effects. The SWRCB recognized this drawback and initiated a
major study to interpret the effect of elevated levels of toxic
-------
Effects Assessment", will identify which toxic substances are
primarily responsible for the decrease in mussel "Scope for
Growth" (SFG). The SFG index gives a numerical value for how
much energy the mussel has available for growth and reproduction.
The higher the SFG value, the healthier the mussel is. Comple-
tion of this study is scheduled for sometime in 1983 or 1984,
depending on the need for additional work.
In view of the limitations in using transplanted mussels in
monitoring EPA's priority pollutants and the inability to inter-
pret the meaning of elevated levels of bioaccumulated toxics in
mussels, we can conclude that it is premature to initiate the
use of mussels for in situ bioassays. Much more work is needed
in refining the field and laboratory methodologies as well as
identifying the effects of transplanting. Research is already
underway by the SWRCB and EPA.
The Districts do, however, support the concept and pilot
program effort proposed by the Los Angeles County Sanitation
Districts and will follow the progres of their work. Should
the use of mussels for in situ bioassays prove to be effective
of toxic pollutants, the CSDOC may implement such a program at
-------
California Ocean Dischargers
P.O. BOX 8127, FOUNTAIN VALLEY. CALIFORNIA 92709
Large Dischargers
Representative 9laka Anderson
(714) 540-2910
Small Dischargers
Representative Felix Martinez
(
March 31, 1983
California State Water Resources
Control Board
P. 0. Box 100
Sacramento, CA 95801
Attention: Mr. John Huddleson, Chief
Division of Technical Services
Subject: Position Papers of California Ocean Dischargers
on the Draft Ocean Plan
Gentlemen:
Transmitted herein are position papers of the California Ocean Dischargers writ-
ten in response to the Draft Ocean Plan issued by the State Water Resources
Control 8oard (SWRCB) in January 1983. The California Ocean Dischargers is an
informal association of POTWs. It was created to develop a coordinated
technically-based response to the Draft Ocean Plan.
On February 17, 1983, the Goleta Sanitary District invited all coastal agencies
to participate in a day-long roundtable session to discuss the Draft Ocean Plan.
As a result of that meeting, (attended by 17 coastal agencies) a list of con-
cerns over the Draft Ocean Plan was developed. Also, a group of 7 people were
appointed to translate these concerns into technically based position papers.
The technical committee consists of the following people:
Members of the Technical Committee began drafting the position papers in late
February and continued through March. Draft position papers were distributed to
all coastal dischargers for technical review as they were completed.
Kris Lindstrom
Blake Anderson
Felix Martinez
Irwin Haydock
Frank Wad a
Bill Sukenik
Salar Niku
Orange County SD
Goleta SD
Los Angeles County SD
Los Angeles City
K. P. Lindstrom & Associates
(for Orange County SD)
Aliso Water Management Agency
-------
SWRCB
March 31, 1983
Page 2
The results of the California Ocean Dischargers efforts are 14 position papers
that include the following issues:
1. Purpose and Use of the Ocean Plan
2. Total vs. Fecal Coliform Bacterial Standards
3. Kelp Beds Designated as Shellfishing Areas
4. Light Measurements
5. Radioactivity
6. Caged Bivalves for Pollutant Uptake Monitoring
7. Effluent Grease and Oil
8. Effluent Suspended Solids
9. Effluent Turbidity
10. Effluent Toxicity
11. Chlorinated Phenols
12. Polychlorinated Biphenols
13. Ocean Disposal of Municipal Treatment Plant Sludges
14. Monitoring Frequency
Political and managerial endorsement of these position papers by the effected
coastal dischargers will follow. Copies of these position papers are being sent
to the distribution list accompanying this letter. The effected agencies are
being asked to review these final versions and forward their endorsements to the
SWRCB.
We believe that this unified approach will help the SWRCB to forcus on the con-
cerns that are of primary importance to the community of coastal agencies. We
also understand that several of the coastal agencies are forwarding to the SWRCB
independent responses that concern issues of particular importance to those
agencies.
The California Coastal Dischargers are willing to meet with your staff to
discuss these position papers and explain our concerns. To this end, Blake
Anderson and Felix Martinez will meet with your staff on this date to transmit
the position papers and to answer your preliminary questions.
Very truly yours,
Blake P. Anderson
Representing the Large Dischargers
Felix Martinez
Representing the Small Dischargers
-------
3/31/83
POSITION PAPER
OF
THE CALIFORNIA OCEAN DISCHARGERS
ORAFT WATER QUALITY CONTROL PLAN, OCEAN WATERS OF CALIFORNIA, 1983
ISSUE: Caged Bivalves for Pollutant Uptake Monitoring
REFERENCE: Draft Ocean Plan, Page 4, Chapter III, Section B, Item 3, and
Footnote 14
LANGUAGE OF OCEAN PLAN DRAFT BY SWRCB
Waste Discharged to the Ocean Must be Essentially Free of:
Substances which will accumulate to toxic levels in marine waters, sediments or
biota, (14).
Footnotes
(14) Increased tissue burdens of conservative toxicants in marine biota may be
determined using caged bivalves transplanted to the discharge zone.
Results of the pollutant uptake monitoring shall be interpreted on a case-
by-case basis and shall be used at the discretion of the Regional Board.
POSITION OF CALIFORNIA OCEAN DISCHARGERS
The California Ocean Dischargers cannot support the use of caged bivalves as a
routine monitoring method in deeper ocean waters until this technique has been
further developed.
LANGUAGE PROPOSED BY CALIFORNIA OCEAN DISCHARGERS
Footnote 14: Increased tissue burdens of conservative toxicants in marine biota
may be determined by measuring the increase in species indigenous to the speci-
fic discharge site. The use of caged bivalves transplanted to the discharge
zone can be used at the discretion of the Regional Board after techniques have
been adequately developed by the State Mussel 1 Watch Program of the SWRCB.
TECHNICAL DISCUSSION
The California Ocean Dischargers recognize the Board's interest in the use of
caged bivalves and their recognition of the present limitations on the use of
-------
this monitoring technique for deeper ocean waters. We agree with the DEIR (Page
25) which states:
"Prior to routine implementation of caged bivalve monitoring, three tasks will
need to be completed to assure standardized data acquisition and interpretation.
These tasks are:
1. Preparation of a manual for agencies involved in caged bivalve monitoring to
ensure a standardized and compatible approach.
2. Refinement of offshore, deep water caged bivalve transplant techniques to
Improve present deployment/retrieval methods.
3. Development of an efficient and economical caged bivalve grid of network
siting formula to be applied to each discharge's characteristics; i.e.,
ocean currents, zone of initial dilution, etc."
We also agree that it is premature to use mussels for direct enforcement
purposes.
The California State Water Resources Control Board (SWRCB) and the U. S.
Environmental Protection Agency (EPA) have established research and monitoring
programs which use bay (Mytilus edulis) and the California coastal (M.
californianus) mussels for the first aforementioned purpose. In 1977, the SWRCB
established a State Mussel Watch (SMW) Program. The SMW has monitored the
bioaccumulation of selected trace metals and organic compounds along the
embayments and intertidal open coast of California. _Several SMW annual reports
describing the results have been published. In brief summary are some major
points on the use of mussels for monitoring toxic pollutants and biological
responses:
1. Resident and transplanted mussels are good accumulators of certain trace
metals, pesticides, petroleum compounds, and PCBs. Correlations between
certain metals have been shown. However, the effectiveness of mussels in
bioaccumulating the remaining list of EPA priority pollutants is unknown.
The analytical methodology for detecting and quantifying petroleum hydrocar-
bons and many of the synthetic organic compounds in tissue are developmental
and require an intercalibration program with specialized research facilities
for quality results. Chromatograms with "unidentified peaks", which repre-
sent unidentified hydrocarbons, were found in mussels from all of the SMW
stations. It is not known if these "unidentified peaks" are environmental
pollutants or toxic substances.
2. The SMW studies had fouling problems with the transplanted mussels. In
fact, some of the samples were believed to be of "somewhat questionable
value". It is thought that fouling by small barnacles and mussel spat
limits the organism's ability to obtain enough of the surrounding water,
thereby limiting feeding and growth. The technique of transplanting mussels
needs to be refined to reduce the fouling problem.
-------
3. To obtain valid trace metal bioaccumulation data, the transplanted mussels
were collected after six months' exposure. This period was selected to
ensure that chemical equilibrium of the trace metals in the mussels was
attained.
4. There is a need to investigate the influence salinity exerts on trace metal
concentrations in mussel tissues.
5. The use of transplanted mussels to monitor environmental pollutants is pro-
mising but work needs to be continued in refining the field and laboratory
procedures.
6. And, lastly, the bioaccumulation of certain toxic pollutants by mussels does
not indicate adverse biological effects. The SWRCB recognized this drawback
and initiated a major study to interpret the effect of elevated levels of
toxic substances in mussels. This study, entitled the "Biological Effects
Assessment", will identify which toxic substances are primarily responsible
for the decrease in mussel "Scope for Growth" (SFG). The SFG index gives a
numerical value for how much energy the mussel has available for growth and
reproduction. The higher the SFG valve, the healthier the mussel.
Completion of this study is scheduled for sometime in 1983 or 1984,
depending on the need for additional work. Final results of this work are
still pending State Board review.
In view of the limitations in using transplanted mussels in deeper ocean waters,
(i.e., mooring, fouling, growth, salinity, temperature, etc.), and the inability
to interpret the meaning of elevated levels of bioaccumulated toxics in mussels,
we can conclude that it is premature to initiate the use of mussels for defini-
tive bioaccumulation studies. Much more work is needed in refining the field
and laboratory methodologies as well as identifying the effects of
transplanting. Research is already underway by the SWRCB and EPA.
In March 1983, the SWRCB and several of the dischargers began to develop a plan
for a demonstration project. The dischargers are willing to participate in a
cooperative effort to develop the techniques for cagnd bivalves pollutant uptake
monitoring in deeper ocean monitoring. However, until this project is completed
we believe it is not cost effective toestablish any routine monitoring require-
ments.
REFERENCES
California Department of Fish and Game. 1982. California State Mussel Watch
1980-81, State Water Resources Control Board Water Quality. Monitoring
Report, 81-11TS, May.
Martin, M., 0. Crane, T. Lew, and W. Seto. 1980. California Mussel Watch:
1979-1980 Synthetic Organic Compounds in Mussels, Mytilus californianus,
and M. edulis, along with the California coast and selected harbors and
bays - Part II. State Water Resources Control Board. Water Quality
Monitoring Report 80-8, Sacramento. 49 pp.
-------
Risebrough, R.W., B.W. De Lappe, E.F. Letterman, J.L. Lane, M. Firestone-Gill is,
A.M. Springer, and W. Walker II. 1980. California Mussel Watch 1977-1978
Volume III - Organic Pollutants in Mussels Mytilus californianus and
Mytilus edulis, along the California coast. SWRCB Water Quality
Monitoring Report No. 79-22, Sacramento. 108 pp. plus 7 appendices.
Stephenson, M.C., M. Martin, S.E. Lange, A.R. Flegal, and O.H. Martin. 1979.
California Mussel Watch 1977-1978 Volume II Trace metal concentrations in
the California mussel, Mytilus californianus. State Water Resources
Control Board, Sacramento. Water Quality Monitoring Report. 79-22. 110
pp.
-------
STATE OF CALIFORNIA-RESOURCES AGENCY
GEORGE DEUKMEJIAN, Governor
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SANTA ANA REGION
6809 INDIANA AVENUE, SUITE 200
RIVERSIDE, CALIFORNIA 92S06
PHONE- (714)684-9330
April 29, 1983
Mr. William H. Pierce
Chief, Technical Support Branch
United States Environmental Protection
Agency
Region IX
215 Fremont Street
San Francisco, CA 94105
Dear Mr. Pierce:
Re: Draft Biological Assessment of 301(h) Permit Actions on the
Endangered California Brown Pelican
We have reviewed this Draft Biological Assessment and find it to be
very well done - a thorough and responsible assessment of the
situation.
We recommend that the process of developing 301(h) permits for
Southern California be continued.
We look forward to receipt of the Final Biological Assessment when it
becomes available.
Si ncerely,
Joanne E. Schneider
Environmental Specialist II
-------
WASFf WATf B
RECLAMATION
SOLID WASTE MANAOBMEN
9
COUNTY SANITATION DISTRICTS
OF LOS ANGELES COUNTY
1955 Workman Mill Road / Whither, California
Mailing Address / P O Box 4998, Whittier, California 90607
Telephone (213) 699-741 1 / From los Angeles 1213) 685-5217
WALTER E. GARRISON
Chief Engineer and General Manot
May 11, 1983
File No: 31-220.20B
Mr. Frank M. Covington, Director
Water Management Division
Environmental Protection Agency
Region IX
215 Fremont Street
San Francisco, California 94105
Dear Mr. Covington:
The Sanitation Districts' staff has reviewed the March 1983 Draft Brown
Pelican Biological Assessment received in this office April 14, 1983. In sum,
this document presents a more than adequate case to sustain the conclusion that
the minor decrease in (DDT) emissions that could be realized from full secondary
treatment over that allowed under 301(h) waivers would be unlikely to have a
noticeable effect on pelican productivity in the Southern California bight.
Further, the Districts are confident that the proposed 301(h) monitoring
programs will adequately address significant environmental parameters and will
assure that clean water goals are being met. As for the specific recommenda-
tions, resulting from the biological assessment, it is the Districts' position
that these items (residue levels in water, plankton, and fish, biomonitoring
with shellfish, and surveillance following the closure of Montrose) are best
addressed by focused research rather than routine monitoring. There is little
hope that monitoring efforts carried out in the immediate vicinity of outfalls
will provide meaningful results to assess the continuing status of the Brown
Pelican population throughout Southern California waters. On the other hand,
carefully planned and executed research (such as that carried out on the east
coast by Blus) can lead to both better definition of the potential problem and
to development of meaningful environmental standards. Population trend assess-
ment of endangered species, such as has been supported or carried out by federal
and state officials, is meaningful and should continue.
From the work to date it is clear that pesticide residues act in concert
with other factors, such as anchovy food availability, human disturbance, and
even malicious acts of maiming recently noted in Southern California. The end
result may be a Brown Pelican population decline, but the answer to this will
require a more balanced response of fishery regulation, pesticide regulation,
habitat protection, human concern, and other strategies. The Districts agree
with the report's conclusion that source control and treatment have already
brought about substantial declines in pesticide residues and that further controls
-------
Mr. Frank M. Covington
-2-
May 11, 1983
A final comment would be that if a monitoring program were implemented on
waste dischargers, an equally rigorous program would need to be implemented to
assess aerial fallout, harbor inputs, and flood control runoff, in order to
provide the proper perspective. The Districts contend that since the impact on
pelicans is the concern here, it is the birds and their eggs that should be
watched for some indication that the improving population trend will continue.
With regard to the two original issues cited by USFWS: (1) chronic egg-
shell thinning and (2) effluent pesticide standards; there is no reason to
suspect that the discharger monitoring proposed will answer these crucial ques-
tions. Again, the literature (Blus) indicates that 3 ug/g DDE in eggs is marginal
and 4 ug/g causes reproductive failure in East Coast pelicans. All things
considered, the most direct approach would appear to be a research program to
determine first the average concentration in pelican eggs, adults (especially
blood samples or fresh carcasses) and representative samples of anchovies caught
in pelican feeding areas up and down the coast, including Mexico. Based on the
data given in Tables 2 and 3 of the report, the biomagnification of DDT from
anchovy pelican fodder and pelican eggs averages 39 and ranges from 11-79. If
3 ppm is taken as the critical level not to be exceeded, then anchovies should
not exceed 0.08 ppm or about twice the level noted in 1980-81 (0.047 ppm).
An additional issue questioned was the effectiveness of existing water
quality standards in protecting Brown Pelican needs. This issue has already
been addressed in the recently proposed revisions to the State Ocean Plan which
is presently being held up to scientific, regulatory and public scrutiny.
Revisions are scheduled at regular intervals to take account of the most recent
scientific and social findings as well as to carefully consider the economic
costs and benefits involved in additional controls.
Also enclosed for your use are some detailed corrections to tables and
text; wherever these seem to be in error.
Very truly yours,
Walter E. Garrison
Irwin Haydock, Ph.D'
Supervisor, Monitoring and Research
IH:ar
-------
Additional notes, comments and corrections to EPA letter of May 6, 1983
regarding EPA Draft Biological Assessment on the Brown Pelican.
Page No.
1. DOT (formerly named p.p'-dichlorodiphenyl trichloroethane) is listed
as l,l-dichloro-2,2-bis(p-chlorphenyl) ethane (MacGregor, 1974) or
l,r-(2,2,2-trichloroethylidene.bis(4-chlorobenzene)(Ba1 rd-LACSD, 1983
memo). I am unsure which is correct, or if it matters in this context
(see PCB, same list).
26. A group of California Ocean Dischargers has recently gone on record as
opposing the very stringent DOT, PCB, etc., limits set in the CALIF
OCEAN PLAN'S proposed Table B.
PCBs have not been implicated in reproductive failure of Pelicans (see
Blus, various papers and the statements on p.32-33), so PCB need not be"
included in this review.
32. There are probably not enough data (or samples) available to Table 2
(p. 31) to make the flat statement that "residue levels have stabi-
lized around 5 ppm,...u.
This appears to be a crucial point, since Blus has determined 3 ppm to
be critical and 4 ppm as causing reproductive failure 1n Pelicans on
the east coast. This seems not be be the case in the SCB. (See
attached figures 1 and 2).
33. Biomagnification statement of Blus (1982) that fish to egg BF
(Biomag. factors) are on order of 50-100 fold is not sustained by
the bulk of the data of Tables.l'J-and Further, if 3 ppm is taken as
critical level not to be exceeded in CBP eggs, then anchovies should
not exceed 3/40 or 0.08 ppm. The 1980-81 anchovy concentrations were
about one-half this amount. It would appear (p.38) that much better
measurement of bioaccumulation would be critical for assessing any need
for further DDT control in the SCB. Comment: anchovy monitoring might
better be carried out by CFG and NMFS, those agencies responsible for
the fishery, which have larger sampling grids than the discharge agen-
cies involved.
36. If food shortage plays a critical role in CBP reproduction, then
serious consideration must be given to anchovy fisheries management,
especially on populations in the SCB.
39. CalCOMP - a group of state and local agencies is presently discussing
an experimental program to demonstrate the efficacy of mussel watch-
type monitoring. Discharge agencies have commented at recent SWRCB
hearings on the Ocean Plan that routine monitoring should await the
outcome of such studies.
47. Table 5 requirements for JWPCP are not the current established 1imits—
they are for full secondary and source control with a timetable for
-------
I
SOUTHERN CALIFORNIA BIOHT PELICAN POPULATIONS
(Adult Pairs, Young Fledged, Productivity]
Log Value
It 4-03—
lEt02-
!Et01-
1E+O0—
1E-01-
1E-02-
.
0 Young/Nest
Young F ledgQd
Adult Pairs
1 1 1 1 1 1 1 1 1 1 1 1
1969 1970 1971 1972 1973 1974 1975 1976 1977 1973 1979 1980 1981
Years
-------
SOUTHERN CALIFORNIA BIGHT PELICAN POPULATIONS
mnT-nnF rnnrpn+ra+inn^ in Anrhflvu. Ppliran Fcm
-------
compliance ranging from July 1983 to January 1985 (see attached sheet
for corrections).
48. [line 7) ... some of the sludge is dewatered with very inefficient
equipment and the high solids centrate is also...
49. (line 3) It (60") is currently used only infrequently during seasonal
peak flow periods....
50. (line 3) ... anaerobic digesting dewatering, and final disposal.
(2 Par, line 6) There is some question about the final JWPCP flow in
the 301(h) permit, now approximately 350 mgd. on pg. AXX-5 of Appendix
III of LACSD's 301(h) application, discussion indicates that the permit
should be set at 385 mgd for the 5-year period.
53. The values in Table 7, "UWPCP-Influent and Effluent Characteristics"
were checked against the cited references. The Influent suspended
solids for 1982 (8-month average) is incorrect. It should be 444 mg/1.
Influent DDT, Influent PC8, Influent TICH and Effluent TICH values for
1971-1977 differed slightly from those in reference 5; however, the
differences are not considered significant. The trends remain the same
(Table attached).
54. (suggested replacement for lines 5-7, although there have been no
Improvements...). During the past decade, a number of improvements
have been made at JWPCP to reduce the mass emission of suspended
solids. Sedimentation tanks have been added, sludge dewatering capa-
city has been expanded, chemical addition to the sedimentation tanks
has been initiated, and fine screening of the effluent has been added.
TICH emissions have declined to a greater extent than suspended solids
emissions.
(line 11)... constituents is provided by facilities already under
construction for secondary treatment and sludge dewatering. Improved
removal....
55. (Table 8, add to note 1) Values for advanced primary treatment
include centrate returned to effluent from incomplete sludge dewater-
ing, which contribute roughly half of the effluent suspended solids.
Data from Table 7 (not 6).
57. Suggest Table 9 reflect proposed revisions to flow as discussed with
EPA. Parameters of Table 9 pertain to Scheduled not current NPDES and
Existing Treatment is Primary (not adv. 1" level}. Note: Existing
permit includes schedule for full secondary by January 1985.
Footnote 1 refers to Table 7 (not 5) and same note pertains as in Table
8 regarding centrate.
58-82. LCASD did not review the sections on LAC or CSDOC.
83. It should be emphasized that records of other sources (beyond
wastewater) are incomplete, much less comprehensive, and outdated for
-------
TABLE 5 (CORRECTED)
COMPLIANCE DATE CONSTITUENTS UNITS 30 DAY 7 DAY DAILY
July 1, 1977
BOD, 20°C
mg/1
kg/day
1bs/day
225
328,000
722,000
- 1
360
584,000
,160,000
Suspended
solids
mg/1
kg/day
1bs/day
200
291,000
642,000
270
393,000
867,000
BOD, 20°C
mg/1
kg/day
1bs/day
30
43,700
96,300
45
65,540
144,500
87,400
192,600
Suspended
solids
mg/1
kg/day
1bs/day
30
43,700
96,300
45
65,540
144,500
87,400
192,600
CONSTITUENTS
UNITS
not to be
exceeded
more than
10% of the DAILY
30-DAY time MAXIMUM
July 1, 1983
July 1, 1978
Total
Identifiable mg/1 .002
chlorinated Kg/day 2.91
hydrocarbons lbs/day 6.42
.004
.006
5.83
12.8
B-15 - The concentration in marine sediments of sub-
stances listed in item A-3 (includes TICH) shall not
be significantly increased above that present under
natural conditions.
January 31, 1985
The final receiving water toxicity concentrations
shall not exceed 0.05 toxicity units.
-------
TcLt'e. i jwu» - inEiuent And Li.j.xuent t-iiaracucii.dtit^i
o*»
Suspended Sol ids
3CO 2
Flow Fate
ihq/1
£.
mg/1
Year
MGD 1
Influent
Effluent
Influent
Effluent
A
A
_A
4
A
1970
371
[3973
3843
¦
1971
372
325
328
1972
351
\416
293
319
307
1973
355
r518
289
357
244
1974
34*
460
276
314
213
1975
3421
484
278
302
209
1976
353
424
282
306
229
1977-
330
463
220
334
220
1978
345
448
219
324
204
1979
367
435
195
322
204
1900
374 1
442
176
335
208
1901
364
V442
167
322
202
1902
363
(3G2«
sia,/(J
V Vy.f
1604
3234
205
Total DOT
5,n PCB 5,6 TICH 5,6
ug/i ug/1 ug/1
Influent Effluent Influent Effluent Influent Effluent
C<^ S— c^-
<2.057c^V
<1.387 *'1
1.057
0.837
0.529
i.707cA
0.917{S>/c
0.837^
0.967
0.529
2.67
2.73
0.697
0.657«?/<
0.547
0.339
<3.677^/C<3.20 ^
2.097o/T<2.l97c' a"
3.037<"
4
stunn^,
cJ) St^
-------
the most part. Agency responsibilities for non-point source monitoring
are not yet defined state-wide.
87. (line 7) 1985 (not 9185).
88. (1st par), landfill, toxic waste dump site studies are underway by
responsible state and local agencies.
89-90. (and table 20 footnotes). It should be noted for each source the date
I I
and frequency of sampling that went into these estimates v1s-a-v1s
wastewater discharge sources.
91. SCCWRP 60 meter survey data provide SCB area-wide summary of 1977
sediment contamination levels (see Young 1982, attached).
(2nd par. line 8) JWPCP (not A).
(2nd Par. line 10) pesticide contamination...is a few (3-4) orders of
magnitude lower. Might also refer to MacGregor (1974, 1976 - Fish.
Bull. Vols 72(2) and 74(1) at this point.
92. (last Par.) Smokler's results showed that water column fish DDT levels
declined while that of bottom forms did not. This somewhat contradicts
first sentence where It's stated that despite major decreases...
elevated levels persist in bottom and water column fishes
However, DDT has slowly declined in the only flatfish (bottom) moni-
tored since t7ie~Smokler paper, the Dover sole-see Figures V-21, p. 271
in LACSD annual report 1980-81, which was sent to EPA Reg. IX some time
ago (copy attached).
93. Figure 11: Curves are not directly comparable because different
sampling devices and analytical techniques were used. Log values plot
does not clearly show extent of decrease--5 ppm surface versus 200 ppm
buried.
94. (Par. 2) seems out of place. Data provided in Appendix I (? not III)
was from modelling a worst case scenario and not actual measurements
of massive versus pension. Also fish should be able to avoid
low D.O. areas and resuspenslon (or bioturbation) cannot be large
and still account for distinct layering of cores as shown 1n Figure 11!
In sum, the Districts feel that burial presently dominates the
situation and is responsible for the lower DDT burdens seen in recent
monitoring of fish flesh.
(Par. 3, lines 4-6). We question the validity of the statement about
mussel biomonitoring attributed to Young et al (1981); this may
refer to the single pilot study at Palos Verdes in June 1974 to
early 1975. Also, to 1 lowing paragraph (line 3, page 95) it is stated
that the experiment was repeated (January 1976), whereas Young (1982,
op cit, p. 28) states: "toward the end (winter) of the June 1974 survey
We concentrations tended to merge at the different depths" due to
-------
breakdown of stratification. Since the EPA reference cited Is not
available to us, we are not certain what the facts are in this descrip-
tion.
95. (last Par.) Point is made that wastewater rather than sediment
resuspenslon is the source of DDT. We feel this conclusion is inade-
quately based; for example, SCCWRP (D. Brown) has found seasonality to
be very important 1n chlorinated hydrocarbon levels 1n mussels and
this could also account for differences observed.
96. The last paragrpah is an Important conclusion, but seems out of place
here. We doubt 1f Its promise can be demonstrated by the suggested
items in Section 8. However, a more focused research effort might be
appropriate; certainly not the type of monitoring here suggested.
97. (1st par). Much is made of the limited accuracy of projections here
and in Table 21; however, 1t Is much more certain that the inherent
variability and accuracy of environmental forecasts of effects (and
that of other important sources) are far less understood or even
equally well measured.
99. We are unaware of any recent data or models that would allow one to
state that sediment sources of DDTs overshadow other inputs. The
release of DDT from sediments is a function of burial/resuspension or
other release mechanisms. As shown by Figure 11, DDT concentrations
are now highest below the surface and should be effectively isolated
from the environment, 1f this remains the case for the next decade.
However, we agree that combined effects and sediment, aerial dis-
persion and runoff make current wastewater inputs a minor factor.
-------
1 1 1 1 1 1 1 r
(9)
(2 1)
(20)
(I 07
(6)
(ND)
,(10)
FDA LIMIT = 5 ppm
(ND)
(10)
_J I I L I I I I 1—
19 72 1973 1974 1975 1976 1977 1978 1979 1980
YEARS
Fiqure V-21.
Trend of modi an DDT concentration in flesh of
Number of samples indicated in parenthesis.
Dover sole
-------
Response to LACSD Comments on Draft Biological Assessment
Page No. Response
26 The status of the California Ocean Plan revisions has
been updated. The opposition of the California Ocean
Dischargers (COD) to the proposed limits for trace
organics is acknowledged. The EPA supports the proposed
limits and finds the COD's arguments unconvincing. In
a briefing notebook transmitted to the SWRCB on April
20, 1983, the COD argued that limits for DDT, PCBs.
etc., should be based on bioassay results, that the
levels proposed are below detection limits, and that
background levels from domestic wastewater entering
treatment plants exceed the proposed limits. However,
the basis for the proposed limits is not simply the
direct toxicity effects of these compounds on the marine
biota, but their biomagnification through the food
chain. In addition, it has not been adequately
deomonstrated that the proposed limits are unachievable.
The COD base their argument on TICH levels in wastewater
Influent rather than levels of individual constituents
-------
Although in our assessment PCB concentrations found in
brown pelican eggs in Southern California are not
inhibiting reproduction, the fact remains that this
question was investigated and is an appropriate subject
for a full disclosure document.
32 The statement in the assessment has been qualified;
however, the figures accompanying the ccnments do not
disprove the the validity of Blus' critical level.
33 We presume that the reference is to Tables 2 and 3.
The assessment does state that lower bioaccumulation factors
have been oberved. Anchovy sampling is carried out by the
agencies mentioned and by the SCCWFP; however the data gathered
for Table 3 are frcm scattered sources and sampling locations.
A more concerted monitoring program is required to improve the
estimates of bicmagnification.
36 Cement acknowledged.
39 Cerement acknowledged. We retain our position on the use
of caged mussels to monitor increased tissue burdens
of toxicants in marine biota.
48 Conment acknowledged and has been used in the text.
49
Comment acknowledged the assessment already states that the
-------
50
53
54
55
57
83
88
89-
91
92
93
The JWPCP flow rate used for 301(h) is the flowrate identified
in the tentative decision document and in the original 301(h)
application. "Dewatering" was incorporated into the text.
The influent suspended solids value for 1982 has been changed.
This carcnent has been incorporated into the text.
Changed table 6 and 7. However, statement about centrate
return did not seem necessary after the description of the
treatment processes within the text of the report (made
change on centrate return according to ccmment for page 48).
Table 9 reflects the flow discribed in the current 301(h) tentative
decision document. Current NPDES limits are the once described
in Table 5. The Footnote #1 has been corrected in Table 9.
The second paragraph on this page has been modified appropriately.
Garment acknowledged.
Sources of data are provided only, to avoid excessive
detail in the report.
Young's study incorporated by reference. Other comments
noted with appropriate changes in the text.
Ccmment acknowledged and sttement on page 92 has been
adjusted appropriately.
Figure 11 and the referenced paragraphs both supporting and
-------
94 The Young study referenced on page 94 is not the single
pilot study described in the August 1976 issue of the
marine Pollution Bulletin, but a more comprehensive
study described in the cited reference.
95 We express no opinion as to the validity of Young's conclusion.
96 See revised text.
97 Our intent in carefully qualifying the numbers in Table
21 was not to criticize the dischargers' monitoring
program but rather to prevent the misuse of the simplified
and assumptive information.
99 In our opinion, the DDT levels found within the zone of
surface sediments that are periodically disturbed remains
significant; although concentrations at the surface
itself has declined dramatically, concentrations a few
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