SR-502-007 (3)
GS:SS:EL:a
Cour,cil Heet~l'"jg:
. !J02-00?- -
ch 26, 1985 Sar>ta _lca, CalifornIa
To:
Mayor and C~ty Cour-cll
h-r
From:
"Ai 2 6 1985
CIty Staff
Subject:
Water QualIty 1" Sarota MODIca Bay
I"ltroductlon
Per Council Instructlor-S staff ~s to provide a status report of
developments regardlr.g the determlnatlor- of water qualIty and
health Issues cancernlr,g ocean waters off the coast of Santa
Mon~ca.
Report
Staff has no new lnformatlor, to report on f~nd~l'1gs related to
water quality or potentIal health hazards of consumI~g fISh taken
from Santa Moroica Bay.
Staff has submItted to the City Attorney for reVIew, alternatIve
word~ng for s~g~age to cautIor people who fISh. The Attorney has
also ~ndIcated a need to review potentIal locatIons for SIgn
placement. Staff wIll report back to the Council when a slgnage
recommendat~or has been developed.
Currently, SIgns wIth the follow~ng words are posted or> the pIer
warning people about potentIal health hazards from cor,sumir,g
mussels durIng certail'1 tImes of the year.
WARNING
MUSSELS
from these waters are unfI t
consumptior, and ~t ~s unlawful to
or offer them for sale for food
perIod May 1 to October 31.
for human
take, sell
durIng the
ThIS quarantIne establIshed by order of the State
of PublIC Health and any vlolatIor: thereof
- 1 -
Board
IS a
teJ-I
"Ai 2 6 '985
~
GS:SS:EL:a
Councll Meetir.g:
.h
26, 1985
Santa _i ca. California
mlsdemea~or. It IS u~lawful to destroy, remove or
m~tllate thlS slgn.
CLAMS
Clea~ and wash all clams before
COOkl"'lg.. .dlscard all dark parts WhlCh may
contal"l pOlson.. .only the Whl te meat should
be prepared for cook~~g and eatl~g.
L.A. County Health Offlcer
Recommendatlon
No actlo~ IS requested at thlS tIme.
Prepared by: Stan Scholl, Dlrector of Ger.eral Servlces
Ed Lash, Utllltles Manager
Nell MIller, Asst. DIrector of Ge~eral ServIces
- 2 -
.
1h- 'sfa-r/ I
1
OCEAN DUMPING UNDER LOS ANGELES REGIONAL WATER
QUALITY CONTROL BOARD PERMIT: A REVIEW or PAST PRACTICES,
POTENTIAL ADVERSE IMPACTS, AND RECOMMENDATIONS FOR fUTURE ACTION
by:
~LLAN B. CHARTRAND
SUE MOY
ANDREW N. SAFFORD
TAIRA YOSHIMURA
LEWIS A. SCHINAZI, Ph.D.
CALIFOR~IA ~EGIONAL WATER QUALITY CONTROL BOARD
Los Angeles Reg~on
f'o4arch 1985
~-x
3-2b-~-S~
.
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
Los Angeles Region
James H. Grossnan, ChalI"nan
Jack R. Wltz, V~ce-Chal~an
Celso C. MartInez, Member
Tony Thacher, Member
Betty J. We rthll an , II1ember
Ronald D. Wherry, Member
.
Robert p. Ghlrelll, O.E~v.
::'xecutlve Off leer
.
.
CONTE"ITS
-~......
Part hUe
1.0 Execut~ve Summary
2.0 Recommendat~ons
3.0 Introductlon
4.0 H~story of Ocean DumpIng
a.1 Ocean DumpIng: Board Involvement
and Regulatlon
CalIfornIa Salvage Company
PaCIfic Ocean Dlsposal C~mpany
H-l0 Water Ta~1 Company
4.2 Current Ocean DumpIng In the
Los Angeles Reglon
THUMS Long Beach Company
Star-K~st Foods, Inc.
Other Currently Accepted Practlces
5.0 EnVIronmental and Health Effects of
Ocean DumpIng
5.1 Montrose ChemIcal Company
5.2 Impact on Mar~ne Blrd PopulatIons
In Southern Callfornla
5.3 OverVIew of SClentlflc LIterature
5.4 Proposed Reg~onal Board Study
of Ocean DumpIng at DumpSlte No. 1
and Its Envlronmental Effects
5.5
Cancer Risk Asessment of DOT
LIterature CIted
4ppend~x A
OverVlew of Legal Hlstory
AppendIX 8
Correspondence
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F~9ure
1
2
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4
5
6
7
8
9
10
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LIST OF FIGURES
T~tle
Map of General Area
Designated Ocean Dumping Sites
~n the Southern Cal~fornia B~ght
Yearly Volumes of Wastes Ocean
Dumped by CSC and PODCO
Summary of Ocean Dumped l~Qu~d Wastes
DDT and PCB Em~sslons Into
the Southern Cal~fornla
DDt Mass Emiss~on Rates
DDT Wastes from Montrose Chem2cal Company
Callfornla Undercurrent
Hlstorlc Record of Brawn Pellcan
on Anacapa Island
Partlal Summary of Stud~es on Marlne Wlldllfe
Relatlng to Effects by DDT
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Page
S
6
~l
12
21
27
22
26
27
29
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1.0 EXECUTIVE SUMMARY
Publ~c concern has recently been focused upon ogean d~mp~ng of_~ndustrla~__
wastes in San Pedro Channel. Th~s pract1ce began 1n th~2)O's and
cont~nued untIl the early 1970's. Past ocean~dump~ng--was reg~lated under
state anareaeial~law from 19671 unt~l practIce was dlscontlnued In
1973.The Los Angeles Reglonal Water Quallty Control Board prescrlbed waste
dIscharge requIrements for two f1rms engaged 1n the ocean dump1ng of
lndustrlal wastes; Cal1forn1a Salvage Company (CSC) and PacIf1c Ocean
D1sposal Company (PODeO). These requIrements lImIted dIsposal to a sIngle
sIte (Oumpslte No.1), approxImately 10 nautIcal mIles northwest of Santa
Catallna Island. Recor~~ IndIcate that ac~d wastes generated by the
~ontrose ChemIcal Company, the largest manufacturer of DOT 1n the UnIted
-?tates. were_d~mped at o~ near Oumps~te No. 1prIor to_~he ~~ppt~on_of -
requirements 1n 1961 by the Board.
No conclusIve eV1dence dIrectly llnks the ocean dump~ng of 1ndustrlal
wastes at Dumpslte ~o. 1 wIth adverse env~ronmental effects 1n the Southern
CalIforn1a BIght.'No DOT wastes are known to have been ocean dumped after
1961;~' about 3/4 o~f the-DDTlo~bd_ln_Southern Cal1forn1iwater~ appears to
have or~g~nated- chlefly from the\JoInt Water Pollut~on Control Plant
outfall at Whltes POlnt (600 metrlc-tans.and 1800 metrlc tons; respec~
tIvely). callfornla~Salvage Company and Pac1flc Ocean Dlsposal Company
may have dumped a SIgnIfIcant portlon of theIr wastes short of the deslg-
nated dumpsIte. large volumes of wastes were elther stored or dlsposed at
land-based sltes. Addltlonal InvestIgatlon and enVlronmental monltorlng
are needed to assess possIble effects of th1S past dump~ng practIce. The
lnvestlgatlon Wlll conSIst of a hlstorlc Ilterature reVlew and a f1eld
study to be conducted by Los Angeles Reg10nal Water QualIty Control Board
stafF (outl1ned In Sect10n 5.4). The report recommends a serIes of actlons
to be taken by concerned agencles and sClentlsts w~th a Vlew toward: (a)
ImprOVIng our understand1ng of transport and potentlal envIronmental lmpact
of ocean dumplng at Dumps1te No. 1 and (b) mlnlmlzlng adverse envIronmental
Impacts and human health rIsks.
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2.0 RECOMMENDATIONS
The folloWIng recommendatIons are made to ensure an actlve follow-up to
thIS report by the respectIve agenCIes, organlzatlons and SCIentIfIC
groups. They wlll aId In acqulrlng Informatlon on the effects of ocean
dumplng at DumpsIte No.1 upon the marlne enVIronment.
1. CalIfornIa Department of FISh and Game (DFG)
~atlonal Park SerVIce (NPS)
a) MonItor prlor1ty pollutant levels 1n marIne WIldlIfe In the
Channel Islands NatIonal Park to determIne if elevated levels are
present and what effects these substances may be havlng In
WIldlIfe populatIons.
2. Department of Health Servlces
Place the follOWIng SItes on the stat~wIde Inventory of confirmed and
abandoned hazardous waste sl~es, and Initiate remedial actlvlt18S-:
a) CalIfornIa Salvage Company harbor storage faCIlIty, Berth 15, Port
of Los Angeles
b) PacIflc Ocean DIsposal Company harbor storage faCIlIty, Berth 116
PIer E, Port of Long Beach
c) PODCO dry wells 914 Paul Jones Avenue, Wllm1ngton
d) Grant Street LIqUld Dlsposal Company, Wilmlngton
3. State Water Resources Control Board and Reglonal Water Quality
Control Boards
a) ~reate a coord~~at~~__~arlne Informatlon exchange system to provlde
ready-access-to data on waste dIsc~arges and water QUalIty In
ocean waters along the Southern CalIfornIa coastllne.
b) jeek add1tIonal fundIng to contInue fish pathology studIeS In
Call fornla harbor and coastal waters. I '-
4. Los Angeles Reglonal Water Quality Control Board (LARWQCB) ,
aj Seek Immedlate fundIng for the rv 1985-1986 SpeCIal Study
.froposal Eo moni forsEarm_ draJn:::; fo_r pnon t y pollutants - to
ensur~e that-no SIgnIfIcant quantItles of pestICIdes; hydrocarbons,
heavy metals, etc., are enterlng ocean waters.
b) ~_~Itor stqr~_dral~s and_se~ag~_e(fluent dlscharges for pestlcldes
such as dIcofol (Kelthane) which could Increase the load of
chlorInated hydrocarbons In ocean waters and Inhlblt the recovery
of the Southern CalIfornia marIne enVlronment.
.
.
c) ~rep~ye a cD~prehensive annua~ report to the Reglonal Board on
the quaIl t y 0 f ocean _watet-a lD_ thlL.reglon. Th.ts annual 1treport
card"- would be used by the ReglOnal Board to ensure that acbons
are taken 1n a tlmely manner to protect all beneflclal uses of
the ocean.
d) Incorporate effluent llmltatlons and recelvlng water obJectives for
tOX1C constltuents of concern lnto the Reglon's baSIn plans.
e) Adopt a POllCY and gUldellnes for staff rev~ew of new ocean
dumplng proposals and IssuanCe of permlts.
f) Report to the Board ln three months on lmprovements needed to
tIghten current staff procedures for conductlng 1nspections,
malntalnlng In-house records, and lnltlat1ng enforcement actlons.
g) Condl,Jct~_ ~ st udy_ J.nto the env!romental _e ffects -!:If ocea~dumplD~ _at
Dumpslte No.1. ThlS should provlde flrsthand Informatlon lnto an
~ssue-about WhlCh very llttle lnformatlon has been collected to
date (outllne glven In Sectlon 5.3).
5. Appropriate Health Agencies
'--
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'.
a) Followlng the release of the cancer rlsk assessment by the
Department of Health Serv1ces, Epldemlologlcal Studles Sect10n,
actlons prescrlbed (If any) should be promptly followed WIth a
VIew toward mInImizlng consumpt1on by flshermen and others of
DOT-contamlnated spec~es, WhlCh could lncrease the r1sk of
de\lelop~ng cancer. ~I. ,,:::-,.t~~L "--'__~~ _~r~.,..-_..:-r-_~--,
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Los Angeles County Sanltatlon DIstrIcts
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6.
a) Evaluate the extent to whlCh the DOT remalnlng In the JOlnt Water
PollutIon Control Plant outfall 1S contrlbutlng to the total load
of DDT In the the Southern CalIforn1a Blght.
7. SCIentlflc OrganIzatIons and AcademIc InstItutIons
are encouraged to undertake studIes to lnvestlgate:
a) Transport dynamlcs of chlorInated hydrocarbons 1n the mar1ne
enVIronment, and
b) AerIal fallout of DOT and other perSIstent compounds as a
contrIbutor of pollutants to the marIne enVIronment.
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3.0 OCEAN DUMPING UNDER LOS ANGELES REGIONAL WATER QUALITY CONTROL BOARD
PERMIT: A REVIEW OF PAST PRACTICES, POTENTIAL ADVERSE IMPACTS, AND
RECOMMENDATIONS FOR FUTURE ACTION
Introduct~on
The RWQCB began regulat~ng the practlce of ocean dump~ng 1n 1961. Ocean
dumplng was, as stated 1n the permlts lssued at the tlme, 11mlted to two
de81gnated dumpsltes (Figure 1). These are Dumpslte No.1 and the H-l0
Dumps1te space. Other known dumpsites are shown 1n figure 2. Today 1n
Ilght of our more advanced understand1ng of pollutant transport through
sedlments, water columns, and blota, thlS practice has largely been
dlscont1nued 1n Callfornla. However, pollutants dumped under RWQCB permlt
stlll may be present 1n conslderable QUant1t1es on the ocean bottom. A
reasonable effort must be made to ascertaln the degree to WhlCh potentlally
hazardous compounds such as berylllum, cyanlde, naphthalene, pestlclde
res1dues, and other mater1als cont~nue to pers1st and adversely affects the
local mar1ne env1fonment. The purpose of thlS report, then, 18 threefold:
(1) to summar~ze a careful exam~natlon of Los Angeles Regional Water
Qual1ty Control Boardf~les perta1n~ng to the practIce of ocean dumpIng,
(2) to reVlew the current state of knowledge on potentlal or actual adverse
effects upon the mar1ne env~ronment and human health result1ng from ocean
dump~ng, and (3) to recommend actions to be taken ~n orderto mlnlm~ze any
harmful ~mpact ar1slng from past and present ocean dumpIng pract1ces.
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DESrGNA TED OCEAN DU~"P!NG SITES IN THE SOUiHERN CALI FORNIA BIGHT
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4.0 HISTORY OF OCEAN DUMPING
Although Federal law has regulated ocean dumpIng of wastes from vessels
SInce 1886, the laws were Intended to prevent any obstructIon or danger to
navlgatlon. The envIronmental aspect of regulatIng ocean dumpIng dId not
come Into beIng untIl the MarIne ProtectIon, Research, and SanctuarIes Act
(Ocean Dump~ng Act) of 1972. ThIS Act sought to regulate ocean dumpIng and
to phase out dumpIng of harmful wastes.
The State Slnce 1949 has regulated all waste dIscharges consIdered a threat
to water quality In ground, surface, and ocean waters. However, thlS early
leglslatlon sought to regulate new and known waste dIschargers that were
caUSIng a nUIsance or pollutIon. Also, IndIVIdual regIonal boards Issued
theIr own water qualIty control polICIes for theIr respectIve coastal
waters. ConSIstent WIth what was known then of water qualIty standards,
these plans relIed on descrIptIve (qualItatIve) standards only. Only
durIng late 1960's and early 1970's dId (quantItatIve) water qualIty
obJectIves fIrst become establIshed.
Major changes of the 1970's have led to present-day practIces of regulatIng
ocean dump~ng. In general, EPA ~ssues permIts to dIschargers propOSIng to
dump only lf they meet strlngent crIteria. The State can assume an actIve
role by ISSUIng recommendatIons and comments on the proposed permlts (for a
detaIled dISCUSSIon of the relevant leglslatlon on ocean dumpIng see
Appendlx A.)
,
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4.1 Ocean DumpIng: Board Involvement and RegulatIon
-1~_ past decades, the ocean dumpIng at Industrlal chemIcals and other wastes
In the ~aters offshore of Santa Catallna 131and~was an accepted d1sposal
pract~ce. The dumplng was sanctIoned and regulated at var10us tImes by
dIfferent governmental agenCIes, Includlng the US Army Corps of EngIneers,
the CalIfornIa Department of Food and Agrlculture, the Los Angeles RegIonal
Water QualIty Control Board (LARWQCB) and the EnVIronmental Protection
Agency (EPA). OC~~~qlsQ9sal~of wa~~~~~~ the VICInIty of Santa CatalIna
Island was ~alJed ~~19~~~lthough uncontamInated dredge materlals
contInue to be dIscharged at an approved EPA SIte In the San Pedro Channel,
approxImately 7 mIles from the maInland at POInt Fermln.
On October 18, 1961, the Los Angeles Reglonal Water Quallty Control Board
prescrIbed waste dIscharge requ1rements for two waste haulIng f1rms, the
Callfornla Salvage Company (CSC) and the PacIf1c Ocean DIsposal Company,
Inc. (PODCO). On February 24, 1971, a thIrd waste haulIng fIrm, H-l0 Water
Tax Company, Ltd. (H10WTC), was placed under waste dIscharge reqUIrements
by the Los Angeles Regional Water Quality Control Board.
..
The nIne reglonal boards was establIshed wlth the passage of the
Porter-Cologne Water QualIty Control Act In 1969. PrIor to thIS tlme
the Los Angeles Reglonal Water Qual~ty Control Board the RWQCB was known
as the Las Angeles Water Pollutlon Control Board.
The waste dIscharge reqUIrements Issued to these three fIrms establIshed
the type, locatlon and manner In WhIch wastes were to be dumped at sea. The
requlrements also established that the waste haulIng flrms keep malntaln
logs of all trIps made to DumpsIte No.1, and that records be kept of the
quantItles and types of wastes dIsposed. FollOWIng IS a hlstorlcal
summary of ocean dumpIng whIle under regulatIon by the Los Angeles RegIonal
Water QualIty Control Board. ThlS summary prImarlly focuses upon
CalIfornIa Salvage Company and PaCIfIC Ocean DIsposal Company due to theIr
frequent dIsposal of Industrlal wastes.
CalIfornIa Salvage Company
In 1347, under methods and procedures prescrIbed by the Callfornla
Department of FISh and Game, the UnIted States Coast Guard, and the Los
Angeles Harbor Department, CSC began Its ocean dlsposal operatlon~ (1).
Between 1947 and 1961, CSCocean-dumped over 126 million gallons of liquid
wastes (1). The majOrIty of materIal dIsposed of durIng thIS perlod
conSIsted of caustlC and aCId wastes produced by oil reflnerles, although
'~nvlronmental P~otectlon Agency has estImated that about 2000-3000 gallons
~er day of DOT-containlng aCld sludge were also dumpe~ untll 1961~
The volume af wastes handled by CSC dropped from 1.2 ~1111on gallons (4.5
m1llion liters) per month 1n the m1d 1950's to approx~mately 210,000
gallons (795,000 lIters) per month In 1960. In a letter to the RWQC8 In
1966, WIllIam Hutchlnsan, then preSIdent of Cal Salvage, attrIbuted the
declIne to new 011 refInlng methods or to nother uses" for the wastes (2).
FIgure 1 shows the volume of wastes dumped on a mont~ly baSIS by ese.
~.
---
.
.
The RWQCB began regulat~ng CSC's ocean disposal actIvItIes In October 1961
when It adopted ResolutIon No. 61-43 as the company's waste dIscharge
requIrements. Under these requlrements, CSC dIscharged SOlId and lIqUId
contalner1zed IndustrIal wastes at a dIsposal SIte (Dumpslte No.1) located
~lth1n a radIUS of 3 nautIcal mIles at (5.5 km) Latltude N 330 37'
LongItude W 1180 40', about 10 nautIcal mIles (18.5 km) northwest of Santa
CatalIna Island (FIgure 1) at a mean depth of about 2500 feet (760 meters).
~~nt~~rl~~aste materIals were receIved at the company's operatIon SIte
at Berth 115, Port of Los Angeles, where they were loaded on a barge and
towed to sea for dIsposal. 10 mInImIZe navlgahoflC!.!ha~s t.o_s!ll-P-~, the
contaIners were perforated beforebe~n9 tbrown-Dverboard ~n order~to_lnsure
_ slnkIng.- The types and quantihes of 1ndustrial wastes dumped at sea -by
CSC durIng Its 12 years of operatIon (1961-1973) under the RWQCB's requ1re-
ments are lIsted on FIgure 4.
WhIle under regulatIon of the Los Angeles Reg~onal Water QualIty Control
Board, CSC was observed on three d~fferent occaSIons dump~ng IndustrIal
wastes ~n areas other than those prescrlbed 1n Resolut~on 61-43. The f~rst
v~olation was noted by los Angeles RegIonal Water QualIty Control Board 1n
a letter to CSC 00 July 20, 1966 (3). Accord~ng to CSC, the company
changed the d~sposal slte to Lat~tude N 330 34' LongItude W 1180 27'
(DumpsIte No.2, see FIgure 1) because the dIsposal area deslgnated by
RWQCB was "in hne WIth the naval weapons flung range" from San Clemente
Island (4). Although esc's waste dIscharge requirements were nat amended to
reflect thIS change 1n the dIsposal area, 1t appears from a letter CSC
wrote to RWQCB on May 23, 1968, that there was a verbal agreement between
Board staff and CSC to allow contlnuat1on of dumpIng at thIS locatIon to
cont~nue.
other dumpIng v1olatIons were observed on March 5 and March 12, 1968, when
the Los Angeles County SanItatIon DIstricts reported that CSC illegally
d~sposed of IndustrIal wastes near the Wh1tes POInts outfall (5). On
March 16, 1968 In response to these complaints RWQCB 1ssued a letter to the
company InformIng them that thIS was a vIolat1on of the Board waste
d1scharge requ~rements set by the Board. CSC was ordered 1n the letter to
ImmedIately cease Its 1l1egal dumpIng. There was no formal lovestlgatlon
~nto the problem by Board staff; ~t 1S not known therefore for how long or
how much waste was dumped near Wh1tes POInt.
-
The CalIfornIa Salvage Company operated untIl early 1973 (AppendIX B). In
order to clear the record of closed cases, RWQCB reSC1nded CSC's waste
discharge requ~rements on Apr1l 27, 1981. The total volume of 1ndustrlal
wastes dumped by CSC appears to be about 128 mIll10n gallons (485 m1llIon
l1ters) .
-q-
.
.
PacifiC Ocean D~sposal Company, Inc.
On May 22~ 1961, the Pac~f~c Ocean DIsposal Company, Inc. (PODCO) flIed
w~th RWQCB for an ocean dump~ng perm1t. Los Angeles Reglonal Water
QualIty Control Board adopted waste dIscharge requIrements (Resolut~on ~o.
61-44) for PODCO on October 18, 1961 and the company began ocean dumpIng on
November 1, 1961.
80th l~quid and SOlId ~ndustrial wastes were receIved at PODeO's facilIties
located at Berth 116, Pler E, Port of Long Beach. Bulk llqUld wastes we~~_
_ pumped Into a 45,000-ga110n (170,OOO-11ter) tank mounted on the company's
barge. -In addltlon to the bulk wastes, -smaller amounts of contalnerlzed
_sol~d and l1~Uld. Wastes were recelved by PODCO and towed by motor vessel
to the disposal area located wlthln a three nautlcal mlle radlUS of center
coord1nates Latltude N 330 37' LongItude W 1180 40'. The volumes and types
of wastes dIscharged Into the ocean by PODCO are given 1n F1gures 3 and 4.
For var10US reasons such as Shlp repalr, bad weather and 011 1n the wastes,
PODCO at tlmes dlsposed of materlals at the Elklns Ranch Dlsposal Plant
located 1n Flllmore or at the Grant Street LlQUId D1sposal Company located
ln WIlmIngton (6). Between 1961 and 1964, PODCO dlsposed of 684,000
gallons (2.5 mlllion llters) of 11quId wastes at Elklns Ranch and 149,000
gallons (564,000 lIters) of liqUld wastes at Grant Street LIqu1ds DIsposal
Company.
Although PODCO's waste dIscharge requlrements for ocean dumpIng remaIned 1n
effect untIl December 1969, PODeO conducted ocean dlsposal operatIons only
between November 1961 and January 1964 (Flgur-e 1). - 8eglnn1ng In ~prll
1964, Industrlal wastes receIved by PODCO were dIsposed of In the f1rm's
: dry wells. The dry wells, located at 914 Paul Jones Avenue, W1lmlngton,
-were Issued a permIt for operatIon by the Los Angeles CIty Health
Department on November 7, 1963. The condItIons for operatIon set forth 1n
the C1ty'S perm1t were adopted as waste d~scharge reqUIrements by RWQCB on
December 11, 1963.
'From 1965 to 1976 PODeO, through_tne~e~ells, d1scharged 450,000 gallons
l1-:iiTIilllon liters;-o7~1~-quld wast~_per month ~nto-the ground (7). The_
l~quld wastes percolated lnto-fhe- salt water-lntruded_Gasp~~ water-~earlng
zone of t~ Wes[--CoastBasln. From the-re lt eventua1ly f1owe_~ l!lto the~
Pacific Ocean (8;:-~----------- ~ ~ p- ~- - - -
-On Aprll 4, 1975, the State Water Resources Control Board, DIVISIon of
PlannIng and Research, determIned PODeO's dry wells dld not meet the
requ1rements set forth In Subchapter 15 of the CalIfornIa Admlnlstratlve
Code for Class 1 dIsposal (8). Based upon the evaluatIon of the DIVISIon
of PlannIng and Research, 'RWQC8~L~~Qt0ged PODCa~~_ waste dlscharge requlre-
ments for ~an_d dlsp~sal__of ~a~5_e~_o!1_ O::t':lber_ .1.0, 1976.
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1::73
.
.
F.lgure 4
SUMMARY OF OCEA~ DUMPED LIQUID WASTES
BY THE CALIFORNIA SALVAGE COMPANY
BETWEEN THE YEARS 1965 TO 1972
Jype 0 f Wastes Volume (gallons) Percent (%)
Alunl.lnum Chlonde 776,000 50.5
Cyan.lde 273,000 17 .8
Solvent Wastes 55,000 3.6
AC.ld Wastes 24,000 1.6
Beryll.lum 5,000 0.3
M.lsc. Chemlcal Wastes 403,000 26.2
(e.g., ceSlum, brom1ne,
f.llm process.lng materlals)
1,536,000 100.0
SUMMARY OF GCEA~ DUMPED LIQUID WASTES
BY THE PACIFIC OCEAN DISPOSAL COMPANY, INC.
8ETWEE~ THE YEARS 1961 TO 1964
Type of Wastes Volume (gallons)
Caustlc Wastes (NaOH) 1,382,000
Percent (%)
85.4
CalClum Fluor.lde 103,000
6.4
Polymer Ac!d Sludge 78,000
4.8
ACld Wastes 16,000
1.0
M1SC. Chemlcal Wastes 39,000
(e.g. n.ltflc-hydrofluoflC
aCld, palnt and lacquer,
hydrolyzed alumlnum
chlorlde solutlon) 1,618,000
2.4
100.0
-1..7-
.
.
H-10 Water Tax~ Company, Ltd.
H-10 Water Tax~ Company, Ltd. (H-10WTC) began operat1ons 1n 1931 when the
company was 1ssued a permIt for Vessel and Alrcraft Garbage Collectlon by
the State Department of Food and Agrlculture. Between the years 1931 to
1975, H-10WTC dumped at sea up to 50 tons per week of garbage and trash
collected from ShIpS In the Los Angeles and Long Beach Harbors. In
addltlon to d~spoSlng of vessel refuse, H-10WTC also dumped mlnDr amounts
of lndustrlal wastes (In weIghted, sealed contalners) and dlseased meats
prohlblted from enterlng the UnIted States.
The RWQCB began regulating H10WTC's ocean dlsposal operatlons on February
24, 1971 when It adopted ResolutIon No. 71-10 as the company's waste
dIscharge requIrements. The H10WTC dlsposal slte 15 located wlthln a one
nautIcal mlle radlus of center coordInates at LatItude N 330 17' LongItude
W 1180 10' (See Flgure 1) RWQCB desIgnated a second d1sposal slte,
although it was rarely used.
In 1973, EPA requlred H10WTC to flle for a garbage and trash ocean dIsposal
permIt. EPA regulated H10WTC's ocean-dumpIng untll 1975, when the company
ceased its d1sposal operatlons.
Los Angeles Regional Water QualIty Control Board InspectLons of DumpsLte
No. 1
In general, trlp logs to the disposal area submItted by CSC and PODeO are
not well documented. On several occaslons, the companles were dellnquent
in submlttLng the requlred trlp logs.
Logs were submItted only when speclflcally requested by Board
staff. On July 20, 1966 and agaIn on March 18, 1968, Board staff Issued
letters to CSC statIng that trlp logs must be flIed wLth the
records of materlal dlsposed (3, 9). PODCO was issued slmllar letters
on May 3, 1962, July 29, 1962 and September 25, 1964 (10, 11, 12)
Although Board staff lnspected both Cst and PODCO harbor facIlltles durLng
thelr years of operatlon, the companles' dIsposal actlvltles were not
closely monltored. Board staff never a~companled pooeo on any of ~t$
dIsposal runs. Board staff observed CSC dIsposal operatIons only once, on
March 30, 1973. Accordlng to a report fLled by Los Angeles Reglonal Water
QualIty Control Board navIgatlon to the deslgnated dumpslte was accom-
pllshed by dead reckonIng:
"From my esbmate we were approx~mately on 10caUon, based on
tlme of run and relatIve posltlon between the maInland and
[Santa Catal1na] lslandll (13).
Upon arrIVIng at OumpsIte No.1, the dlsposal operatIon was carrled out In
the follOWIng manner:
"Dlsposal of the chemicals was very thorough, none of the glass
bottles or Jars were left floatIng on the surface [of the ocean].
Each contaIner was IndlvIdually broken before dlsposal overboard.
~ Drums contalnlng chemlcals were emptled and allowed to slnk after
holes were placed 1n the top, bottom and sldesll(13).
_1 "'::_
.1--
.
.
FJ.gul"e 4
SUMMARY OF OCEAN DUMPED LIQUID WASTES
BY THE CALIFORNIA SALVAGE COMPANY
BETWEEN THE YEARS 1965 TO 1972
Type of Wastes Volume (9allons) Percent (%)
AlumJ.num Chloude 776,000 50.5
Cyamde 273,000 17.8
Sol vent Wastes 55,000 3.6
ACld Wastes 24,000 1.6
BeryllIum 5,000 0.3
M1SC. Chemlcal Wastes 403,000 26.2
(e.g., ceslum, bromlne,
fllm processlng materlals)
1,536,000 100.0
SUMMARY OF OCEAN DUMPED LIQUID WASTES
BY THE PACIFIC OCEAN DISPOSAL COMPANY, INC.
BETWEEN THE YEARS 1961 TO 1964
Type of Wastes Volume (gallons) Percent (%)
Caustlc Wast es (~aOH) 1,382,000 85.4
Calclum fluorlde 103,000 6.4
Polymer ACld Sludge 78,000 4.8
ACld Wastes 16,000 1.0
M1SC. Chemlcal Wastes 39,000 2.4
(e.g. nltrlc-hydrofluorlc
aCld, palnt and lacquer,
hydrolyzed alumlnum
chloride Solutlon) 1,618,000 100.0
---:;-
.
.
H-10 Water Tax1 Company, Ltd.
H-1Q Water Tax1 Company, Ltd. (H-10WTC) began operations 1n 1931 when the
company was 1ssued a perm1t for Vessel and A1rcraft Garbage Collect1on by
the State Department of Food and Agr1culture. Between the years 1931 to
1975, H-1DWTC dumped at sea up to 50 tons per week of garbage and trash
collected from Sh1pS 1n the Los Angeles and Long Beach Harbors. In
addItIon to dlsposIng of vessel refuse, H-10WTC also dumped mInor amounts
of 1ndustr1al wastes (In we1ghted, sealed conta1ners) and dIseased meats
prohlb1ted from enter1ng the Unlted States.
The RWQCB began regulatlng H10WTC's ocean dIsposal operat1ons on February
24, 1971 when It adopted Resolut1on No. 71-10 as the company's waste
dIscharge requ1rements. The H10WTC d1sposal slte 1S located w1th1n a one
nautlcal mIle radlus of center coordlnates at latltude N 330 17' long1tude
W 1180 10r (See F1gure 1) RWQCB desIgnated a second dIsposal slte,
although It was rarely used.
In 1973, EPA requIred H10WTC to flle for a garbage and trash ocean dIsposal
permlt. EPA regulated H10WTC's ocean-dumplng untll 1975, when the company
ceased 1tS dlsposal operatIons.
Los Angeles Reglonal Water Quallty Control Board Inspectlons of DumpsIte
No. 1
In general, trlp logs to the dIsposal area subm~tted by CSC and PODeO are
not well documented. On several occaSIons, the companles were delInquent
1n submlttlng the requ1red trlp logs.
Logs were submItted only when specIflcally requested by Board
staff. On July 20, 1966 and agaln on March 18, 1968, Board staff 1ssued
letters to CSC statlng that trIp logs must be flIed wlth the
records of materlal d1sposed (3, 9). PODCO was lssued slmllar letters
on May 3, 1962, July 29, 1962 and September 25, 1964 (10, 11, 12)
Although Board staff lnspected both CSC and PODCO harbor facllltles durlng
the1r years of operatIon, the companles' dlsposal actIvlt1es were not
closely mon1tored. Board staff never accompanled PODeO on any of Its
disposal runs. Board staff observed CSC dIsposal operatIons only once, on
March 30, 1973. According to a report flIed by Los Angeles Reglonal Water
QualIty Control Board navlgatlon to the deSIgnated dumpslte was accom-
plIshed by dead reckonIng:
"from my estImate we were approxImately on locat1on, based on
tIme of run and relatIve posltlon between the maInland and
[Santa Catahnal Islandll (13).
Upon arrIvlng at Dumpslte No.1, the dIsposal operatIon was carrled out In
the followlng manner:
IIDIsposal of the chemicals was very thorough, none of the glass
bottles or Jars were left floatIng on the surface [of the ocean].
Each container was IndIVIdually broken before dIsposal overboard.
Drums contalnlng chemicals were emptIed and allowed to slnk after
holes were placed 1n the top, bottom and sldes"(13).
, ~
.... --,j-
.
.
Due to the Imprec~se method of navIgatIon and the poor recordkeeplng by CSC
and PODCO, It IS not possIble to determ~ne how many tImes the companIes
actually dIscharged theIr wastes at the desIgnated dumpslte. A dIsposal
run tg _and jromJJ1~lLflr:..escr_lbed_Jl_'!l_~t~ of PlJ.!T!PS1J:~ No. 1 took 11_hour~_---
ThI{s-lnconvenlence, combIned wLth Infrequent RWQCB complIance InspectIonS,
presents the pOSSIbIlIty that industrIal wastes were frequently dumped
closer to San Pedro eay.
.
.
4.2 Current Ocean DumpIng 1n the Los Angeles RegIon
THUMS Long Beach Company
In November 1982, THUMS Long Beach Company of Long Beach, Cal1fornla,
applied to EPA for an ocean dumpIng permIt to dIspose of drillIng mud and
cuttIngs by dumpIng them In a speCIfIc slte that wIll meet EPA require-
ments. The muds and cuttings wastes proposed for ocean dIsposal wIll
result from THUMS' drIllIng actlvltles at four Islands WIthIn Long Beach
Harbor and wIll be hauled to the dumpsIte by a 220-foot (67-meter) motor
vessel.
As prOVIded In the MarIne ProtectIon, Research and SanctuarIes Act of 1972,
as amended, EPA proposed to issue an ocean dumpIng permIt after formally
deSIgnatIng the slte, pursuant to the EPA Ocean DumpIng RegulatIons (40
erR, Chapter I, Subchapter H, SectIon 228.4). EPA Issued a publIC notIce
on December 8, 1983 (FR, Vol. 48, No. 237, pp 55000-55004) announCIng a
tentatIve determInatIon of Its proposal to deSIgnate an approprIate SIte at
which THUMS muds and cuttIngs may be ocean dumped, and to issue a permIt
for the d~sposal of spec~f~c types and amounts of mater~al for a specIf~ed
peLlod 0 f bme.
The proposed SIte 15 about 16 nautIcal mIles (29.6 km) from long Beach
Harbor WIthIn a 1.5 mIle (2.8 km) radlus of lahtude 330 34' 3011 Nand
longltude 1180 27' 30" W near the center of San Pedro BaSIn. It lIes about
8 mlles north of Isthmus Cove on Santa Catallna Island. The water depth 15
485 fathoms (2,910 feet, 887 meters).
EPA proposes to Issue a 3D-year permIt and to lImIt the disposal to a
maXlmum of 628,900 barrels or 100,000 CUbIC meters per year. The average
load WIll be about 6,000 barrels, and dumplng WIll occur at a frequency of
between 6 and 26 tImes per month.
SImIlar waste materIals had been dumped for three years In the VICInIty of
the proposed SIte from 1966-69 under the cognIzance of State and Federal
agenCIes WIthout any reported slgnlf1cant effect.
The drIllIng muds to be used by THUMS WIll be water-based and chromlum-
free. Soybean 011 Will be used as a lubrIcant Instead of the more tOXIC
diesel or mIneral 011. The drIllIng muds formulatIons are SImIlar to the
"generIC" muds WhICh have been approved by EPA on the basls of bIoassay
'tests for use In the EPA general permIts.
Board staff has reVIewed the EPA proposed SIte deSignation the
EnVIronmental Impact Statement (1983) on the deSIgnatIon, and the THUMS
applIcatIon document. A water qualIty monItorIng program WIll be 1ncar-
porated Into the perm~t.
If at some future tIme, eVldence appears that militates against continued
dIscharge, the Board could arequest to termInate the permIt.
-~:::-
.
.
Star-KIst Foods1 Inc.
Star-K1st Foods, Inc. has applIed to EPA for a spec1al permlt to transport
and dump waste materIals resultIng from the operatIon of Its fIsh proces-
SIng facllIty at Termlnal Island, Cal~fornla. The materIals to be dumped
conSIst of unprocessed wastewaters (l.e., brlne water, unloadIng water,
croaker JUlce and press lIquor) and DIssolved AIr FlotatIon (OAF) sludge.
Because the unprocessed wastewaters are conSIdered fISh waste, the exclu-
Slon from permlt requlrements pursuant to 40 eFR 220.1(c)1 apply(14);
however, the DAF process sludge whlCh 1S derived from the floatable sollds
obtaIned In the wastewater treatment process at each cannery does requ1re a
permlt and formal slte deSIgnatIon (15).
The proposed dlscharge slte 1S 3.5 nautIcal mIles (6.5 km) from the Los
Angeles Harbor breakwater at a depth of over 120 feet (37 meters) and WIll
be deSIgnated as a CIrcle WIth a dlameter of 1.5 nautlcal mIles (2.8 km)
centered at 330 38.7' N latItude and 116014.3'W long~tude. SInce the SIte
IS on the edge of State Waters, the Reglonal Board requ~red Star-KIst Foods
to fl1e a report of waste dIscharge. EPA has prepared a Draft
Envlronmental Impact Statement on the proposed SIte and on June 14, 1984,
Issued a draft permlt, fact sheet, and publIC notlce. EPA has made a
tentatlve determlnatlon to Issue a Research Ocean Dumplng permIt for a SIX
month perIod. The SIX month limIt IS necessary to determIne the fate of
the waste materIal durIng full-scale dIsposal operatIons and to allow for
addIt10nal fIeld monltorlng (15). To date, EPA has not Issued the fInal
permIt. LARWQCB WIll lssue waste dlscharge reqUIrements after revIewlng
the fInal EPA permit.
-~~-
.
.
Other Currently Accepted Practlces
W~th the recent closure of BKK landflll, there are currently no Class I
hazardous waste dlsposal s~tes eXlst1ng In Los Angeles County. Industrlal
wastes produced In the Los Angeles area are now trucked to
elther the Casmalla Resources FaCll1tIes 1n Santa Barbara County, or
Kettlemsn Hllls waste dlsposal s~te ln Klngs County.
Garbage and trash from fore1gn vessels moored in Los Angeles and long
Beach Harbors are compacted or stored 1n holdIng tanks for dIsposal at sea.
By 1nternatlonal agreement, the refuse may be dumped or
lnClnerated once the vessel IS 50 m1les offshore. The d1sposal actlvltles
are regulated by the United States Coast Guard.
When brought ashore for d1sposal, the Cal1fornis Department of Food and
Agrlculture requires that refuse such as d1seased meats be double-bagged
and sealed. The waste 15 then transferred by sealed trucks to a plant
where It ~s sterlllzed and burled In a landfIll. The waste IS transferred
by sealed trucks to a plant where It 1$ sterIlIzed and buried In a
landfl1l.
-~7-
.
.
5.0 ENVIRONMENTAL AND HEALTH EfFECTS OF OCEAN DUMPING
5.1 Montrose Chemlcal Company
'_Recent publIC a~~e~tlon has focused upon a po~en~lal heal~~_h~zard aSSOCl-
_ ated w~ ffi consumpUon 0 f fHh taken from Southern Call forn.la coa5lt_~r=-- ~
_wateE-s; many of-wh~ch have been found to contaJ.n hJ.gh concentratIons of
DOT. Though other env~ronmental toxlcants are also wIdespread and the
subject of great concern (e.g. heavy metals, synthetJ.c organJ.c compounds,
etc.),DDT and PCB's have been subjected to more_sc~entifJ.c scrutlny _~hr_ough
~the yearsThan- any other pollutants ~n hJ.story. ThlS lS due In part to the
persrstenc~o-r these compou~ds wh.lch enables them to remaln for years In
marIne sedlments and tJ.ssues of lIVIng organJ.sms. They have both been
declared by the Envlronmental Protection Agency (EPA) to be potentIal human
carclnogens, and lt IS thlS fact In conjUnctIon WJ.th the1r hIgh tOX.iClty
prohles and then potentIal for "blomagnl flcatlon" that has caused EPA to
d.lscont~nue reg1strat.ion of both compounds. DDT 1$ of prlmary enVlron-
mental and publlc health concern both because of the amounts barged to
Dumps1te No.1, and because of .its dIscharge through the JOInt Water
PollutJ.on Control Plant (JWPCP) of the Los Angeles County San1tation
Dlstrlcts (LACSD).
Montrose ChemIcal Company of Torrance! Callfornla, was for 35 years
(1947-1982) the ~ole manufacturer of ODT~ln Cal~f~rnl? and the largest
m~nufacturer .in the Unlted States (16). Records from the years 1957-1958
show -tfiat- 2000~}nQa_barr~~s~a~moQtb of waste aCLd sludge (est.imated to
conta1n 5,000-10,000 ppm (0.5-1.0%) total DOT) were barged to ocean
~Oumpslt~_N~.1~. These records show about 2,OOO,OOOgallons-17:6 mIllIon
l.iters) dumped during the two-year per10dj from thlS It .is Inferred that
Montrose chemlcal barged at least 10,000,000-14,000.000 gallons (37-53
mlll10n lIters) of waste DDT-contalnlng aCId sludge durlng the years
1947-1961.
At the t.ime Los Angeles RegIonal Water QualIty Control Board assumed
responslbl11ty for the lssuance of ocean dumplng permlts (1961), records
IndIcate that Montrose ChemIcal Company was already dIvertIng Its caustIC
wastes to the JWPCP at WhItes PO.int, and had begun transportIng ItS aCld
wastes to a Class I landfIll (Flgure 7). It IS therefore reasonable to
assume that whatever DDT was dumped at ocean Dumpslte-No. 1 has b~en there
for at least 24 years.
Examlnat.ion of the records on DOT waste beIng generated from Montrose
Chemical reveal some very startllng numbers WIth respect to quantItIes
dlscharged fram the JWPCP outfall at WhItes Point. Dur1ng the 1960's up
to 290 kg (638 pounds) ~~r da~ Wefe being~_dlschar~l}r~llg~ _ !~~
*
Based on quantItIes of aCld sludge dlsposed through CSC for 1957-1958,
the following calculatIon for the fourteen-year dumpIng perlod of
Montrose Chemlcal Company has been made: average no. of bbl/mo = 2416
EstImated concentrat.lon of DDT 1n aCId sludge IS 0.5% - 1.0%. For an
average 0.5% DOT concentratlon .in the aCId waste stream, Montrose
would have dumped about 346 metrIC tons over the fourteen year perIod,
and for 1.0% about 696 metrle tons (1 metrlC ton = 2205 lb.).
_1S'_
.
.
outfall. As publlC awareness grew, the LACSD responded by takIng samples
wh~ch eventually traced vIrtually all of the DDT waste to a SIngle pOInt
source; Montrose ChemIcal. FollowIng IS a brIef chronology leadIng to the
curtaIlment and eventual removal of Montrose ChemIcal Company Influent to
JWPCP (17):
*
March 30, 1970: LACSD samplIng showed dIscharge of close to 290 kg (638
lb.) peZ' day
*
AprIl 1970: InIt1atlon of caust1C waste landfIll disposal (together
WIth aCId sludge)
*
July 27, 1970: LACSD sampl1ng showed dIscharge of "only" 20 kg
(44 lb.) per day
*
August 4, 1970: Analysls of lIqUId waste stIll Issulng from Montrose
showed a DDT concentratIon of 3400 ppm.
*
July 15-16, 1971: SamplIng of 200 meter sectIon of sewage pIpe
between two samplIng statlons downstream of Montrose
showed 32% and 39% (320,000 and 390,000 ppm,
respectIvely) DOT by total weIght In the sedIment.
* June, 1971: Influent from Montrose ChemIcal IS completely shut off, and
all DDT wastes (aCId and caustIC) are trucked to a Class I
landfIll.
* 1975: FIve years after termlnatlon of Montrose dIscharge to JWPCP
the mass emISS10n rate (MER) IS stIll 15 tImes hIgher than
the MER to Hyperlon Treatment Plant, (1 metrIC ton/yr vs.
0.06 metrIC ton/yr, respectIvely).
-"'"
An estlmate maq~ late~_Qf the total caustlc waste emlSSlon through JWPCP
was some 22,000 galions (83,000 lIters) per day WhICh corresponds to
approxImately Z70~kg_S595 pounds) per day total DOT dIscharged _through the
outfall(B)~ Therefore-;- It can be estlmated that durIng the 18 years of --
dIschargIng caustIC waste, about 1800 metrIC tons. of DDT was dIscharged
through the JWPCP outfall. The upper 30 cm.(l foot) of sedIment In the 48
km2 (18 square mlles) around the JWPCP outfall were found to contaln
180-250 metrlc tons total DOT (19), and, In another study, the 28 km2 (11
square mIles) of sediment around the outfall were est1mated to contaIn 200
"metrlc tons (20). It should be noted that all studIes done to date wh~ch
measure DDT ~n sedIments of Southern Callforn~a show ~ clear grad}ent-QL
declln~ng 001 c~~ce~~ratlons as a functlon of dlst~n~e ~rom the Whltes__
POlnt outfall. EVIdence suggests that because there IS relatively hIgh
- uptake of DOT by marlne biota, DDT In the sedIment IS "bIoaval1able".
Though as much as 700 metrlc tons of waste DDT may have been dumped at
Oumps~te No.1, very lIttle lS known about environmental transport or
bIodegradatIon of DOT at such depths (about 2500'). DDT 15 thought to be
more readIly metabolIzed to DOE and other metabolites In sedIments under-
lylng shallower waters, due In part to Increased levels of dIssolved
oxygen (19). Addltlonally, because water movement at such depths is far
_'10_
....-
.
.
less than along shallower coastal ocean bottoms the m~x~ng of DDT In the
deep water column Is not lIkely to be as thorough as In shallower waters.
In varlOUS studIes bacterIa have been found WhlCh are Involved In the
bIodegradatIon of halogenated hydrocarbons. However, ~n the absence of
dIssolved oxygen aerobIC bacterIa would not readily surVIve (21). It
therefore fallows that even If substantlal quantltles of DOT have been
dumped and are stlll present, thelr low bioavailabillty due to the extreme
depth may Ilmlt effects on marIne blota.
C~~centratIons of DDT In surfICIal sedIments, the water column, and In
~ b~ota--appear to be decl1mng. In 1983 the total quantlty of DOT d.ls-
charged through the WhItes POInt outfall (from sedIments In the sewage
lIne) was less than 500 kg. (1102 pounds) for the fIrst tIme SInce the
1950's (30). FIgure 5 depIcts the declIne of DOT emlSSlons over tIme whIch
appear to be presently decllnlng at the rate of 20-30%/yr. FIgure 6
dep~cts mass emISSIon rates from varlOUS Southern Callfornla sewage
treatment plants, clearly shOWIng that the Los Angeles County outfall
(LACSD) has contrlbuted for more DOT residues than have the other sewage
treatment plants. young et 81.(31) have stated that aerlal fallout may be
a major source of DOT In Southern Callfornla. Other non-pOInt sources of
DDT ~nclude storm draIn runoff and agrlcultural return waters. Recently,
the pestICide dlcofol (kelthane) has been the reCIpient of much attentlon
due to the fact that DOT, DOE and ather metabolltes comprIse a SignifIcant
porhon of its formulatIon (32). When tI[ fresh" OOT IS found In enllHon-
mental samples It 15 therefore diffIcult to trace the source, as dIcofol
contInues to be regIstered and wldely eyed in Callfornla.
-. ~
-~-- .-
.
.
DD~ ;2~D ?C3 ~~ISSICES FRC~ r~~OR
l'Tul~IC :?,..;.L \~").ST=:~~l.ATE3. DISCHP2G.E
CfJTF;_:'LS DrI'O THE SOUT~RH
CALIFORXL4. BIGHT
20,000
700l (1971) 8,500
).. J. ).
\ r ,
f ,
I ,
. I ,
1 I \
I \
6000 [ \ ..
1 I \
1 I
I \
J ,
I \
5000 f \ J \
\ f \
\ I \
\ I \
\ I \
1/ \
\
(/) , \
\
~ ..
< s \
c: 4000 r \ \
(!l \
q \
\
::: \
~ I \
\
\
3000 ~ \
l \
\
1
\ .....,
2cot 1./ ,
~. ... \ PCS
\
'11 \
\
\
COT \ \
..............",........., "'~
100l /-"" '",V'"
11__
..........
"----
f I I f I
1971 73 75 77 79 81 83
YEAR
.,...,-,..,u-- 5
~ . 1- i........
-.......... -........
D=~ ~2~ PC3 E~=SSIO~S, 1971-1983
:~:z SCCw3P 3len2lal ~eport, 1983-1984
-2:-
.
.
FlgUI'e 6
DOT Mass Emlsslon Rates from
VarlOUS Southern Callfornla Sewage Treatment Outfalls, 1975-1978
(after SCCWRP 1979-1980)
Sewage Treatment Plant
Hyperlon Treatment Plant
Total DOT (k9/yr)
5 mIle out fall
18 + 4
7 mIle outfall
12 + 3
LACSD
870 + 150
OCSD
15 + 5
San Dlego CIty TP
24 + 10
Oxnard TP
1.4 + 0.3
FIgure 7
DOT Wastes from Montrose Chemlcal Company: DescrIptIon of the Wastes and
the ~ature of thelr DIsposal, 1947-1961
YEAR ACID SLUDGE CAUSTIC WASTE
1947-1951 Barglng to Ocean Barglng/Storm DraIn
Dumpslte No. 1
1951-1961 Barglng to Ocean Storm DraIn/Sewer
OumpsIte No. ~ (permlt Issued 1953)
I
1961-1970 Class I Landflll Sewer (LACSD)
1970-1982 C1 as s I Landflll Class I LandfIll
1982 MONTROSE SHUTS DOWN
~..,
-/-=.--
.
.
DESCRIPTION OF DOT WASTE GENERATION
ACID WASTE: Monochlorobenzene, chloral and sulfur1C aCId are reacted to
form DOt, ODE and other related compounds. As a result of thIS reactIon
process an ac~d waste IS generated contaInIng a mIxture of sulfurIC aCId,
organIC substances and water. Montrose ChemIcal Company produced up to
10,000 galiday of aCId waste.
CAUSTIC WASTE: In order to remove lmpurltles created durIng the
reactlon process, DOT IS washed WIth a sodIum hydroxide-based caustIC
solutIon. The amount of caustIC waste produced by thIS step was
approxImately three tImes that of aCld waste generated.
SOURCES
Los Angeles CIty EngIneers
Montrose Chemlcal Company
lACSD
RWQca
EPA Report (CERCLA InvestIgatIon, 1983)
~~
-~~-
.
.
5.2 Impact on Mar1ne BIrd PopulatIons In Southern CalIfornIa
HIgh total DDT concentratlons In WIld bIrds are belIeved to cause eggshell
thInnIng, whICh has resulted In the declIne of the CalIfornIa brown pelIcan
populatIon In the late 60's (21, 22, 23). VIrtually all eggs laId In
Southern CalIfornIa In 1969 dId not surVIve the InItial perIod of Incuba-
tIon (24). Due to these hIghly VISIble manIfestatIons, DOT IS a conven1ent
pollutant Indicator In determlnIng waste transport and environmental
effects, as the pelIcans are of DDT pollutIon.
'The effects of DDT from deep ocean dumpIng should be most apparent In areas
of upwellIng. One such area, located 75 kIlometers (41 nautlcal mlles)
down current (FIgure B) of OumpsIte No. 1 is the Channel Islands NatIonal
Park (FIgure 1). The upwellIng of nutrIent-rIch waters from 240o-meter
(7900') deep basIns-fo-the south and west of the park contrIbute to
_except~onally productlve food webs (25). ThlS supports large schools of
northern-anchovy, whICh In turn sustaIn the pellcan durIng ItS breedlng
season. These bIrds nest In colonIes on Anacapa, a group of small Islands
WIthIn the NatIonal Park. The pelIcans. however. are not confIned to the
Southern CalIfornIa 81ght beyond the nestIng season(26).
HIstorIC records (FIgure 9) of the Anacapa pelIcan populatIons eXlst from
1884 (25). These records IndIcate a populatIon of between 200 and 5000
breedIng paIrs between 1910 and 1941. There is a 21-year gap from 1941 to
1962. Records do not 1ndIcate when eggshell thInnIng was fIrst obser-
ved, but fledglIngs were reported as late as 1962. Up to a thousand
breedIng p81rs were observed In 1963 and 1964. In the late 1960's and
early 1970's populatlon decllne caused by DDT Induced eggshell thInnIng
became appar8nt (23). By the mld 1970's the pelIcans of Anacapa had begun
to recover.
The pelIcans qUICkly responded to the curtaIlment of Montrose Chemlcal
Companyls process wastes from the LACSO system In AprIl 1970 (24). There
IS llttle doubt that DOT pollutIon contrIbuted to the declIne of the
pelIcan populatlon on Anacapa durIng the late 1960's. However, no compel-
11ng eVIdence presently eXlsts whIch lInks this declIne WIth the ocean
dumpIng of DDT wastes (1947 to 1961).
Other bIrd populatlons from CallfornIa offshore Islands have also declined
In recent decades. These lnclude the bald eagle, peregrIn falcon, osprey,
and double-crested cormorant (27). All these bIrds are dependent upon the
marIne ecosystem.
No documentatIon has been found lInkIng populatIon decllne of local Island
bIrds to waste dIsposal at ocean DumpsIte No.1. The dIsappearance of the
bald eagle from Santa CatalIna Island, howevert may COInCIde WIth the
InItIatlon of dumplng operatIons. ThlS bIrd has hIstorlcally nested on the
Island. Though egg collectIng, shootlng, trappIng and other human
pressures have contrIbuted to Its declIne In the early 20th century (28),
eVldence suggests that the eagle populatIon was healthy In the mld 1940's,
by WhlCh tIme such actIvltles had dlmlnIshed. The bald eagle became
locally extlnct on Santa CatalIna Island between the late 1940's and mId
1950's (29).
-2~-
.
.
Factors contrlbutlng to the bald eagle dlsappearance from Catallna Island
are presently under lnvestlgatlon. The bIrd was reIntroduced onto the
1sland In 1980. Though apparently healthy, they have not yet successfully
reproduced (29).
The Natlonal Park ServIce conducts an ongolng marIne blota monltorlng
program WIth the Callfornla Department of FISh and Game 1n the Channel
Islands Nat10nal Park (25). The analysls of prloflty pollutants such as
DDT should be incorporated in to this program to provide valuable Infor-
matlon on the dlstrlbutlon of these substances and thelr envlronmental
effects. SlmIlar programs should be developed for other Islands In the
Southern Callfornla Blght.
~~
-/;-
.
.
CAI!~O?2~1 u~~JERC~~qs1~
1
J
""'MT 'EACH ~
, ~~ ~>
-- ~ I~
~ C~'" " ~V"""OAl
'- 'J~ &"\~;- i (\ gc~" I
I' ..0-
'I 0'" '00 """"'\ .CQJ' ~ \ ./ i
. , I ~~.
J(;~81.1;-E::;S '--) _ t~ f
X"'!- :lE.?-i-'S iN ME":'"e RS - =<:. L~ ~_
\ ," ~. I
1:2..Q 1:::-0 1~ 118w , 160
;V~ean Geostro"hlC ;:::::Q\"J at 2CC '"':"I Oe::::th In t,e Scutf'''ern California Sight (Arrol,.vs Sho\.'V Dlrec:~al"' anc
:W~~;nn:ude: of F"O~..,li
~
I
JoI 0<-
I
l
,
i
:;:z;:>L
\
o
I
I
S"E=~ IClol'SE:l
:0
I
~
3':GL:?2 E
2C\C\-1.:..G:r~.3. ~:3:EP C;E.RE:{:S
:::; 'IS SOCr::3E~E~ CALI:2'CP..":.'i' -l.
-::'"'7"--:~"'"
_.J.........:.__
-)6-
.
.
FIGURE 9
H~storlcal Record of ~umbers of Seab~rds on Anacapa Island
(From Channel Islands Natlonal Park BIenn1al Natural Resources Report, 1982)
Colony
LocatlOn
BROWN PELICAN
BreedIng Paus
Date
E Island
E lsland
E Island
E Island
f\J end (7)
W ls1and
.W Island
W lsland
W 181 and
M~ddle ~51and
E Island
W Island
W lsland
'N lsland
W lsland. ~ slde
BreedIng birds reported
Nesbng buds
None
500 nests w/eggs, yng
(200), a few w/nests
Mendlng old nests; no eggs
(200); 2 nests w/1 egg each
"At least 1000"
1500
2000
(5000+)
Colony of several hundred (birds?)
2000-3000
500
Colony reported
200 nests w/eggs, yng
2000
(2000)
2000+; 1000 + yng
None
None
Same as for 1939
500 w/ eggs & yng
Several hundred liar perhaps 1000"
Nestlng b1.t'ds
~one
-77-
1884
1889
4-6 June 1899
5 June 1910
12 March 1911
May 1911
May 1912
11 June 1914
March 1916
March 1917
March 1920
B March 1922
28 March 1927
5 March 1928
24 Feb 1929
9 March 1930
Apul 1935
1 March 1936
16 Apnl 1939
16 Apnl 1939
16 April 1939
1 940, 1941
27 May 1962
1963, 1964
1967, 1968
13 May 1968
.
.
BROWN PELICAN (contlnued)
Breedlng Palts
f!
Colony II Ii Fledghn9s1
locatIon (Nests Sampled) Fl edgl1ngs Nest Year
W Island 750 4 0.005 1969
W Island 552 1 0.002 1970
W Island 540 7 0.013 1971
W Is1and 149 26 0.17 1972
W Island 247 34 0.14 1973
W Island 311 230 0.74 1974
W Island 212 182 0.86 1975
W Island 417 279 0.67 1976
W Island 76 39 0.51 1977
W lsland 210 37 0.18 1978
W lsland 1258 980 0.78 1979
W lsland 2147 1438 0.67 1980
W Island 2946 1805 0.61 1981
-28-
.
5.3 Summary of SClentlf1c LIterature
.
FIgure 10: Summary of Studies on Marlne Wl1dllfe relatIng to Effects by
DOT
Author/Vear
Gossett, et al.
1982
Schafer, at al.
1982
Gosset t, et a1.
1983
Puffer, et al.
1983
Burnett
1971
SCCWRP
1973
Macgregor
1974
McDermott/Sherwood
1975
- Young/Szp11a
1975
RIsebrough
1974
LAcsa
1919
SpecIes
Sport f1Sh
Mar1ne Mammals
Whlte Croaker
FISh
Sandcrabs
Dover Sole
Lantern fISh
Dover Sole
Mussels
Seab uds
~<
-~
j...--~
-=,
FISh and Invertebrates
_"10_
, ~
Relevant Flndlngs
DOT 1n wh~te croaker from
Wh~tes POInt 7.6 ppm
Exceeds FOA gUIdelines for
seafood
DDT In blubber of coastal
bottlenose dolphIn up to
2000 ppm
levels of DOT and PCB's may
present pOSSIble health
hazard when these f~sh are
consumed from Wh1tes POInt
DOT and PCB's dIssolve In 011
durlng pan-frYIng, thereby
reduclng concentrat1on
DOT In sandcrabs from Palos
Verdes are 50-100x greater
than concentratIons adjacent
areas
66% of Dover sole from Palos
Verdes exceeded FDA lImIts of
5 ppm In ed1ble fIsh flesh
LIver/flesh DOT rat10
decreases WIth an Increase In
percent 011 In flesh
FIn erOSIon assocIated w~th
hIgh DOT concentratIons
near out falls
DOT In mussels reflects a
decrease In lnput to Palos
Verdes coastal waters
l~nks chlorInated hydrocar-
bons to Pac1flc seablrd
decllne
DDT concentratIon 1n the
muscle tlssue of flSh and
~nvertebrates are one to
three orders of magnItude
lower for CatalIna Island
than for Palos ~erdes
Author/Year
Mearns
1977
Delong
1973
G~lmartln
1976
.
Spec~es
Sport F1Sh
.
Relevant Flndlngs
Half the annual commerclal
party boat catch on the
southern Callfornla malnland
shelf IS taken wlth~n 10 to
20 kIlometers of sewage
out falls.
Cah f. Sea L~on
Premature bIrth of sea 110ns
show possIble pred~sposltlon
to lnfectlon possIbly brought
on by hlgh chlorlnated hydro-
carbon concentratlons
-'},~-
.
.
5.4 PROPOSED STUDY REGIONAL BOARD OF OCEAN DUMPING AT DUMPSITE NO. 1 AND
ITS ENVIRONMENTAL EFFECTS
Los Angeles Reglonal Water Quallty Control Board wll1 seek fundlng to study
lnto the effects of hlstorlC ocean dump1ng upon the local marlne enVlron-
ment. A study of th1S nature could contrlbute very slgnlflcantly to what
lIttle lnformatlon IS already avaIlable [e.g. Macgregor 1976 (19)]. ThlS
proposed study would approach the problem as follows:
1) a gr1d wIll be developed for the approxImately 28 square mile area
of ocean Dumpslte No.1.
2) RegIonal Board staff along and cooperatIng agenCIes) WIll take water
and sedIment core samples from designated sltes along the grid. For
example, a telev1slon camera mounted on a "sled" could be used to
transmIt a vlsual Image from the ocean bottom 1n order to facIlltate
VIsual ldentlflcatlon of barrels or other eVIdence of wastes dumped at
ocean DumpsIte No.1.
3) FLSh w1ll be taken throughout the water column 1n the area of Dumpslte
~o. 1, and examIned for prlorlty pollutants.
4) BIota, water, and sedIments around the Santa CatalIna Island shorelIne,
and perhaps those of other offshore 1slands WIll be monltored to
detect any eV1dence of pollutIon orlglnatlng from the dumpsltes. Any
shorellne survelllance data already compLIed from other agencles and
researchers WIll be Incorporated Into the study.
5) Salls from former storage areas of CSC and PODCO WIll be thoroughly
analyzed, w1th a Vlew toward "flngerpr1ntlng" the types of wastes
lIkely to be retr1eved wlth sea bottom sedIment samples.
6) A slgnlflcant number of trlpS made by CSC to Dumpslte No.1 may never
have reached the deslgnated dumpslte area. Several vlolatlons have
been documented, but there IS no way of estlmatlng how many other trIpS
may have ended In dumplng of IndustrIal wastes Just offshore, or
enroute, and thIS possIblllty must be realized. Therefore, samplIng
WIll be done along a "transect" from Palos Verdes to Ocean Dumpslte No.
1 .
7) RWQCB records 1ndlcate that CSC may have also dlsposed of Industrlal
wastes at Dumpslte ~o. 2 (F~gure 1). The proposed study wlll Include
an lnvestlgatlon Into pOSSIble contam1natIon at thIS SIte.
B) If a lIhotspot" 1S found 1n the sed1ments, samples WIll be taken In
surroundlng areas 1n an effort to trace the mlgratlon and transport of
contamlnated sed1ments.
-~l-
.-
- ~- .-
- - ..'"-.--
- '--
.......
-
5.5 Cancer R~sk Assessment of DOT
'-'>-
1,_ ~
DDT analyses of sedlments, water, and b~ologlcal tIssues have been made
from many areas throughout the 5an Pedro Channel and Santa Mon~ca Bay
durlng the past two decades, and results have clearly shown that DDT has
been present 1n very hlgh concentratLons. Though concentratLons have
slgnlflcantly decllned Slnce 1970 due to dlmlnlshed ODT Input lnto coastal
waters, Lts perslstence and capaCity for b1omagn~flcatlon has led to a
gradual ascent through the varlOUS troph1c levels of the mar1ne ecosystem.
~ ,3?-.1!'Je prl.mar:L co,,!~ume!, _of J.Q~al seafgod must _p~_ aware of the health
r1sks assoClated wlth consump~~on_qf th1s~seafoo~; _WhLCh may cont~~n_DDT
and slm]}~E_ ~~~I~_u_~~~s. - --- --
The prlmary Issue of concern lS not acute tOX1Clty: It would reqUIre an
estImated 237 years for a 70 kg. f1sherman consum1ng 85.2 g/day In order to
accumulate enough ODE (the prImary metabolLte of DOT) to attaIn the rat
lCSO (the estlmated concentratlon reqUIred to klll half a study populatlon)
(33 , 34).
The maJor l~s~e IS ~athe0!'te-potenbal J.9_r DOT _to _~~duce cancer 10 humans
Wh1Ch, based on a number of studLes completed over recent years~ -has become
a matter of major concern (35). For example, the half-lIfe of DOT stored
1n human tIssues has been found to be 10-20 years, and that of DOE 1S 60-70
years (36). Th1S pers1stence 1n add1tlon to ItS well-documented tendency
to bloaccumulate requ~res careful attentlon to the potentIal for DDT and
Lts metabolltes to act as human carclnogens. AnLmal-based eVIdence for
DOT as a human carcLnogen 1S rather Inconslstent, as summarlzed 1n a table
from a 1985 report Issued by the EPA Carc1nogen Assessment Group (36):
AnImal test specles
EVIdence for (+) or aga1nst (-)
DOT carclnogenlclty
mIce
rats
hamster
flSh
dogs
monkeys
adequat e (+)
hmlted (+)
adequat e (+)
l1m1ted (+)
~nadequate
limlted (-)
Addltlonally, there 1S only llmlted eVldence based on human epldem10-
logIcal studIes. DQ! has not been found to be mutagen1c 1n bacterIal test
systems, and eVIdence of carc1nogeniclty from ~amma11an tIssue culture
systems IS also inconclUSIve. However, from the regulatory perspectlve
thlS eVldence IS suffIclently compelllng to cons~der DOT a potent1al
human carclnogen and to assign a llcarcinogenlc potency factorll based on
available InformatLon. The upper confldence Ilm1t of fISk can be approx1-
mated based on thIS factor.
Puffer et al. (37) Investlgated patterns of sportflshlng and seafood
consumpt1on from Southern Callfornla waters. They found wh1te croaker t~
be the _~o~t commonly ~~~gDt and_con~um~d fl~~~ Other stud1es (e.g. 33)
have shown whIte croaker to be among the most ODT-contamlnated flSh 1n
-37-
.
.
local coastal waters. Dover sole l~kewlse has been found to harbor hlgh
DOT concentratlons (33, 38). The federal Food and Drug Adm~n~strat~on has
stated that the 2e.flm31.af5!ty tolerance llm~t for ODT lr'1 ~~dlble_ f}.~~ tIssue
would be Ina~~g~~~~ ~~ protect_sPQ~i~~~Q~rme~ wh~~c~nsu~~ large quantItIes
of ~onf~~!lated speCIes -{?4;., AccordIng to a 1980 report -issueaby the
Sludge Management Program for the Los Angeles/Orange County MetropolItan
Area (LA/OMA), consumptlon of contamInated whlte croaker from WhItes P01nt
presents a 23-fold r1sk over the US average for those consumIng 36 g/day
(50th percent1le), and 180-fold over those consumlng 280 g/day (about half
a pound) (90th percentlle) (34). Th1S report calculated other potentlal
health risks based on concentratlons of DOT and PCB's found 1n local f1Sh.
It found, for example, that for the flSh contalnlng the h1ghest DOT
concentratlons at Wh1tes P01nt, consumptIon of "only 550 grams...would
result In a SIngle dosage eqUIvalent to that prOjected for the U.S. average
dIet for a perlod of... 30 years ln the case of DOT". In contrast the
report states that consumptIon of seafood from the areas around Hyperion
Treatment Plant (CIty of Los Angeles) or Orange County San1tatlon Dlstr1cts
out falls pose ~ SIgnIfIcantly greater rIsk from ODT than from control
areas.
The CalIfornIa Department of Health SerVIces, Epldeml010gIcal Studies
Sect10n has been commlssloned to conduct a carclnogen1c rIsk assessment
for Southern Call forma coastal waters based on -focal studles of DDT
contamInated flSh (37,33,39). The recommendatIons generated from thlS
assessment report pend1ng reVlew by EPA Reg10n 9, will be closely followed
w1th a v~ew toward prompt actIon by approprlate local, state, and federal
agencles. In add~tlon, work already 1n prInt such as the LA/OMA 1980 rlsk
assesment study WIll be conSIdered serIously, as ~t may accurately estlmate
human rlsks. If all fInd1ngs are conSIstent, ImmedIate actIon should be
taken to llmIt the Intake of fIshermen f1shermen consum1ng contamInated
speCIes. Mltlgatlon measures for m~nlmlz1ng the cancer rIsk from consumIng
DDT-contamlnated seafood could Include:
*
Pan-frY1ng of contamlnated flSh. ThIS may help to reduce concen-
trat~ons of chlorInated hydrocarbons, WhICh part~t1on Into solutlon
WIth hot cookIng 011 (40).
*
Advls1ng reCIpIents of sportflshlng lIcenses (by the Department of
FISh and Game) regardlng areas closed to or not recommended for
fIshIng, at the tlme of llcense Issuance,
*
~- ......
Posting warnIngs on pIers or other seafood-gatherlng areas for llmIt1ng
consumptIon of contamInated spec~es,
*
DesIgnat1ng the area surroundIng the WhItes POInt (JWPCP) outfall off
llmlts to sport fIshIng , at least for the two most potent1ally hazar-
dous specles (thought to be w~lte~Cr~!~er ~a~~_~ver sole).
Llmltlng the commerclal avallablllty of the most contamInated specles
caught 1n or near San Pedro ehannel on Santa Monlca Bay.
*
~~?
"
-----'
_-:c.~_
.
.
REFERENCES CITED
1. letter to RWQC8 From ese, dated August 2, 1961.
2. letter to RWQCB from ese, dated July 27, 1966.
3. Letter to CSC from RWQCB, dated July 20, 1966.
4. Letter to RWQCB from CSC, dated May 23, 1968.
5. Letter to RWQC8 from the Los Angeles County
Sanltat10n DIstrIcts, dated AprIl 10, 1968.
6. Letter to RWQCB from POOCO, dated March 5, 1966.
7. Cl.ty of Los Angeles Department of Pubhc Works
Bureau of San~tat~on, IndustrIal Waste PermIt,
(W-27397), dated May 21, 1965.
8. Memorandum to George B1111ngsley from State Water
Resources Control Board DI v 1510n of Planmng and
Research, dated April 4, 1985.
9. Letter to CSC from RWQCB, dated March 18, 1968.
10. Letter to PODCO Fran RWQCB, dated May 3, 1962.
11. letter to PODeO from RWOCB, dated, July 29, 1963.
12. Letter to POOCO Fran RWQCB, dated September 25, 1964.
13. RWQCB ComplIance InspectIon Report, dated March JO, 1973.
14. Env1ronmental Protectlon Agency - 1973
40 Code of Federal RegIster, Vol. 42
Parts 220-224
15. EPA - 1984
Notlce of Appllcatlon and Proposed Act10n
(Publ1c NotIce No. OD 82-02) for Star-Klst Foods Inc.
16. Schnldt, T. T., R. W. RISebroLgh and F. Gress, - 1971
Input ~- PCB's Into CalIfornIa Coastal Waters from Urban
Sewage Outfalls
Bull. Env~ eontam. and Tox~col. 6(3): 235-243
17. US EPA - 1983
Tox1cs and Waste Mgt. DIV. InvestIgatlon Report
Cerda InvestIgatIon (Montrose Chsucal)
18. McDermott, D. J., T. C. Heesel"l and D. R. Young - 1974
DOT In Bottom Sedlments 4round FIve Southern CalIfornIa
Outf all System s TM 217, ScCWRP
-34-
.
.
19. YOlllg, D. R., D. J. I1::Dennott and 1. C. Heesen - 1976
DDT In Sedlments and organlsms around Southern
cal1f ornla lAltf all s J. Water Po 11. Cont.
fed 14:'9'9-1928
20. MacGregron J. 5. - 1976
DDT and Its MetabolItes In the SedIments off Southern californIa
FIshery BulletIn 74(1): 27-35
21. Cern1qlla, CE et al. - 1980
OXIdatIon of Naphthelene by Cyanobacterla and Mlcroalqae.
J. Gen MIcrobIal 116: 495-500
22. Envlronnental ProtectIon Agency - 1983
Impacts of SectIon 301(h) Penut.
23. Anderson, D. W. et aI, - 1975
Brown PelIcan: Improved ReproductIon off the Southern CalIfornia
eoast ScIence 190: 806-808
24. Risebrough, R. W. - 1965
PestIcIdes and BIrd PopulatIons
(In Press) SubmItted to Current Ornlthology, 44 pages.
25. Natl.onal Park Setll lce - 1982
Channel Islands ~atIonal Park Blennlal Natural Resources Study Report
26. Anderson, D. W., F. Gress, and K. F. Mals - 1982
Brown PelIcans: Influence of food supply on reproductIon.
Glkos, 39:23-31
27. Gress, F. Personal CommunIcatIon
Department of WIldllfe and FlsherIes Blology
UnIverSIty of Callfornla DaVIS.
2B. Llncer, J. L. et al, - 1979
Workln9 Blbllography of the Bald Ea91e
29. Garcelon, D. Personal CommunIcatIon
PresIdent, Institute for Wlldl1fe Stu:1les. Avalon
_30. 5CCWRP - 1981-1982
B1ennlal Report
31. YOlJ"lg, D. R. and D. J. f-t::~rmott - 1975
Aenal Fallout of DOT
SCCWRP Annual Report
32. R~sebrough, R.W. - 1985
Pest~cldes and Bird Populat~ons
(In Press) SubmItted to Current OrnIthology 44 pp.
33. Gossett, R. W. et. al - 1981-1982
Levels of Trace Organic Compounds ~n Scortf Ish from Southern Cal1fornla
SCcWRP Blenmal Report
-35-
.
.
34. LA/(JIlA Project Pohcy Soard - 1980
Assessnent of Publ1c Health Concerns
ASSocIated wIth Trace OrganIcs In Seafood
Flnal EIS/FER, Sludge ~t. Program for the Los Angeles/Orange County
Metropohtan Area
35. EPA - 1980
Crlterla Standards OlvlsIon
~mblent Water Quallty CrIterIa for DOT
36. CarCInogen Assessment Group - 1985
The Carclnogen Asses9I1ent Group's
Evaluatlon of the CancInogemoIty of OJ.cofol
(Kethane), DOT, DOE, and DDD (TOE)
37. Puffer, H. W. M. J. Duds and S. P. Azen - 1982
Potentlal Health Hazards fran Consunptlon of FISh Caught
In polluted coastal waters of l~ County
North AmerIcan J of F~sher~es 2~74-79
38. McDermott, D. J. and M. J. Sherwood - 1975
DOT and PCBls In DIseased Dover/sole
SCCWRP BIennIal Report
39. Young, O. R., R. W. Gossett and T. C. Heesen
PerSIstence of ChlorInated Hydrocarbon
Contanlnatlon In a Callfornla Manne Ecosystem.
TM SerIes, 4Opp.
40. Puffer, H. W. and R. W. Gossett - 19B3
PCB, DOT and 8enzo (a) Pyrene In Raw and Pan-FrIed
WhIte Croaker (~enyonemus Llneatus)
Bull. Env. Contam. and TOXlcol 30: 65-73
~ r
.;r--
.
F"~9ure
1
2
3
4
5
6
7
B
9
.
References for Flgures
Reference
LARWQCB Flle ~o. 60-28, No. 61-81, and
No. 66-114
LARWQCS - 1975
Water QualIty Control Plan Report,
Los Angeles RIver BaSIn (4-B)
LARWQCB F~le No. 60-28, No. 61-81, and
No. 66 -114
LARWQCB Flle No. 60-28, No. 61-81, and
No. 66-114
Schafer, H. A. - 1984
Character1stlcs of MunlC1pal Wastewater
SCCWRP B1enmal Report, 1983-1984. pp 11-19
SCCWRP Blenn1al Report, 1979-1980
LARWQCB FIle No. 60-28
SCCWRP, 1973
Natlonal Park ServIce, 1982
Channel Island NatIonal Park
BJ.enn1al Natural ~esources Study Report
- -; 7_
.
.
APPENDICES
.
.
APPENDIX A
Federal leg~slatlon
Federal law has regulated ocean dumplng of wastes from vessels snce the
19th century (1). The RIver and Harbor Act of 1899 declared that It was
not lawful to dIspose refuse from float1ng crafts ~nto nav1gable water of
the Unlted States. However, the same Act prov~ded that the Secretary of
War, after the ChIef of Eng~neers determ~ned that anchorage and navIgat~on
would not be lnJured thereby, could perm1t the depos1t of such materlal 1n
naVIgable waters, W1th~n Ilm~ts and condltlons def~ned and prescr1bed by
hlm, provlded appllcatlon was made to hlffi prlor to the dIsposal (2). More
spec1flc language IS contaIned 1n the Rlver and Harbor Act of 1905, WhlCh
author~zed the Secretary of War to prescrlbe regulatlons to govern the
transportatlon and dumpIng Into navlgable waters of dredgIngs, earth,
garbage, and other refuse materIals whenever 1n hlS Judgment such regula-
t10ns are requIred In the Interest of navlgatlon (3). These two excerpts
Indlcate that the thrust of regulatIng ocean dumplng 1n the past was to
prevent any obstructIon or danger to naVIgatIon. In turn, the U.S. Corp of
EngIneers, (COE) seems to be the agency w1th regulatory authorIty to
control dumpIng of a broad class of materIals, relIed on these sectlons for
ocean dumpIng In the terrltorlal seas.*
In the 1950s and 19605, ocean waste dlsposal lncreased markedly. Sewage
sludge and lndustrlal wastes from sources In the northeast coastal area of
the U.S., where land dIsposal had proved expens1ve and Impractical,
composed much of these wastes. ThIS 1ncreased ocean dumplng led dIrectly
to the MarIne ProtectIon, Research, and Sanctuar1es Act of 1972 WhICh 15
commonly known as the Ocean DumpIng Act (1).
The Ocean DumpIng Act was slgned into law on October 23, 1972
(P.l. 92-532). It prohlblted the transportatIon and dumplng of materIal
(exceptIng dredged mater1al) Into ocean waters except as authorlzed by an
Envlronmental ProtectIon Agency (EPA) permIt. The Corps of EngIneers
regulated the dIsposal of dredged materlal.
An 1mportant defloltlOn In the Act was that "dumplng" does not Include
dIsposal from any outfall to the extent that such dlsposal 1S regulated
under the Federal Water PollutIon Control Act, SectIon 13 of the RIver and
Harbor Act of 1899 or the Atom1c Energy Act of 1954. "Sectlon 106 of the
Ocean DumpIng Act prOVIdes that after Its effectlve date, all lIcenses,
'permlts, and authorlzatlon5 other than those Issued pursuant to the Act are
to the extent that they authorIze any actIvity regulated by the Act, and
whether lssued before or after the effectIve date of the Act" (4). Under
the Ocean Dump1ng Act, EPA developed crIterIa to govern dump1ng permlts
and dumpIng Sltes. These crIterIa take Into account, among other matters,
the need for dumpIng, ava1labll1ty of alternatIve d1sposal methods and
effects 1n water qualIty. "In pnnc1ple, ocean dumplng IS not entnely
foreclosed by the Act, but only controlled" (4).
* For Dredged Materlal Perm~ts, 40 CFR, Parts 225-228 conta1n the
relevant InformatIon.
(Federal RegIster, Vol. 42, No.7, 1977)
.
.
The EPA publlshed the flnaI revrSlon of regulatlon and cI'rterra for ocean
dumplng, whlCh Implemented sect10ns of the Ocean DumpIng Act and the
rederal Water Pollutlon Control Act 10 the rederal Reg~ster, Vol. 42, No.~
1977 (3). These regulatlons provIde for several types of permlts: (6).
1. General - lifoI' the dumplng of certaIn materIals WhlCh wIll have a
mln1mal adverse env1ronmental Impact and are generally disposed of In
small quantItIes, or for speclflc classes of materlals that must be
dlsposed of In emergency sltuatlons."
2. SpecIal - fifoI' the dumplng of materIals WhICh satIsfy the crIterIa and
shall speCIfy an eXpIratIon date no later than three years from the
date of Issue".
3. Emergency - ror any of the materrals llsted ln Sectlan 227.6," (l.e.
organlC halogen compounds, mercury and mercury compounds, cadmIum and
cadmlum compounds, 011 of any klnd or 1n any form, and human or
suspected carCInogens, nutragens, or teratogens) "except as trace
contam1nants,...whICh poses an unacceptable rlsk relatlng to human
health and admIts of no other feasrble solutlon."
4. Interim - "Prlor to Apnl 23, 1978, Interrm perm1ts may be 1ssued 1n
accordance Wl th Subpart A 0 f Part 227. n
Research - lifoI' the dumplng of any materIals specIf1ed In Sectlon 227.5
or for any of the materIals llsted In Sectlon 227.6 except as trace
contam~nants, unless subject to the exclus10n of Sect~on 227.6(g), Into
the ocean as part of a research project when ~t has been determlned
that the SClentlflc merIt of the proposed project outwelghs the
potentlal envlronmental or other damage that may result from the
dumplng.lI
The Corps of Englneers lssue 1I0redged MaterIal Perm1ts" under Sectlon 103
of the Ocean Dumolng Act but EPA Reglonal Admlnlstrators have the
author~ty to reVIew, to approve, or to dlsapprove, or to propose condltlons
upon these PermIts for ocean dumplng of dredged materIal at locatIons
WIthin the respectlve Reg10nal JurIsdlctlons.
State Leg1slatIon
- The Water Pollubon Control Act (also know as the "Dickey" 4.ct) was added
to the Callfornla Water Code by Chapter 1549, Statutes of 1949 (8) and lt
prOVIded for the establlshment of the State Water PollutIon Control Board
and nlne RegIonal Water Pollutlon Control Boards.* SectIon 13022, auth-
orlzed the State 80ard to formulate a statewIde polley for the control of
..
The State Water PollutIon Control Board was later changed to the State
Water Qual1ty Control Board and flnally to the present State Water
Resouces Control Board. State Board WIll be used to represent all
three names.
..
The nIne Regional Water PollutIon Control Bords were changed to the
present nlne RegIonal Water Quallty Control Boards
.
.
watet pollutIon. Undet Sectlon 13052 :he teg~onal boards were dIrected to
formulate and adopt long-range plans and pollcles w~th respect to water
pollut1on, to request enforcement of laws concern~ng water pollut~on or
nu~sance by approprlate federal, state and local agenCIes, and to prescrIbe
requIrements relatlve to any partlcular condItion of pollutIon or nu~sance,
eX1sting Ot threatened, ~n the reglon.
The Act also requlred that any person propos~ng to discharge sewage or
1ndustr~al waste wIthln any reglon, other than lnto a commun~ty sewer, flle
w~th the approprIate regIonal board a report of such proposed d~scharge.
The Reg~onal Board, after any necessary hearIng, prescr1be requlre-
ments as to the nature of such dlscharge (7).
ThIS new leglslat~on dId not 11mlt the power of local agencles to deal w1th
d~sposal of sewage or ~ndustrial waste or to abate nuisances; therefore,
cooperat1on and coord1nat1on wlth local agenC1es hav~ng ordlances
controlllng water pollut1on had to be obtaIned. In the Los Angeles Reg~on,
cop~es of the reports of waste dIscharge receIved were forwarded to other
state and local agenCIes that m~ght have an Interest In the proposed waste
d~scharge (8).
In accordance w~th prov~sions of SectIons 13000 and 13052(a) of the
Cal~forn1a Water Code, the lARWQC8 adopted Resolut1on No. 54-3, "AdoptIng
Long Range Waste DIsposal and Water QualIty ObJect1ves for Los Angeles
County and Ventura County Coastal Waters of the PacIf1c Ocean w~thln the
Boundaries of the Los Angeles regIon, excludIng Wate~s of Harbors, R~vers,
and TIdal Estuar1es", 1n 1954. ThIS ResolutIon recognIzed that one of the
then present uses of the coastal watets was for the dIsposal of sewage and
~ndustrIal wastes, as well as a supply of process waters to certaln
1ndustr~es and that lithe total Interests" of the RegIonal Board "encompass
both ecnom1cal waste dIsposal and preservatIon of the benefICIal uses of
the waters of the State. The obJect~ves applIcable to ocean dump~ng
conta~ned In thIS Resolut1on 54-3 prohlb~ted dIscharged wastes to:
1) cause the appearance of grease, OIl or o~ly SllCks, obJect~on-
able color, or of vis~ble SOllds of waste orIgin in the receiv-
Ing waters!
z) cause odors In the receIVIng waters or along adjacent beaches
or shores such that they may constItute a nu~sance,
3) cause concentratIons of tOXIC materIals in the receIVIng waters
WhIch would be detrImental to human, anlmal, fISh, plant, or
b1rd l~fe, and,
4) cause the format~on of sludge banks or depos~ts on the ocean
floor or along adjacent shores or beaches to the extent that
they would slgnIflcantly Interfere WIth development of marIne
Ilfe Dr cause nUlsance due to odors or unsightllness.
.
.
LARWQCB
The obJectlves In Resolutlon 54-3 were Intended to prevent lmpalrment of
the quallty of coastal waters for beneflclal uses, whlle reservlng a
reasonable amount of the capaclty of these waters for sewage and lndustrlal
waste dlsposal. The ObjectIves outllned ln the Resolutlon do not In
themselves constltute the Boards requests as to any speclflc waste dISpO-
sal, the reqUIrements may be more severe, and under certain condit loons ",ay
be less restr1ctlve than the obJectIves would seem to lndicate (9).
In Resolut1on 55-16, adopted In 1955, Los Angeles RegIonal Water Quallty
Control Board adopted a "General Polley wlth Regard to the Appl1caUon of
the Board's Resoluhon No. 54-3 In Los Angeles County.1f ResolutlOn 55-16
11sted eXlstlng and proposed recognIzed recreatlonal beaches and coastal
waters In Los Angeles County that are open to the publIC year round,
therefore, the Resolutlon resolved that the quallty of the coastal waters
adJacent to the eXlstlng recognlzed beaches 11sted shall at all t1mes
comply wlth the Coastal Water QualIty ObJectlves contaIned ln the Board's
Resolutlon No. 54-3.
Resolutlon 57-62, adopted by Los Angeles Reglonal Water Quality Control
Board ln 1957, correspondingly adopted the same general POllCY as
Resolution 55-16 WIth regard to the coastal waters In Ventura County.
In accordance wlth the provlslons of the Federal Water Quallty Act of 1965
(PL 89-234) and Sectlon 13052(e) of the Callfornla Water Code, by
Resolutl.on 67-5, In 1967 establlshed the "Water Quallty Control Pollcy for
Paclflc Ocean Coastal Waters, Rlncon POInt to San Gabrlel RIver", as
standards of water auallty for the coastal waters. The Los Angeles
Reglonal Water Quallty Control Board held 2 publlC hearIngs on the POllCY
prIor to ItS adoptlon for the purpose of determlnlng the nature, extent and
locat~ons of beneflclal uses of the coastal waters and the approprlate
levels of water qualIty lndlcators necessary to protect the beneflClal
uses.
The Water Quallty Control POllCY descrlbed the boundarIes of State Waters
(Coastal Waters) as those waters between the mean hlgh tldellne and three
~autlcal mIles (5.5 km) offshore of the outermost channel lslands. Today,
State waters extend three nautIcal ffil1es (5.5 km) from the mean hlgh
tLdellne and three mIles around each channel lsland. The dlscusslan an
"Present ComplIance" stated that all dlrect dIscharges of wastes lnto the
Paclflc Ocean Coastal Waters wlthln thls RegIon were conformIng to waste
'dIscharge reqUIrements and were not creatlng any known water quallty
problems and that every known dIrect dIscharge of wastes Into the Coastal
Waters of the PaClflC Ocean-wIthln Los Angeles Reglonal Water Quallty
Control Board's JUfIsdlct10n were under requlrements prescrlbed by the Board.
Startlng In 1970, the State Implemented major reVIsions to lts POlICY on
water quallty control parallelIng the major reV1SIon brought about by the
creatlon of EPA, and the adoptlon of the Federal Water Pollutlon Control
Act and the Ocean Dumplng Act. The Porter-Cologne Water Quallty Control
Act completely reVIsed Water Quallty provIslons of the Californla Water
Code In 1969. Important pOInts of the new law speclfled (12):
1. The State Board as the state water pollutIon control agency for
all purposes stated In the Federal Water Pollutlon Control Act and
any other federal act.
.
.
2. State Board shall formulate and adopt State POllCY for water
Quallty control WhICh shall Include water qualIty control
plans adopted by the State Board far Interstate or coastal
waters of Inter-reg~onal or statewIde interest.
3. Any person dIscharging waste or proposIng to dIscharge waste
WIthIn any reglon that could affect the quality of the waters of
the state, other than Into a communIty sewer system, and any
entlty of thIS state dIschargIng waste or propOSIng to dIscharge
waste outSide the boundarles of the state In a manner that could
affect the quality of the waters of the state WIthIn any reglon,
shall fIle WIth the reglonal board of that regIon a report of the
dIscharge.
The State Board In March of 1971, approved a report on the "DIsposal of
Wastes Transported by Vessels to the TIdal Waters of Callfornlall (13). The
report recognIzed that "1ndustr1es, munlClpalltles, federal agenCIes, and
mllltarIes of the U.S. dIspose of wastes by dumpIng them from vessels Into
the open ocean and Into speCIfIed areas of bays and estuarIes. In 1971,
there were 71 actlve disposal SItes along the Pac1flc Coast operatIng under
permIts Issued by the U.S. Corps of Engineers. Of these, 42 sltes were
located In the federal offshore waters of CalIfornIa. The largest
category of wastes was dredge spOIls (80%) the majorIty of WhICh were are
derIved from actlvltles of the Corps of EngIneers. The second largest
category was Industrlal waste dumped at SItes 5-75 mIles (8-121 km) off the
PaCIfic Coast. The report recommended that the State Board and the
affected reglonal board's be gUIded In use of theIr respect~ve authorItIes
and responslbllltles by a POlICY WhICh essentIally vlewed ocean dumplng as
an InterIm means of dIsposal to be termInated 1n the future (14).
In 1972 the State Board adapted ResolutIon No. 72-45, a "Water QualIty
Control Plan for Ocean Waters of CalIfornIa" (the Ocean Plan)-to further
legIslatIve POlICY set forth In SectIon 13000 of DIVISIon 7 of the
CallfornIa Wate~ Code. The Ocean Plan WhICh IS applIcable to pOInt and
non-polnt sources but not to vessel wastes or the control of dredge
spoll, promulgated water qualIty ObjectIves and effluent quallty requlre-
ments to govern the dlsposal of waste Into the coastal waters of
CalIfornIa. The Plan contaIned dISCUSSIons of benef1clal uses and water
qualIty obJectlves for ocean waters effluent qualIty reqUIrements for waste
dIscharges, and d~scharge prohlbltlons. RegIonal boards were gIven the
optIon to establIsh more restrlct1ve water qualIty obJectlves and effluent
"quallty reqUIrements than those set forth In the Plan.
The Ocean Plan reVIsed In 1978 (15) and agaIn In 1983 (16) to reflect new
Informatlon In the benefICIal uses, water quallty obJectIves, effluent
qualIty requlrements, dIscharge prohlblt1ons and general provlslons. The
Los Angeles RegIonal Water QualIty Control Board has adopted the Ocean Plan
as part of the regIonal water qualIty control plans (17) for the Los
Angeles Basln and Santa Clara BaSln.
.
.
BegInnIng of Permlt
As contaIned In 40 eFR Parts 221-222, 1977 the present procedures (6) for
proceSSIng an ocean dumpIng permIt IS as follows:
1. The applIcant submIts a permIt applIcatIon to EPA In the form of a
letter conta1nIng pertInent Informatlon such as names of applIcant,
person or fIrm transportIng the materIal to be dumped, the producer or
processor of the materIal; Informatlon on the conveyance to be used for
transportIng the materIal; adequate phYSIcal and chemIcal descrIptIon
of the materIal; the number, sIZet and phYSIcal configuratlon of any
contaIners to be dumped; quantIty of materIal to be dumped; proposed
dates and tImes of dIsposal; proposed dump SIte; proposed method of
releaSIng the materIal at the dump SIte and means of controllIng the
dIsposal rate; descrIptlon of past dIsposal methods of the materlal an
evaluatlon of short and long term alternatIve means of dIsposal,
treatment or recycle of the materIal WIth an analYSIS of the avaIla-
bIlIty and envlronmental Impact of such alternatIves; and an assessment
of the antlclpated envIronmental Impact of the proposed dumpIng on the
marIne enVIronment, navlgatlon, lIVIng and non-lIVIng marlne resource
explOItatIon, SCIentIfIC study, recreatIon and other uses of the
ocean (6).
2. EPA reVIews the permIt appl1catlo~ for completeness and accuracy and
requests further InformatIon as necessary WIthIn 30 days of recelpt
of the Inltlal applIcatIon.
3. WIthIn 30 days after rece1pt of a completed appl1cat1on, the EPA
RegIonal AdmInIstrator shall publlSh notIce of such appllcat10n
1ncludlng a tentatlve determInatIon wlth respect to the Issuance or
denIal of the permIt. A tentatIve determInatIon of Issuance Includes
(a) proposed tIme IlmItatlon
(b) proposed rate of dIscharge from the vessel
(c) proposed dumpIng SIte
(d) a brIef descrIptIon of any other proposed condItIons approprlate
for Incluslon In the permIt (6).
The notIce also Includes a summary of the InformatIon Included In
the appllcatlons, a brIef descrIptIon of the procedures for
requestlng a publIC hear1ng, and a brIef statement of the factors
conSIdered In reachIng the tentatIve determInatlon wlth respect
to the permIt.
. 4. EPA
( a)
(b)
(c)
(d)
( e)
(f)
sends caples of the notIce to varIOUS persons Includlng:
Any person, or group of Federal, State or local agency upon
request. These requests may be standby requests for coples of
such notIces submltted in wrltlng to EPA;
The state water pollution control agency;
The offIce of the approprlate DIstrIct Englneer of the U.S.
Army Corps of EngIneers.
The approprIate dlstrlct offIce of the U.S. eoast Guard for
reVIew and pOSSIble suggestIon of addltlonal condItions In the
permlt to faCIlItate surveIllance and enforcement;
The agency exercls1ng admInIstratIve Jurlsdlctlon over the
flSh and w1ldllfe resources of the states;
The Food and Drug Admlnlstratlon, ShellfIsh SanItatIon Sranch
.
.
5. W~thln 30 days of the date of publlcatlon of the not~ce, any person
may request a publ1C hearIng to consIder the Issuance or den~al of, or
the condlt~ons to be ~mposed upon, such permlt.
6. After such a request, the Reg10nal Admln~strator determlnes whether a
publIC hear~ng ~s necessary or approprIate. The date shall be no less
than 30 days aFter rece~pt of the request or after a determ~nat~on by
the Reg~onal Adm~nIstrator to hold such a hearIng without a request.
7. At the publlC hear~ng, the Presldlng Officer WIll be the RegIonal
AdmInIstrator or h~s deSIgnee and the hearIng wl!l be informal and
allow the oresentatlon of publIC comments.
8. W~thln 30 days follOWIng adjournment of the publIC hearIng, the
Pres1dlng Officer WIll prepare and forward to the RegIonal
AdmInIstrator wrltten recommendatlons relatIng to the insurance or
denIal of or condIt1ons to be Imposed upon, the proposed permIt.
9. WIthIn 30 days follOWIng the recelpt of the PreSIdIng OffIcer's
recommendatIons or where no hearIng has been held, follOWIng the close
of the 3D-day perIod for requestIng a hearIng, the RegIonal
AdmInlstrator shall make a determInatIon WIth respect to the Issuance,
denIal, or ImpOSItIon of condItIons on any ocean dumpIng permlt
applIed for.
10. EPA WIll glve not~ce to the appllcant and all Interested agenCIes and
persons. Ten days after notIce of the determInatlon, any person may
request an adjudIcatory hearIng. Please see SectIon 222.9-222.12 for
detaIls of the procedures for requestlng an adJudlcatory hearIng and
the appeal procedure follOWIng the adjudIcatory hearIng.
.
.
REFERENeES APPENDIX A
1. Kr~et, James, E. 1983
Ocean Dlscharge of Mun~clpal Waters: Legal and Instltutlonal
Aspects: ~n Ocean DIsposal of Munlclpal Wastewater: Impacts
on the Coastal EnVltOnment, Volume 2, Chapter 11
Myers E. P., E. T. Hardlng, Eds.
2. War Department, OffIce of Chlef of EngIneers 1938
R1ver and Harbor Act of 1899, SectIon 13
3. War Department, Off1ce of Ch~ef of Engineers 1938
Rlver and Harbor Act of 1905, SectIon 4
4. Cal1fornIa State Water Resources Control Board 1972
MInI Memo No. 673 from Galtn M. CraIg, Chief
Counsel to 8111 B. Dendy, Execut1ve OffIcer
5. Un~ted States Department of the InterIor 1979
Bureau of Land Management Flnal Envlronmenta!
Statement for the Proposed 1979 Outer ContInen-
tal shelf O~l and Gas Lease Sale Offshore
Southern callfornla, pp. 374-375.
6. EnvIronmental ProtectIon Agency 1977
40 Code of Federal RegIster Volume 42, Parts
220-224
7. Env~ronmental ProtectIon Agency 1973
Letter from RIchard L. O'Connell, DIrector of EPA
Enforcement Dlvlslon to Bll1 B. Dendy, ExecutIve
Offlce~ of State Water Resource Control Board.
8. CalIfornia State Water PollutIon Control Board 1957
CallfornlB Water Code, D~v~slon 7
Water Pollut~on Control Act
9. CallfornlB Reg~onal Water Pollutlon Control Board No.4 1950
Progress Report an Water Pollutlon Control Program
In the Los Angeles RegIon
10. Callfornla RegIonal Water PollutIon Control Board No.4 1954
Resolutlon rlJo. 54-3, "AdoptIng Long Range Waste DIsposal
and Water QualIty ObjectIves far Los Angeles County and
Ventura County Coastal Waters of the Pac~flc Ocean wlthln
the boundarIes of the Los Angeles RegIon, Excluding Waters
of Harbor 5, RLVers, and TIdal Estuar les" .
11. Callfornla Los Angeles RegIonal Water Quallty Control Board 1967
"ResolutlOn No. 67-5, "Adoptlng Water QualIty Control Polley
for Paclflc Ocean Coastal Waters, RIncon P01nt to San GabrIel
Rlver."
12. CalIforn~a State Water Resources Control Board
Californla Water Code, Divls10n 7
The Porter-Cologne Water Quallty Control Act
1970
.
.
13. Callfornla State Water Resources Control Board
Report on "Dlsposal of Wastes Transported by Vessels
to the Tldal Waters of Callfornla".
1971
14. CalIfornIa State Water Resources Control Board
Water Quallty Control Plan - Ocean Waters of Callfornla
1972
15. eallforn18 State Water Resources eontrol Board
Water Quallty Control Plan - Ocean Waters of Callfornla
1978
16. Callfornla State Water Resources Control Board
Water Quallty Control Plan - Ocean Waters of Callfornla
1983
17. Callfornla Los Angeles Reglonal Water Quallty Control
Board
Water QualIty Control Plans for Santa Clara Basln (4A)
and Los Angeles Basln (4B)
1975
1978
.
.
APPENDIX 8: SELECTED CORRESPONDENCE
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--, ~ ""'~ -,,,.. 'I.- .:.. ., ... 10." ... - .. _ 4 of .. ~-- "- -........_ T r t. ,..v::."....;I I ~ _~~...
:":"-,o"S:.,~1 ... r l'i.r'" ......,. -:"......,!'.. -.... ...'t-..~ ........ -_ .J-(.J;..i~:.."""""''' -, ..;.....~rj I'od....--t,.-...Lt-"'__ A\J"-!.."~--t':i~4 L."":....--.c-.J--:::.1.....'
.... J.: t- h' 011-\ -~.;-'~.- .. -... l't ' ~.:I_ - '\.,. ~ ....-~'l. ~- .} .........._.... .... "'1;.: j___ ........J. .. '.._ ~T -;..:-...~_"':"li... .... \::...
. I';;: " 01' 0 !J' 1 n l .' -' J ,,-. ,~- , a ,. .
. ~ .~ _ ' ~} '.< 'h ~ cean lJ/t. r~~ ~~lLV~. ~,4JOCla~ion,.....ntc~ .~.:,~.l,....:~... _
- ~\i" ~ ~::' A,~lloJ",. u.,u; Cr. ".r'Ii. !;'" '.',j, F,Ja;:';~,.. IN '\\i '0 ~, .
-... ..;:;::"'- ~s"- -.. --- - L'" .. --',~ __ ~.........J -_I .....:,.......
~/ ~ P 0 sox seSl -: CRE:NSl-iAW ~STATiOi-.j -;w' .::-
LOS ANGEL~S e. CALlFO=i:-tJA
~~..,~ /j.:.-{ \~. .~'> ='. - ~.~.~':~yJ.~tl/~~~~~{,.-'; ~il~~Xl>;,:~::~~~r~2 .
.~. . -- ~~ -". .. . - .. ... - '1, ~. t" -,.' T...... l ~_ ] . _ ~...... _. _..~ ~ ~.,... ~ . ~....
,oF - .\I~tI:.... - "\ !. _ -...., _' j'''f \..~'.. '-J- I .D" ._..... 't_.... -..':" ~ .'" _ ;:,... Y".'
'\7.-">.~ '11~ 4'~"'1':'-">'~" -~'. .-..~--..f\(t..Tl"g<<o!=:l..:r~~'~'.::.':..Oi::6"/.,:;?,.:..;i-!;:,~"':: .7"!,:;'-'~'~ d>
' ',' -. G/:):. f ! ,-/1' ,t- :'~-," "'.:. _<'.",' - d-'.', ~ .~.~ -i",-:'~ ~_~._"-~_~':. _ "~_~: _:~ '.? .'_':"',:::."_ ., .~)
r ~;J$i 'L,.J/("',' ~~ - . " '. ~ .'r,'~'-- - ......,. ',' ;>""" ...!-.~ <"" ...1 OrT 18 ., '1=
.. ..('#~~"m-...'J~-.. -.... -..... .... -,rt ....' 1..- L~}.__.(" ....:~';..?....i.~.J::'.....:.::. -r.:._,,;-__:'-i.~.F~.c.... ;-!4':"!-:"'_~_... is.-.~,
.,._l).~~ - '_ ,S...s.te 0..;. Cal..!.forn'la-- ':-,",';..""-f.'-,"",-: -~'.":-~.-.,Lr~-:-_-!'-- '~\'>~__'~:-"" :;11,=--"
-11, '. - -._---c~.. ~:~ (, :~, ~- Regioria1"~\'ia~e~~~P611ut1-6ir:cont~o\'~BOard~No.C!.{:~;; ~,~,;,f.~~:;~~~ _ .. :'~,'
" - ~ \ .: ~Oo- :;OL 'S~""'~';"-;:-~^~c-~~e ~ll''''~~'''''''' ", .'-~-:H"""-' .'~ . ~ _.
~ ... I . ~ .. -....... -, ]::-'-............c ~ ':::'I...i. -./ -J..:..,;~.J.......5 '": ...\--~- ...._-'...~...CS .H~~~
'. " . I 1 f c:;,.c.. 1 S S.... . S..... ' , " . - - "...... - A:--: _ t......A
JI. __ !1 I ~ ... 11,..I'___ .- .P..i.J.~.2 w. ~-t- -__~ - .~-..... -... _. ........:....:..."':,_ ~
II . ; J 'r T ^ 1 ::-7'C 1~.&1 '.1' .r ~ . , #... - .... .. ""
.", . -. ' i i ;: i .......os r.....'1se es .L, a ~fOr:l.-':.e. ."'"".... .' _. .J. " _.. -. _
~~ ....~""'" ..~" 1 ij ! i"~ _..L:..,.._ . I .'_
r~~r~~;1 ~egard~r.s you~ req~~re~ents (dated 10/5/61) which- m1~t
-~, r_ be folloi"..ed bv .cFl..i:....,-.......,~.C>...B~l'<7.!>:c:e.....!::("'\I"I.,.,P1"1,v and -PaCific -
~I. ~-, ~ "-.......~ , ' . OC ee.:1. D~ sp;:: sal Co. lJ1 ~1.:.!llPln;; their - ext~emely noxicu~ ,
i - - "-:. .- industrial wastes (not includin~ any rad:.o-active mater-
- I ':! ,-. ':La 1 s ) in the Pac i fie 0 c ean. -; ~;..,..'~. .~. :i:."_-'.- '.=- " :,;:.".-......:'.. '..' '.. _-~'.~,: ~' i
. : .' I . - . ;,1; o. . : ~~" Sir s: ....::..:' .:..:.~ ~ ',I:,\~- /:' ',":::~ ,',;~ ~~::~:~.:: '\:. .
~ll .~~ -"..~lt,!':o 2. _I.- The OCSS-"1 !"ish ~:'otect.ive.~.A~soc.ii~ion/;.as-:i ~gerieral
\.~ 'D::-i!':c~ '.:le. doe s ~o t .1'5CO 2::1iz e t~at ~ one o~ t:-:.e'_ bene:ic is..l ,'_
~ - \.\*.~ ,. ;'::e:: o~ t:ne wa't8:'s o~<t~:Pacific o'cean is's.'-place_to
? ~l '~ ...r ~
~ ~ c-..:.=.p w,? stes. -. ,
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r _,_ . r
: -, ::t;';: '::~'t' .; - \ 1
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... ....'h.~ "~....", t...., Oce":" ''''~~sl-r-'tl'';;otec'''~''''e '"^<:<: c1a"'~o"'"
r...'.... ......:....-- l..I_oaJ__ ..-'-' c;.....'" _.. _ _..... L.._1I ..t::.__O Lr_..l
"0"" o.....,~er"'+ ....0 "'L..,",o r"'~"i""e""G"""'s (c'p"'or 11"';/-::"/::,;) ......~~c....
.... lJ -~ ww ""' ..-- -~......-- .......~....... _.........._ _v '-"f'-'- "__,,:,,,....;.
yo~ p~c?ose to issue the &~'7e t~o co~pan~e5. We w~ll
~e~e~ve t~e rig~ts to at a~y ti~e in tbe ~ut~~e, tc st=e~-
uO~51y re;~est c~~~ges i~ tLe requi~e=en:s;
I <-') ~-:-... _..~ - ~!...r..
:5. ~f So -: a:1:r f1: tu:'e ti=::.e there;1 s Tcu.,c. ar.";j'" 0 ther-- meens
'c'" di._<:_r.'"'_ "'_2.'_ .of ~1-,~5'" we-ite';;- .;:-.......,"'. O. ",-'-p ! - -~~ i 1.;';" s ~ s'.... - ~
- -- t.l__ - - - _ .., , 1.1...._ ~ ..... _ . _... r~ _ _ . _-6.. ..... ,-,,~..._
t.::at t~e3e v,astes not.be d1.U!lDed~in.the Pacific'ocean. ~,~ ._.
.' ; 'c' ,,' .l:::~. : ,.}: . ~\:' '.t'~'}~~~~;rf~~;~~,:~~::;;:~~Yi:~~.;f~X{5~~~'; ~ .
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c:' 1 S 1951
~
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.
.
/
STATE OF CALJFORNIA-RESOURC~S AGENCY
RONALD R~AGAN O""~"'''r
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD-
LOS ANGELES REGION
,~
~~"'Q~"':
'~~5"'i
'~.
107 SOUTH BltOADWA'(. sUIre 9026
105 ....NGElES. CALIfORNIA 90012
April 25, 1973
.
Environ~uta1 Protectio? Agency
Region IX .
100 California Street
San Francisco, California 94U1
A'l'TmTION: Hr. Frank M. Covington, Director
Air and Water Program Division
Su.bject: Regulations tor Ocean Dumping (A I a 5 z 6)
Gentlemen:
Tbts is 1.0 response to your letter of March 28, 1973, enelosing for our review
and comment a draft copy of interi~ regulations for oeean dumping.
We believe that fish wstea, as referenced in Paragraph 22Q.l(b), should be Illore
thorQ"ehJy defined. ~ill this term inclu~e, for example (and we believe it should),
fish parts tri-!IlJ!I8d away and throw overbciud from part,. fiRhil!g boats?
There are t'olO ocean dumping firms operating in this ~egion. Both are regulated by
wete di8"hlllt"ge requirements adopted by this Board. These requirements prohJ.bi t
dumping ei tber directly into waters of the state or ..here ....aters ot the state Clay
be affected.
One of the fi.rms, H-10 Vater Taxi. COIIIpany', collects wastes from vessels in Los
Angeles - Long Beach Harbor and disposes ot them offshore at a point several miles
east of Santa Catal.in.~ Island.. 'fbe reason for this discharge is because Federal
Regulations (lJ. S. Department of flgricu1ture) prohibit the removal of garbage from
any vessel tor dumping into any territorial waters or onto land except tor immediate
incineration, approved treatment or dieposU under the superrlsion of the State
ilepartment of Agriculture, or delivery to a garbage collector licensed by the State
Department of Agriculture or the federal government.. No approved arrangements of
these types are a.'ailable in the Los Angeles - Long Beach H-...bor, although the
NaV1 bas been cooking and land.filling i ta ve!'l~l garbage for several years. There
appears to be no reason lo'hJr onshore collection facilities could not be provided
by the firm, with disposal of the lI.astes a.t an approved land site. We therefore
recommend that an)" permit tor this operation be iS8Ued only as a temporary permit
and the diechA!"ge be terminated as soon as possible when land dispoeal facilities
are available.
~,
..
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, ~ Environmental Protection Agency
.
~
-2-
A11ril 25, 1973
The second firm is CilifonUa Salvage CompaD1. It receives pnncipal1l chemical
\/&StaB end barges them out to the ~~. general area aa 'H-10 ".ter Taxi Company
for dumping.
The State ot CAl Hornia recentl,. adopted. verr stringent Water Qu~U t1 Control
Pl-!! for Ocean Waters ot California. This Plan will require a progr8lZl of close
aource control OD. trace elements and other cansti tu.enta in di8C"ha1"'ges to municipal
_wrage Sj'stems 1IIhich discharge to tlae ocean. 'l'hi. will result in greater q~A_!!t1-
ties ot these materials being traneported trom the point of origin at the industryt
tor example, to the dispo~'_ Bite.
U the present method of ocean dumping by California Salvage CODlp8n)" iB allowed
to continue, a eie"'~ ficlmt portion of the materials removed in ~e source control
p!"OgralD would undoubtlfdl;y find its way to the ocean for ultimate dispo~l. '!his
vould be a ahort-circuit or the Ocean Plan.
We therefore feel that f"hi e type ot discharge must be prohibited al60 and request
that this be done at the earliest possible time.
'1'h-;l_'l'!.~ you for the opportur.; ty to comment on this matter.
Very truly yours,
RAYMOlm M. HERTEL
Executive Officer
cc: State \iater Resources Cont:-ol Board.
Executive Officers, Boards 1, 2, 3. 8, 9