=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #277
—March 18, 1992—
News and resources for environmental justice.
——
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
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AS THE TRUE COST OF INCINERATION
COMES INTO FOCUS, A NEW UNPLEASANT SURPRISE
It is important to stop incinerating our wastes not only because
incinerators contaminate local air, but also because they are
destroying the productivity of the oceans and other large
water-bodies such as Chesapeake Bay, Puget Sound, and the Great
Lakes.
You might think the oceans are so large that puny humans could
not contaminate them to any significant extent. But you would be
wrong.
The uppermost surface of the ocean forms a peculiarly important
and, until recently, poorly understood, ecosystem. Scientists
refer to it as the “sea-surface microlayer.” The sea-surface
microlayer is the top 50 micrometers of the ocean–a layer half
the thickness of the period at the end of this sentence, yet
critically important to life in the oceans or, for that matter,
in any large body of water such as the Great Lakes, the Gulf of
Mexico, Puget Sound, or Chesapeake Bay. The microlayer is
composed of bacteria, yeasts, and molds in concentrations as much
as 10,000 times greater than in the water below. Microscopic
plants and animals also concentrate in the microlayer, creating
an invisible organic film on the surface of the water, rich in
lipids (fats and oils) and fatty acids.
The sea-surface microlayer is a highly productive habitat for a
broad array of living things.[2] Numerous species of fish,
including cod, sole, menhaden, hake, anchovy, mullet, flying
fish, greeling, saury, rockfish, bluefish, mackerel, halibut and
many others have surface-dwelling egg or larval stages. In
estuarine, coastal, and shelf areas, blue crab, Dungeness crab,
and lobster larvae also concentrate in the surface film during
mid-day, drawn there by the abundance of sunlight. Because of
its importance as a nursery for fish eggs and larvae, the
microlayer has great economic value.
In a Georgia salt marsh, 21-43% of the total productivity is
concentrated in the upper 0.55 mm. Average productivity (measured
by oxygen consumption) was 3000 times greater in the microlayer
than in the water below.[1]
Unfortunately, the sea-surface microlayer is specially vulnerable
to pollution. Contaminants that settle out from the air (such as
emissions from incinerators, or from combustion of gasoline or
coal) tend to accumulate in the microlayer. So do contaminants
deposited on the land, many of which eventually wash into rivers
and then the oceans.
Toxins in the microlayer typically occur at concentrations 100 to
10,000 times higher than in the water below.[1]
Contaminants that have low solubility in water or that attach to
floatable particles (chlorinated hydrocarbons, pesticides and
metals) concentrate in the microlayer. Concentrations of these
contaminants hundreds or even thousands of times greater than EPA
water quality standards have been measured in the sea-surface
microlayer of Puget Sound, Chesapeake Bay and elsewhere.[2]
Contaminants build up in the microlayer. Combustion byproducts
called polycyclic aromatic hydrocarbons (PAHs) in the Lake
Michigan microlayer range from 0.15 to 0.45 ppb [parts per
billion], a million-fold enrichment compared to the air above.[1]
The surface film of Biscayne Bay, Florida, contained 2670 times
higher concentration of DDT compared to the water below.[1] In a
San Francisco salt march, lead was measured at a concentration 6
to 14 times higher than in the water below[1] and in Narragansett
Bay lead was 5 times more concentrated in the surface microlayer
than in the water below.[1]
Atmospheric deposition (fallout) accounts for around 50% of the
PAHs and metals entering some coastal waters.[3] As airborne
particles settle onto the surface of a water body, they become
solubilized and are rapidly introduced into the food chain via
the high concentration of microorganisms found in the microlayer.
Fish eggs are sensitive to environmental toxicants. So are
embryos and larvae, which are deformed or killed by hydrocarbons,
metals, and pesticides.[2] In the ocean, most fish eggs, because
of their high content of lipids (fat or oil), float on the
surface in direct contact with the microlayer.[2] Careful
measurements in Puget Sound have shown that the hatching success
of larvae decreases with increasing concentration of PAHs and
heavy metals in the microlayer. Significant contamination of the
microlayer is considered to be any concentration greater than 1
ppb PAHs and greater than 50 ppb metals. By this criterion, in
Chesapeake Bay, 30% of samples of the microlayer were highly
contaminated.[2]
The killing power of contaminants in the microlayer is
exemplified by benzo(a)pyrene, or BaP, one of the PAHs. BaP is a
strong carcinogen created by the combustion of coal, gasoline,
and many wastes, including municipal trash. Experiments have
shown that 0.3 ppb of benzo(a)pyrene causes 2 to 5 times more
misshapen trout larvae than normal. There was a 30% death rate
among sole embryos exposed to 0.1 ppb benzo(a)pyrene. Yet in
Puget Sound many samples from the sea-surface microlayer measured
3 to 123 ppb benzo(a)pyrene.[3]
Samples of the sea-surface microlayer from Los Angeles harbor
induced severe malformations in 100% of surviving larvae of kelp
bass.[2]
A contaminated microlayer can be carried by wind and surface
currents and deposit on beaches and along shallow coastlines
where it can contaminate shellfish and other species, such as
herring, that lay their eggs in such areas.[2]
U.S. Environmental Protection Agency water quality criteria for
PCBs is 30 parts per trillion (ppt). But sea-surface microlayer
concentrations of PCB in Puget Sound are up to 130 times higher
than EPA’s water quality criterion.[3]
In Puget Sound in 1985 PAHs, which are carcinogenic, mutagenic
and teratogenic occurred in the majority (57%) of sea-surface
microlayer samples. Pesticides were detected in 28% of the
sea-surface microlayer samples.[3]
In controlled tests, more than half the samples from the Puget
Sound microlayer caused a significant reduction in the normal
hatching success of fertilized sole eggs.[3]
There seems to be little doubt that incineration, the combustion
of petroleum products, and of coal, is greatly reducing the
productivity of near-shore regions of the world’s oceans.
Unfortunately, these near-shore regions are the most important
from the viewpoint of productivity.
The consequences of this contamination are real. At a fish store
in Washington, DC, flounder now sells for $10 per pound, red
snapper for $12 per pound. At these prices, only the wealthiest
among us can afford to eat fish regularly. Until recently, fish
was a free or low-cost source of protein.
Fortunately, a possible legal mechanism already exists to protect
the oceans from land-based incineration.
In the FEDERAL REGISTER Vol. 39 (October 17, 1974), pg. 37058,
EPA (U.S. Environmental Protection Agency) stated that “in any
case where it can reasonably be anticipated that incineration of
wastes at sea will result in any such material, or emissions from
the incineration of such material, entering ocean waters, such
incineration will require a permit under the Ocean Dumping Act
[the Marine Protection, Research and Sanctuaries Act, 33 U.S.C.
1401-1444].
In a court case, EPA argued that incineration on ocean-going
ships constituted ocean dumping because incinerator emissions
would enter the oceans. The case was Seaburn, Inc. vs. United
States Environmental Protection Agency, Civ. A. No. 88-637,
United States District Court, District of Columbia, April 20,
1989. Seaburn, a waste disposal company, had challenged EPA’s
decision to suspend its evaluation of the company’s application
for an ocean-incineration permit. The District Court held that
the Agency’s interpretation of the Ocean Dumping Ban Act, to
equate ocean incineration dumping with ocean dumping, was
reasonable. On pg. 7 of its motion for summary judgement the EPA
argued that “Ocean incineration is a process that converts some
of the liquid wastes into “residues” or emissions which are then
“dispersed into the atmosphere and generally deposited into the
ocean.” Thus, the EPA argued, ocean incineration is really a form
of ocean dumping.
The same logic leads to the conclusion that land-based
incineration anywhere within several hundred miles of an ocean
constitutes ocean dumping. U.S. policy on ocean dumping is firmly
established: it is banned. It is time to ban incineration too.
–Peter Montague, Ph.D.
Descriptor terms: water pollution; incineration; waste disposal
technologies; puget sound; chesapeake bay; los angeles harbor;
wildlife; ga; fish; pahs; heavy metals; water quality;