A few of my readers know that I’m a sailor. My husband and I have a 32 foot sailboat, which we keep it in a marina on the Chesapeake Bay. Every year the boat gets hauled out of the water for the winter. Before the boat went back in the water this year, we had the hull painted. Copper based paints are used on boat hulls to prevent the growth of critters and sprouts. I was curious about how copper paints prevent your hull from becoming a Noah’s ark of algae and barnacles, so I have been doing a little reading on the subject. There have been a number of copper based paint studies (also grandly called Anti Fouling Systems) conducted by the U. S. Environmental Protection Agency (EPA) and the California Environmental Protection Agency (Cal-EPA). According to the two environmental organizations, the most commonly used boat paints leach copper into the water and form a toxic protective shield around the boat hull to prevent the attachment of aquatic organisms. Copper is a toxin for many aquatic plants and animals. In fact it is a toxin for many terrestrial plants and animals. Copper is a widely used pesticide in the agricultural industry where it’s employed to eliminate bacteria, fungus, and weeds. After a few years, the leaching rate of copper from the paint on a boat hull decreases and the boat has to be painted once again. It costs a couple of thousand dollars every time, so this is not an incidental expense.
The most common form of copper in the antifouling paints is cuprous oxide. I didn’t realize how much copper is actually in the paint. Cuprous oxide paint is 30 to 60 percent copper. So a lot of copper is going into the water in marinas where recreational boats spend most of their time. The Navy actually did some studies in San Diego Bay back in the 1990s and found that 98 % of the copper in the bay came from antifouling paints on boats. They calculated that each boat in the bay was releasing 1.8 pounds of copper a year just while they were sitting at the dock in the marina. According to the Navy, most of the copper in the paint was released through the leaching process. A smaller amount of copper was released during underwater cleaning of boat hulls. California does seem to have the largest problem with copper in the waters of their marinas, so much so that a marina in California has been listed as an impaired water body under 303(d) of the Clean Water Act. Once a water body is listed as impaired under the Clean Water Act, a state must institute a Total Maximum Daily Load (TMDL) for it. A TMDL basically sets the maximum amount of a particular pollutant that a water body can receive and still meet water quality standards. As you can imagine, the designation of the marina as an impaired water body has now posed a serious problem for the marina’s boaters and California’s environmental regulators. Since hull paint is considered the main contributor of copper into the marina’s waters, the Cal-EPA has instituted a study of alternate antifouling systems – hull coatings without copper – in hopes of finding one which will be effective and economical enough to be used on recreational boats so that water quality there can be improved.
The water quality criteria established by the EPA for copper in marine waters and estuaries is really quite low. It has been revised multiple times over the last 20 years. The revisions have sought to produce a more scientifically justified approach for the development of the water quality criteria. The latest approach in setting the copper water quality criteria was issued in the July 2016 draft guidance: Aquatic Life Ambient Estuarine/Marine Water Quality Criteria for Copper, EPA-822-P-16-001. Scientists at EPA have known for many years that the toxicity of copper in water is dependent upon the water’s salinity (the amount of dissolved solids in the water), the temperature, the pH (the measure of acidity), and the amount of natural dissolved organic carbon. EPA scientists realized variations in these parameters influence the amount of dissolved copper in water. Dissolved copper is the culprit in the metal’s toxicity to aquatic organisms. Toxicity is reduced when copper in the aquatic environment binds with other elements and organic carbon to form ligands. Ligands are a little difficult to understand but simply put, they are complexes of molecules binding together to form a new substance. So for example, if there’s a lot of natural dissolved carbon in the water, it might bind with copper to form a ligand. Copper can also form complex ions with other ions and ligands in the water. Copper tied up in ligands and complex ions is not available to plants and critters, thereby making the water less toxic to them.
Interestingly copper has a similar binding behavior when it interacts with aquatic organisms. It binds to the biota’s gills and surface membranes. Although biota also ingests copper in the water, the scientists at EPA do not consider it a pathway for the toxin to negatively impact the organisms. It is the binding of copper to the gills and surface membranes of marine fish and invertebrates which is the major factor in coppers toxicity to them. EPA has a name for it. They call it the biotic ligand. Therefore to take into account the complexity of the world at large which is obviously not a simple system, EPA has developed a model called the “Biotic Ligand Model” to determine based on the specific temperature, pH, salinity, and amount of dissolved carbon what the aquatic criteria is for any particular marine or estuarine environment you might encounter. This makes it a little tough for state regulators because then they must sample the waters in question for these parameters and run a complex computer model to determine the specific water quality criteria for any given water body.
When setting water quality criteria, EPA usually bases it on the organism in the water which is most sensitive to a given pollutant. Arthropods are pretty sensitive to copper, after all the reason boaters use copper paint is to keep barnacles from attaching to their boat hulls. Although in the grand scheme of things I don’t think anybody is really worried about barnacles. Commercial species of mollusks like mussels, oysters and abalone are also extremely sensitive to copper. EPA was able to collect acute toxicity data on 89 different estuarine and marine fish and invertebrates. In simple terms acute toxicity means that biota aren’t going to live very long when exposed to an acutely toxic concentration of a pollutant. There were far less data available on chronic toxicity. Chronic toxicity happens when exposure to a pollutant results in conditions which are not immediately fatal to an organism, for example reproductive anomalies (we call these birth defects).
With EPA’s Biotic Ligand Model one can pop the temperature, pH, dissolved carbon and salinity values of your local marine/estuarine water into the model and come up with a numeric value for copper which should not be exceeded. So for example, if your water is 68 degrees Fahrenheit, the pH is 8, the dissolved carbon is 1.0 milligram per liter, and salinity is 32 parts per thousand than dissolved copper shouldn’t exceed 2.0 micrograms per liter on average more than once every 3 years, and the 4 day average shouldn’t exceed 1.3 micrograms of dissolved copper per liter more than once every 3 years. Complicated right?
These are extremely low values. The current acute value for copper is 3.1 micrograms per liter and the chronic is 4.8. The water quality criteria are of course guidelines. They are not regulatory in nature. They are there for state regulators to use in determining protection measures for aquatic life. As mentioned above, California has already designated a San Diego area marina as an impaired water body. Other places EPA has suggested might have copper levels impacting aquatic life are certain locations within the Chesapeake Bay and some port areas of Florida. As of yet, I know of no other marinas which have been designated as impaired waters. Alternatives to copper paint are fairly expensive and can potentially double the price for applying an antifouling coating to a boat hull. The American Coatings Association and the International Copper Association have already commented on EPA’s 2016 draft guidance. The organizations submitted a number of technical comments in regard to the Biotic Ligand Model and the conservative values produced by it. They are worried that the new proposed copper water quality criteria will result in unrealistically low TMDLs for other marinas.
