520776504
FINAL
ENVIRONMENTAL IMPACT STATEMENT
DESIGNATION OF A SITE IN THE GULF OF MEXICO
FOR INCINERATION OF CHEMICAL WASTES
JULY 1976
T!BRARY
3. £,*»VI80t»,«t!iTAL PROTECfMN
^'•-^ U. I 08817 f ' ' '?
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460 %•
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
FINAL
ENVIRONMENTAL IMPACT STATEMENT
DESIGNATION OF A SITE IN THE GULF OF MEXICO
FOR INCINERATION OF CHEMICAL WASTES
PREPARED BY: DIVISION OF OIL AND SPECIAL MATERIALS CONTROL
OFFICE OF WATER AND HAZARDOUS MATERIALS
WITH CONTRACTUAL ASSISTANCE FROM TEXAS
A Sc M UNIVERSITY (EPA-EIS-WA 76X-054)
APPROVED BY
DATE
^&"&
: (7
1976
:f
rBRARY
:?,lVI;10;,i;U:.IAL PROTECTION AfcttfiCY
.i N. i 08817 .
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11
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SUMMARY SHEET
( ) Draft (X) Final Environmental Impact Statement
Environmental Protection Agency
Oil and Special Materials Control Division
Office of Water and Hazardous Materials
1. Name of Action
(X) Administrative action
( ) Legislative action
2. The proposed action is the designation of a site in the Gulf of Mexico where
permissible incineration of chemical wastes can be performed aboard specially
designed or adapted incineration equipped vessel. The proposed site, occupying
approximately 4900 square kilometers in the Gulf of Mexico, lies 315 kilometers
SSE of Galveston, Texas and 350 kilometers SSW of Cameron, Louisiana. The
water depth at the site's center is approximately 1375 meters (4500 feet).
3. The designation of a site in the Gulf of Mexico for the incineration of
chemical wastes, the proposed action, will not of itself result in any direct
environmental impacts. The impacts that may occur would result from the per-
mitted use of the site for incineration. These potential secondary impacts
include the effects on air and water quality due to the products of incineration
and the risk of pollution through accidental spillage of unburned wastes due to
ship sinkage or grounding. No significant degradation of air or water quality
was noted during careful and extensive EPA monitoring of research burns of
organochlorine wastes conducted within the proposed site. Further, accidental
spillages are considered to have a low possibility of occurrence.
4. Alternatives considered:
A. No action - rejected because there is a need for an incineration site
in the Gulf of Mexico.
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B. Alternative site - rejected because the proposed site meets or
exceeds all of the criteria for site selection, thus no additional
safeguards to the environment could be gained by studying and
evaluating additional sites in the Gulf of Mexico.
5. Comments on the draft impact statement are requested from the following:
A. Federal Agencies
Mr. T.J. Sharpe, Chief
Environmental Impact Statement
Review Section
Environmental Protection Agency
Research Triangle Park, NC 27711
Mr. Peter Cook, Director
Policy & Procedures Staff
Office of Federal Activities
Environmental Protection Agency
401 M Street, §.'W.
Washington, D.lfj 20460
I \
Dr. William Arc;.., Director
Office of the Ejcjplogy &
Environment^11 Concerns
National Oceanil:;Atmospheric
Administrati^i:
Department of CAt'merce
Washington, D.C: 20230
Mr. Francis S. Kelly, Director
Office of Public Affairs
DAEN-PAP
Office of the Chief of Engineers
Department of the Army
100 Indiana Avenue, S.W.
Washington, D.C. 20314
Commander Thomas Mosher
Office of the Oceanographer
U.S. Navy
200 Stovall Street
Alexandria, VA 22332
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Federal Agencies (CONT'D)
Mr. Bruce Blanchard, Director
Environmental Project Review
Department of the Interior
Room 5311
Washington, D.C. 20240
Capt. Fred Schubert
U.S. Coast Guard
(GWEP 73)
Department of Transportation
Washington, D.C. 20590
Mr. John Nachtsheim
Assistant Administrator for
Operations
Maritime Administration
Department of Commerce
Washington, D.C. 20230
B. State Agencies
Mr. Richard Troy
.Office of the Attorney General
7th Floor
234 Loyola Avenue
New Orleans, LA 70114
Mr. Charles Harden, Executive Director
Texas Air Pollution Control Board
8520 Shoal Creek Boulevard
Austin, -TX 78758
Dr. Paul Templet
Box 23421
Louisiana State University
Baton Rouge, LA 70803
Mr. Joseph Mayhew
Texas Parks & Wildlife Department
John Reagan Building
Austin, TX 78701
Dr. Walter A. Quebedeaux
Harris County Pollution
Control Department
P.O. Box 6031
Pasadena, TX 77506
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State Agencies (CONT'D)
Mr. Peter P. Baljet, Executive Director
Department of Pollution Control
State of Florida
2562 Executive Center Circle
Tallahassee, FL 32301
Mr. Robert A. Lafleur, Executive Secretary-
Louisiana Stream Control Commission
Drawer FC
University Station
Baton Rouge, LA 70803
Mr. Bentley B. Mackay, Jr.
Executive Director, Governor's Council
on Environmental Quality
State of Louisiana
3101 37th Street
Metairie Building, Suite 201
New Orleans, LA 70001
Mr. Glen Wood, Jr.
Executive Director, Mississippi Air & Water
Pollution Control Commission
P.O. Box 827
Jackson, MS 39205
Mr. Hugh C. Yantis, Jr.
Executive Director, Texas Water
Quality Board
P.O. Box 13246
Capitol Station
Austin, TX 78711
Mr. John Malouf, Technical Advisor
Supreme Court Building
Attorr.'.-.y General's Office of Texas
At.^ci.i,' TX 78711
Mr. Patrick McCaffrey
Special Projects Coordinator
Department of Pollution Control
2562 Executive Center, Circle E
Montgomery Building
Tallahassee, FL 32301
VI
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State Agencies (CONT'D)
P. Maxwell, Asst. Attorney General
Office of Texas Attorney General
Supreme Court Building
Austin, TX 78711
H.T. Lee
Texas Coastal & Marine Council
P.O. Box 13407
Austin, TX 78711
Alabama Control Commission
Attention: David Morris
749 State Office Building
Montgomery, AL 36104
Eighth Coast Guard District
Maritime Environmental Protection Branch
Custom House
Hew Orleans, LA 70128
Area Supervisor
National Marine Fisheries
Service Water Reservoir Division
4700 Avenue U
Calves ton, TX 77550
Mr. James Coerver, Director
Bureau of Environmental Health
Louisiana State Department of Health
P.O. Box 60630
New Orleans, LA 70160
C. Citizens Groups
Mr. Brock Evans, Director Mr. Donald D. Carruth, President
Sierra Club The American Eagle Foundation
324 C Street, S.E. 3306 Winneth Road
Washington, D.C. 20003 Chevy Chase, MD 20015
Mr. Kenneth S. Kamlet, Counsel
National Wildlife Federation
1421 16th Street, N.W.
Washington, D.C. 20036
6. Draft environmental statement made available to the Council on Environmental
Quality and the Public on April 23, 1976. Final environmental statement madfe
available to the Council on Environmental Quality and the Public on L 14 1976
vii
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Comments on Draft EIS received from the following:
John Malouf
Special Environmental Assistant
Supreme Court Building
Attorney General's Office of Texas
Auston, TX. 78711
Kenneth S. Kamlet
Counsel, National Wildlife Federation
1421 16th Street, N.W.
Washington, D.C. 20036
Captain D. J. Riley
U.S. Coast Guard
(G-WEP-7/73)
Department of Transportation
Washington, D.C. 20590
Emory G. Long
Director, Administrative Operations
Texas Water Quality Board
P.O. Box 13246
Capitol Station
Austin, TX. 78711
Bill Stewart '
Deputy Director, Control and Prevention
Texas Air Control Board
8520 Shoal Creek Boulevard
Austin, TX. 78758
Col. Jon C. Vander Bosch
District Engineer, Galveston District
SWGED-E — Corps of Engineers
Department of the Army
P.O. Box 1229
Galveston, TX. 77553
R. E. Van Ingen
Manager - Manufacturing
Environmental Conservation
Shell Oil Company
One Shell Plaza
P.O. Box 2463
Houston, TX. 77001
viia
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Orey Tanner, Jr.
Administrator, Technical Assistance Unit
Air Quality Section
Louisiana Air Control Commission
Louisiana State Division of Health
P.O. Box 60630
New Orleans, 70160
Sidney Caller
Deputy Assistant Secretary for Environmental
Affairs
United States Department of Commerce
Washington, D.C. 20230
Stanley D. Doremus
Deputy Assistant Secretary of the Interior
United States Department of the Interior
ER 76/428
Washington, D.C. 20240
Mr. Charles Custard
Director, Office of Environmental Affairs
Department of Eealth, Education & Welfare
Room 524 F2, S. Portal Building
200 Independence Avenue, S.W.
Washington, D.C. 20201
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Preface
The site is being proposed for the at-sea incineration of various
types of chemical wastes. Permits for this incineration will be issued
only as research or interim permits until the promulgation of specific
at-sea incineration regulations and criteria. This restriction will not
apply if studies have already been conducted on the waste, the incinera-
tion method and vessel, and the site.
Research permits may be issued as part of research with respect to
the impact of materials on the marine environment when it is determined
that the scientific merit of the proposed project outweighs the potential
environmental or other damage that may result. Only research permits
would be issued to applicants fpr incineration of wastes other than
organochlorine wastes unless sufficient scientific and technical documen-
tation exists to establish its suitability for incineration at sea, and
impacts on the marine environment.
The designation of the site will be limited to a period of five years.
The decision to make this limitation is based on the information presented
in the EIS and on the comments received from the reviewers. In particular,
the need for further information on the long-term effects on the environment
as reflected in Section VI of the EIS and the comments from the National
Wildlife Federation, the Louisiana Air Control Commission, the Department of
Commerce, the Department of the Interior, and the Department of Health,
Education and Welfare. The five-year period was selected to allow sufficient
time to obtain additional data on this new technology, to coordinate with
the international community under the Ocean Dumping Convention, and to
further evaluate the potential long-term impacts of incineration at the site.
viii-
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TABLE OF CONTENTS
I. BACKGROUND AND DESCRIPTION OF PROPOSED ACTION 1
INTRODUCTION AND BACKGROUND 1
STATUTORY REQUIREMENTS 1
BRIEF HISTORY OF OCEAN DUMPING IN THE
VICINITY OF THE PROPOSED SITE 3
OCEAN INCINERATION IN THE VICINITY OF THE
PROPOSED SITE 4
RELATIONSHIP OF THE DESIGNATION OF AN
INCINERATION SITE TO OTHER FEDERAL PROGRAMS 5
Other Federal Programs for Designating or
Restricting Site Use 5
Activities and Waters Regulated 7
Permit Program 8
Criteria for Ocean Dumping 12
Surveillance and Intervention 13
DESCRIPTION OF PROPOSED ACTION 13
LOCATION OF PROPOSED INCINERATION SITE 13
SELECTION AND ASSESSMENT OF THE PROPOSED SITE 14
Original Site Selection for 1974-75
Incineration of Organochlorine Waste 14
Final Selection and Assessment of the
Proposed Incineration Site 17
SITE DESIGNATION PROCEDURES AND GENERAL CRITERIA. 18
• Si.te Designation Procedures 18
General Criteria for the Selection of Sites 18
Specific Criteria for Site Selection 19
Impact Categories 21
Modification in Disposal Site Use ' 23
II. ENVIRONMENTAL DESCRIPTION OF THE SITE 25
PHYSIOGRAPHY OF THE NORTHERN GUEF OF MEXICO 25
GEOLOGIC NATURE OF THE GULF 25
TOPOGRAPHY OF THE NORTHERN GULF SLOPE 25
SEDIMENTOLOGY BELOW THE PROPOSED INCINERATION SITE 26
METEOROLOGICAL ASPECTS OF THE PROPOSED INCINERATION SITE. ... 28
VISIBILITY 28
RELATIVE HUMIDITY 29
WINDS AND STORMS 29
PHYSICAL AND CHEMICAL PROPERTIES OF THE WATER 31
CURRENT PATTERNS 31
General 31
Current Patterns of the Proposed Site 32
WATER MASSES 34
SEA AND AIR -TEMPERATURE 34
(continued on next page)
IX.
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TABLE OF CONTENTS (continued)
SALINITY 35
DISSOLVED OXYGEN 36
ACIDITY AND ALKALINITY ' 36
WAVE HEIGHT AND DIRECTION 37
THE BIOLOGICAL COMPONENT 38
PELAGIC BIOTA OF THE PROPOSED INCINERATION SITE 38
Phytoplankton 39
Zooplankton. 40
Nekton 41
Neuston 41
BENTHIC BIOTA OF THE PROPOSED INCINERATION SITE 45
Zoobenthos 46
III. ALTERNATIVE TO PROPOSED DESIGNATION OF AN OCEAN
INCINERATION SITE 49
"NO ACTION" ALTERNATIVE 49
Definition of "No Action" Alternative 49
Rejection of "No Action" Alternative 49
DESIGNATION OF THE PROPOSED SITE 50
DESIGNATION OF AN ALTERNATE SITE 54
IV. ENVIRONMENTAL IMPACTS 55
DESIGNATION OF THE PROPOSED SITE •, . . . 55
USE OF THE PROPOSED SITE 55
PHYSICAL FACTOR IMPACTS 55
CHEMICAL FACTOR IMPACTS 57
PHYSICO-CHEMICAL ENVIRONMENTAL RESPONSE TO
INCINERATION PRODUCTS . . . • 59
Short-term Effects 59
Long-term Effects 63
THE SOCIO-ECONOMIC IMPACTS 66
V. PROBABLE ADVERSE ENVIRONMENTAL EFFECTS THAT CANNOT
BE AVOIDED • 71
ENVIRONMENTAL POLLUTION 71
From the Proposed Action . ! 71
From the Use of the Proposed Site 71
From Accidental Spillage 73
From Presence of Incinerator Vessel at the
Proposed Site 74
INTERFERENCE WITH OTHER ACTIVITIES AT THE PROPOSED
INCINERATION SITE 74
Shipping 74
Commercial Fishing 75
Sport Fishing and Other Recreational Activities 75
VI. RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF THE
ENVIRONMENT AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY ... 77
VII. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES 81
VIII. LITERATURE CITED IN TEXT AND IN APPENDICES A-F 83
IX. COMMENTS AND RESPONSES 97
(continued on next page)
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TABLE OF CONTENTS (continued)
Page
Appendix A: Physical Geology and Sedimentology of the Gulf of
Mexico Al
Appendix B: Gulf of Mexico Phytoplankton Species Distributions, Standing
Crop Distributions, Primary Production, and Seasonal
Cycles Bl
Appendix C: Zooplankton Species Enumeration, Geographic Distribution
and Standing Crop Biomass Cl
Appendix D: Nekton of the Gulf of Mexico Dl
Appendix E: Zoobenthos of the Gulf of Mexico El
Appendix F: Meteorological and Physico-Chemical Data Pertaining to
the Proposed Site Fl
Appendix G: U.S. Environmental Protection Agency, Disposal of
Organochlorine Wastes by Incineration at Sea under
Separate Cover
xi
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LIST OF TABLES
Page
II-l. Average monthly'sea surface and air temperatures. 35
II-2. Wave height by month for miniregion 341. 38
II-3. Relative abundance of neustonts from samples taken for pelagic
tar study. 43
II-4. Enumeration of organisms collected in neuston net tows from
northwest Gulf of Mexico. ' 44
IV-1. Results obtained from samples taken during ORCA Test Run II. 61
IV-2. Results obtained from samples taken during ORCA upwind Control
Run II.— 62
LIST OF FIGURES
Page
1-1. Permit procedures.—•—• --< < < U-,—. . •— 9
1-2. Location of 1974-75 incineration site.' ~4 15
1-3. Location- of the proposed site in relation1.to the 1974-75
incineration site.-' : |-» < 16
II-l. Bathymetric map of northwestern Gulf of Mejxico.- 27
II-2. Possible patterns of flow of surface waterk| in the western
part of the northern Gulf. v- 33
>
I '
xii
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I. BACKGROUND AND DESCRIPTION OF PROPOSED ACTION
•\
-INTRODUCTION AND BACKGROUND
Since 1973 when the Marine Protection, Research, and Sanctuaries Act of 1972 as
amended became effective, the Environmental Protection Agency (EPA) has been im-
plementing an ocean disposal permit program which provides that all ocean
disposal of waste materials transported for the purpose of dumping be done
under permit at sites designated by the EPA, except for dredged material
which is regulated by the Corps of Engineers. Since September 1974 the EPA
has interpreted that ocean incineration comes under the regulatory mandates
established by the Marine Protection, Research, and Sanctuaries Act of 1972,
as amended, and therefore requires an ocean dumping permit from the EPA and
involves the designation of sites. EPA believes that ocean incineration is
an emerging viable technological alternative, under carefully controlled con-
ditions, to the direct dumping of the material into the marine environment.
Ocean incineration is a waste burning process whereby chemical wastes are
taken aboard specially designed and equipped-vessels and transported to •
specified locations in the ocean. The onboard incinerators are fuel fired
to a predetermined temperature, the waste valves are opened, and waste is
fed into the incinerator. The nature of wastes being incinerated is such
that once they hit the pre-heated incinerator they ignite and continue to
burn.
STATUTORY REQUIREMENTS
EPA's ocean disposal permit program and its Ocean Dumping Regulations and
Criteria were authorized by the Marina Protection, Research, and Sanctuaries
Act of 1972, as amended (referred to in this statement as the MPRS Act).
This Act very specifically sets forth the policies of the United States in
regards to ocean dumping. The opening section is very explicit concerning
the policy and purpose of the Act:
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Section 2. (a) Unregulated dumping of material into ocean waters endangers
human health, welfare, and amenities, and the marine environment, ecological
systems, and economic potentialities.
(b) The Congress declares that it is the policy of the United States to
regulate the dumping of all types of materials into ocean waters and to pre-
vent or strictly limit the dumping into ocean waters of any material which
would adversely affect human health, welfare, or amenities, or the marine
environment, ecological systems, or economic potentialities.
To this end, it is the purpose of this Act to regulate the transportation
of material from the United States for dumping into ocean waters, and the
dumping of material, transported from outside the United States, if the
dumping occurs in ocean waters over which the United States has jurisdiction
or over which it may exercise control, under accepted principles of inter-
national law, in order to protect its territory or territorial sea.
Under Section 102(c) of the Act, the Administrator of the Environmental
Protection Agency is given the authority to designate recommended sites for
ocean disposal pursuant to addressing the guides set forth in Section 102(a)
of the Act.
In addition to the MPRS Act, certain EPA regulatory activities are subject to
the requirements of National Environmental Policy'Act of 1969. Section 102
(2)(c) of the National Environmental Policy Act of 1969 (P.L. 91-190, 42 U.S.C.
4321 et seg.) (hereinafter "NEPA") required that Federal agencies prepare
detailed environmental statements on proposals for legislation and other major
Federal actions significantly affecting the quality of the human environment.
The object of NEPA is to build into the agency decision making process an
appropriate and careful consideration of all environmental aspects of proposed
actions.
The Federal Courts of Appeals have h.•;!.•; uhaC the Environmental Protection Agency
(EPA) need not prepare an Environmental Impact Statement (EIS) on its environ-
mentally protective activities. Despite this judicial agreement that Section 102
(2)(c) of NEPA is not applicable to E?A;s environmental regulatory activities,
the Agency has been urged to prepare EIS'3. EPA believes that preparation of
EIS's will have beneficial effects for certain of its major regulatory actions.
Accordingly, EPA has decided that it will voluntarily prepare EIS's in connection
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with certain of its major regulatory actions. In accordance with this de-
cision the Agency published (FEDERAL REGISTER, Vol. 39, No. 89, May 7, 1974,
pg. 16186) a Statement of Policy which provided for the voluntary prepara-
tion of EIS's for certain specific regulatory actions which included among
others, the designation of sites for dumping under Section 102(c) of the
Marine Protection, Research, and Sanctuaries Act (33 U.S.C. 1401 et seg.).
This Agency issued a Notice (FEDERAL REGISTER, Vol. 39, No. 204, October 21,
1974, pg. 37419) defining procedures for the voluntary preparation of the
above Environmental Impact Statements. This EIS is prepared in accordance
with those procedures.
BRIEF HISTORY OF OCEAN DUMPING IN THE VICINITY OF THE PROPOSED SITE
In the 1950s various companies (see Hann et al., 1976) began to barge and
dump their industrial wastes in the Gulf of Mexico. Before the enactment of
the Marine Protection, Research and Sanctuaries Act -of 1972 (MPRSA), the
Corps of Engineers had jurisdiction over ocean dumping under the Refuse Act
of 1889. Under this latter Act, industry would first contact the appropriate
regional Corps Headquarters to obtain permission to dump their wastes. Based
mainly upon outside reviewers the Corps would assess the environmental impact
of the industrial waste and if the dumping did not appear to pose a threat
to man, a "letter of no objection" was issued to the applicant (Hann et al.,
1976). Under appropriate sections of the Rivers and Harbors Acts of 1905 and
1917, tins Corps was given the authority to establish disposal sites. However,
bei_aus/- cr the lack of jurisdiction, they could only suggest disposal sites
beyouri Lhe r.bree mile limit. In the area of this proposed site the Galveston
Corrs of Engineers suggested in their letters of no objection a site they referred
to as "Site 100", 110 miles south of Galveston in 100 fathoms or more. In
December of 1971, the Galveston District Engineer rescinded all "letters of
no objection" in his area because it appeared that disposal was not occurring
at the suggested disposal sites. There are no known records of how industries
disposed of their wastes between December, 1971 and the enactment of the MPRSA
or April 23, 1973 (Hann et al., 1976).
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During 1973, approximately 1,408,000 tons of industrial wastes were dumped
in the Gulf. Since 1973 (enactment of theMPRSA) the amount of industrial
wastes disposed of in the Gulf of Mexico has been reduced to approximately
123,700 tons per year. This decrease does not imply a reduction in industrial
output, but rather reflects EPA's firm policy on strictly regulating or elim-
inating ocean dumping through requiring the dumpers to thoroughly analyze their
materials and determine alternate methods of disposal.
OCEAN INCINERATION IN THE VICINITY OF THE PROPOSED SITE
In compliance with the EPA requirements, Shell Chemical Company, Deer Park,
Texas facility suspended conventional ocean dumping of org'anochlorine waste
when their permit, which expired in November, 1973, was not renewed. The
'search for environmentally acceptable methods of disposing of their waste
(accumulating at a rate of approximately 1,900 metric tons per month) led
Shell Chemical Company to at-sea incineration which was in use by European
industry and had been evaluated and endorsed by European regulatory bodies
and the scientific community. Shell approached Ocean Combustion Services,
B.V. (DCS) of the Netherlands about the possible use of the incineration ves-
sel M/T VULCANUS which had incinerated similar wastes in the North Sea for
companies in The Netherlands, Great Britain and Scandinavia. Anticipating
operating the M/T VUL'CANUS in the United States, OCS requested, through an
American representative, an opinion from the EPA as to whether the Marine
Protection, Research, and Sanctuaries Act applied to ocean incineration. On
January 23, 1974 a decision was rendered by the EPA that ocean incineration
was not subject to ocean dumping regulations. Pursuant to this decision
Shell contracted with OCS for the services of the incineration vessel M/T
VULCANUS. In response to questions raised by the National Wildlife Federa-
tion and the Committee on Merchant Marine and Fisheries of the House of
Representatives, and in view of certain new information that came to its
attention, the EPA modified its earlier interpretation and concluded that
ocean incineration was subject to ocean dumping regulations.
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On October 4, 1974 a public hearing was held in response to Shell Chemical
Company's application for a permit to incinerate organochlorine waste in the
Gulf of Mexico. As a result of the hearing Shell Chemical Company was granted
a research permit authorizing at-sea incineration of 4,200 metric tons (one
ship load) of organochlorine wastes subject to specific conditions and moni-
toring activities. Incineration and monitoring activities resulting from the
above permit were carried out at the proposed site on October 20-28, 1974.
The results obtained from the monitoring activities conducted by the EPA and
Shell Chemical Company at the proposed site showed ocean incineration to be
an environmentally acceptable and viable means of ocean disposal of these
organochlorine wastes. Appendix G further discusses the chronology and the
results of the research incineration as well as that of the additional three
ship loads (12,600 metric tons) which were incinerated by January 7, 1975.
RELATIONSHIP OF THE DESIGNATION OF AN INCINERATION SITE TO OTHER FEDERAL
PROGRAMS
OTHER FEDERAL PROGRAMS FOR DESIGNATING OR RESTRICTING SITE USE
The following Acts provide the authority for other Federal agencies to designate
or restrict the use to which sites in ocean waters are put:
A. Marine Protection, Research, and Sanctuaries Act of 1972 (P.L. 92-532),
as amended (P.L. 93-254).
1. Title I - Ocean Dumping
Corps of Engineers Permits - Sec. 103(b)
"In making the determination required by subsection (a), the Secretary
(of the Army) shall apply those criteria, established pursuant to section
102(a), relating to the effects of the dumping. Based upon an evaulation
of the potential effect of a permit denial on navigation, economic and
industrial development, and foreign and domestic commerce of the United
States, the Secretary shall make an independent determination as to the
need for the dumping. The Secretary shall also make an independent de-
termination as to other possible methods of disposal and as to appropriate
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locations for the dumping. In considering appropriate locations, he shall
to the extent feasible, utilize the recommended sites designated by the
Administrator pursuant to section 102(c)."
2. Title III - Marine Sanctuaries
"Section 302. (a) The Secretary (of Commerce), after consultation with the
Secretaries of State, Defense, the Interior, and Transportation, the Admin-
istrator (of EPA), and the heads of other interested Federal agencies, and
with the approval of the President, may designate as marine sanctuaries those
areas of the ocean waters, as far seaward as the outer edge of the Continental
Shelf, as defined in the Convention of the Continental Shelf (15 U.S.T. 74;
TLAS 5578), of other coastal waters where the tide ebbs and flows, or of the
Great Lakes and their connecting waters, which he determines necessary for
the purpose of preserving or restoring such areas for their conservation,
recreational, ecological, or esthetic values. The consultation shall include
an opportunity to review and comment on a specific proposed designation."
B. Deepwater Port Act of 1974 (P.L. 93-627)
"(d)(l) Subject to recognized principles of international law and after
consultation with the Secretary of tfhe Interior, the Secretary of Commerce,
the Secretary of State, and the Secretary of Defense, the Secretary (of
Transportation) shall designate a zoie of appropriate size around and in-
cluding any deepwater port for the ^rpose of navigational safety. In
such zone, no installations, struct^es, or uses will be permitted that
are incompatible with the operation "of the deepwater port. The Secretary
shall by regulation define permitted iactivities within such zone. The
Secretary shall, not later than 30 c ?|ys after publication of notice pur-
suant to section 5(c) of this Act, designate such safety zone with respect
to any proposed deepwater port. »
(2) In addition to any other regulations, the Secretary is authorized, in
accordance with this subsection, to sv?tablish a safety zone Co be effective
during the period of construction of ,; deepwater port and to issue rules
and regulations relating thereto." '
C. Outer Continental Shelf Lands Act
Sec. 5. Administration of leasing of the Outer Continental Shelf.
"(a)(l) The Secretary (of the Interior) shall administer the provisions of
this Act relating to the leasing of the Outer Continental Shelf, and shall
prescribe such rules and regulations as may be necessary to carry out such
provisions. The Secretary may at any time prescribe and amend such rules
and regulations as he determines to be necessary and proper in order to pro-
vide for the prevention of waste and conservation of the natural resources
of the Outer Continental Shelf, and the protection of correlative rights
therein, and, notwithstanding any other provisions herein, such rules and
regulations shall apply to all operations conducted under a lease issued
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or maintained under the provisions of this Act. In the enforcement of
conservation laws, rules, and regulations the Secretary is authorized
to cooperate with the cqnservation agencies of the adjacent States."
At this time the EPA knows of no proposals by other Federal agencies which
would conflict with or restrict .the use of the proposed incineration site in
the Gulf of Mexico.
The Environmental Protection Agency's program for the issuance of permits
pursuant to Section 102 of the MPRS Act, as amended, is another Federal pro-
gram which has a relationship to the site designation. The EPA permit pro-
gram regulates the dumping of materials at the site in accordance with the
MPRS Act -which is consistent with the provisions of the 1972 Convention On
the Prevention of Marine Pollution by Dumping of Wastes and Other Matter.
The goal of this program is to preserve the quality of ocean water. The
procedure used to achieve this goal is to regulate the type and amount of
materials which are intentionally discharged into the ocean. To control
ocean dumping all dumpers are required to obtain a permit before they trans-
port their materials to sea for dumping.
ACTIVITIES AND WATERS REGULATED
The MPRS Act requires Federal permits (1) for the transportation of almost
all materials for the purpose of dumping in the waters of the territorial zone,
the contiguous zone or ocean waters beyond; and (2) for the disposal of mater-
ial in the territorial sea or contiguous zone of the U.S. if the material is
transported by any person from a location outside the U.S. However, the
MPRS Act does not regulate the disposal of (1) "sewage from vessels" as re-
gulated by section 312 of the Federal Water Pollution Control Act, as amended,
(P.L. 92-500); "oil" within the meaning of section 311 (P.L. 92-500) unless
the oil is taken on board a vessel or aircraft for the purpose of dumping;
(3) "fish wastes" under certain conditions as defined by section 102
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(P.L. 92-500); or (4) the disposal of wastes from outfalls or a fixed structure
or artificial island which will be regulated under P.L. 92-500 or some other
Federal legislation.
PERMIT PROGRAM
All intentional ocean disposal (as opposed to discharges through point sources)
is subject to the permit requirements of the MPRS Act. Only those disposal
activities which meet environmentally protective criteria or which are a part
of an implementation schedule leading toward compliance with such criteria
or total phaseout of disposal will be permitted.
Permits are issued by EPA except permits for dredged or fill materials, where
the responsibility lies with the Corps of Engineers. All permits, including
those of the Corps of Engineers, are evaluated by criteria established by
EPA. EPA is proposing revisions to the final ocean dumping regulations and
criteria for the MPRS Act. References in this statement to sections of the
Ocean Dumping Regulations and Criteria refer to the revised -version being
proposed by EPA.
Permits for ocean dumping are granted according to the regulations promulgated
under the MPRS Act. This is a federally mandated program and state certifi-
cation is not required for transportation for dumping, or dumping by vessels
unless the State can demonstrate that dumping in the contiguous zone will
violate its water quality standards within the part of the territorial sea
under its jurisdiction. In addition, no permits will be issued which will
violate a State's water quality standards. EPA must give public notice and
allow opportunity, for public hearing before any permit is issued. For a
presentation of the procedures by the EPA Regional Offices in processing per-
mit applications see Figure 1-1.
There are five types of permits which can be issues by the EPA: general per-
mits, special permits, interim permits, emergency permits, and research permits,
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APPLICATION SUBMITTED
TO REGION
PRELIMINARY EVALUATION OF APPLICATION
PUBLIC NOTICE OF APPLICATION WITH TENTATIVE DECISION
I TENTATIVE DECISION TO ISSUE
i
[TENTATIVE DECISION TO DENY
REQUEST FOR HEARING
HEARING
FINAL EVALUATION OF APPLICATION
ISSUANCE OF PERMIT
DENIAL OF PERMIT
NOTIFICATION
OF COAST GUARD
SURVEILLANCE
MONITORING OF DUMP SITE
ENFORCEMENT ACTION
FIGURE 1-1. PERMIT PROCEDURES
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(a) General permits. General permits may be issued for the dumping of cer-
tain materials which will have a minimal adverse environmental impact
and are generally disposed of in small quantities, or for specific
classes of materials that must be disposed of in emergency situations.
General permits may be issued on application of an interested person
in accordance with the procedures of Part 221 or may be issued without
such application whenever the Administrator determines that issuance of
a general permit is necessary or appropriate.
(b) Special permits. Special permits may be issued for the dumping of
materials which satisfy the Criteria and shall specify an expiration
date no later than three years from the date of issue.
(c) Emergency permits. For any of the materials listed in Section 227.6,
except as trace contaminants, after consultation with the Department of
State with respect to the need to consult with parties to the Convention
on the Prevention of Mai'ine Pollution by Dumping of Wastes or Other Matter
that are likely to be affected by the dumping, emergency permits may be
issued to dump such materials where there is demonstrated to exist an
emergency requiring the dumping of such materials, which poses an un-
acceptable risk relating to human health and admits of no other feasible
solution. As used herein, "emergency" refers to situations requiring
action with a marked degree of urgency, but is not limited in its ap-
plication to circumstances requiring immediate action. Emergency permits
may be issued for other materials, except those prohibited by Section
227.5, without consultation with the Department of State when the Ad-
ministrator determines that there exists an emergency requiring the
dumping of such materials which poses an unacceptable risk to human health
and admits of no other feasible solution.
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(d) Interim permits. Prior to April 23, 1978, interim permits may be issued
under certain conditions in accordance with Subpart A of Part 227 to
dump materials which are not in compliance with the environmental
impact criteria of Subpart B of Part 227, or which are otherwise un-
acceptable for ocean dumping as determined in accordance with the .
criteria of Subparts D or E of Part 227 or for which an ocean disposal
site has not been designated on other than an interim basis pursuant
to Part 228 of this Subchapter H; provided, however, no permit may be
issued for the ocean dumping of any materials listed in Section 227.5,
or for any of the materials listed in Section 227.6, except as trace
contaminants; provided further that the compliance date of April 23,
1978, does not apply to:
(1) the dumping of wastes from sewage treatment works when the
Regional Administrator determines that the applicant has
exercised his best efforts to comply with all requirements
of a special permit; or
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(2) the dumping of any other wastes by existing dumpers when
the Regional Administrator determines that the dumper has
attempted in good faith to comply with the date of April 23,
1978, and has a treatment facility under construction on a
'? schedule adequate to permit phasing out of ocean dumping or
, <• compliance with the criteria of Subpart B by April 23, 1981,
at the latest.
•'<
r
No interim permit will be granted for the dumping of wastes from
a facility which has not previously dumped wastes in the ocean
(except when the facility is operated by a municipality now
dumping such wastes), from a new facility, or from the expansion
or modification of an existing facility, after the effective date,
of these regulations.
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No interim permit will be issued for the dumping of any material in the
ocean for which an interim permit had previously been issued unless the
4
applicant demonstrates that he has exercised his best efforts to comply
with all provisions of the previously issued permits.
(e) Research permits. Research permits may be issued for the dumping
of any materials, other than materials specified in Section 227.5
or for any of the materials listed in Section 227.6 except as trace
contaminants, unless subject to the exclusion of paragraph (e) of
Section 227.6, into the ocean as part of a research project when it
is determined that the scientific merit of the proposed project
outweighs the potential environmental or other damage that may
result from the dumping. Research permits shall specif}'- an .
expiration date no later than 18 months from the date of issue.
(f) Permits for incineration at sea. Permits for incineration of
wastes at sea will be issued only as research permits or as interim
permits until specific criteria to regulate this type of disposal
are promulgated, except in those cases where studies on the waste,
the incineration method and vessel, and the site have been conducted
and the site has been designated for incineration at sea in
accordance with the procedures of Section 228.4. In all other
respects the requirements of Parts 220-228 apply.
Evaluation of Other Disposal Methods. The Regional Admiriistrator, in
considering an application for a permit for at-sea incineration of
chemical wastes, must evaluate other feasible alternatives. These
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12a
include, but are not limited to:
(1) Land fill;
(2) Well injection;
(3) Land-based incineration;
(4) Spread of material over open ground;
(5) Recycling of material for reuse;
(6) Additional biological, chemical, or physical treatment
of intermediate or final waste streams
(7) Storage
The following list of references is provided for descriptions of these
treatment and disposal methods.
(1) Environmental Protection Agency, "Report to Congress:
Disposal of Hazardous Wastes" .Appendix D, 1974, SW-115
(2) Environmental Protection Agency, "Incineration in Hazardous
Waste Management," 1975, SW-141
(3) Environmental Protection Agency, "Promising Technologies
for Treatment of Hazardous Wastes" November 1974,
EPA-670/2-74-088.
CRITERIA FOR OCEAN DUMPING
Proposed final regulations and criteria for ocean disposal to be issued by
the EPA require consideration of a number of factors before a permit may be
given. These include: (1) the need for the disposal; (2) alternative
measures of disposal or recycling; (3) the feasibility -of disposal beyond
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12h
the continental shelf; and (4) the effect of the disposal on marine
ecosystems, fishery resources, economic, esthetic and recreational
values, and on other uses of the oceans, such as scientific research
or economic development of living resources.
Conditions in the permits specify the type and amount of material to be
disposed of, the location of the disposal and the time during which the
permit is valid. No permits will be issued for the dumping of radiological,
chemical or biological warfare agents or high level radiological wastes.
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SURVEILLANCE AND INTERVENTION
Surveillance and enforcement of permit conditions during actual dumping opera-
tions are being accomplished by the Coast Guard. All violations of permit
conditions and illegal disposal reported to EPA are subject to enforcement
through the assessment of civil penalties and, where necessary, criminal
proceedings.
The U.S. Coast Guard has the authority under the intervention on the High
Seas Act (P.L. 93-248) to take whatever measures necessary to prevent, miti-
gate, or eliminate the danger to the marine environment from oil pollution or
the threat of oil pollution resulting from a marine casualty on the high seas.
The P.L. 93-248 implements the International Convention Relating to Intervention
on the High Seas in Cases of Oil Pollution Casualties, 1969. There is a bill
before Congress to amend P.L. 93-248 to implement the Protocol Relating to
Intervention on the High Seas in Cases of Marine Pollution by Substances Other
than Oil, 1973. The amended Act will provide the authority for the U.S. Coast
Guard to intervene in the case of a marine casualty which creates a grave and
imminent danger from pollution of oil and other substances to the coastline or
related interests of the U.S. Thus, the Coast Guard will be able to take ap-
propriate action to protect the marine environment from pollution resulting
from marine casualties involving an ocean incineration vessel proceeding to or
navigating within the proposed ocean incineration site.
DESCRIPTION OF PROPOSED ACTION
The proposed action is to designate a site where permissible incineration
activities can be performed in the Gulf of Mexico aboard a specially designed
vessel.
LOCATION OF PROPOSED INCINERATION SITE
The location of the proposed incineration site is centered 355 km ENE of the
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14
Texas-Mexico border, 315 km SSE of Galveston, Texas and 350 km S of Cameron,
Louisiana; it being positioned in a parallelogram with corners at 27°06'12"N-
93°24'15"W, 26032'24"N-93015'30"W, 26019'00"N-93°56'00"W, and 26°52'40"N-
94°04'40"W. This is essentially the same site as that within which organo-
chlorine wastes were incinerated during late 1974 and early 1975 (Fig. 1-2).
The minor alterations to the site may be viewed in Fig. 1-3, but thereafter
the proposed incineration site will appear as a rectangle on succeeding fig-
ures in this statement.
The proposed site occupies an area of approximately 4900 square kilometers.
Water depths within this perimeter range from near 600 fm (1100 m) to more
than 1000 fm (1835 m) and the seafloor gradient for this portion of the outer
continental slope is somewhat uniform and gradual (1:105) (see Fig. II-l).
The site is seaward of Gealy's "hummocky zone" in an area of relatively low
-*
relief where the surface is cut by steep-sided troughs that extend down-slope
(Gealy, 1955). Alaminos Canyon (Bouma, et al., 1972) and Ida'Greene Canyon
(Watkins et al., 1975), probable extreme components of the trough zone, flank
the area of the proposed site on'the west and the east, respectively.
SELECTION AND ASSESSMENT OF THE PROPOSED SITE
ORIGINAL SITE SELECTION FOR 1974-75 INCINERATION OF ORGANOCHLORINE WASTE
The general location of the incineration site was originally formulated prior
to, but was finalized based on the October 4, 1974 public hearing held in
Houston, Texas, pursuant to Shell Chemical Company's Permit Application Num-
ber 730D008c for at-sea incineration of organochlorine wastes. The EPA,
Shell Chemical Company, and other interested parties submitted testimony as
to the acceptability of the site's location based upon available published
and unpublished data. The original criteria used for selecting the test in-
cineration site's general location were: (1) the incineration site must be
outside all present disposal sites in order that detailed biological and
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15
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16
94°20'
94°00'
I
93°40
I
93°20'
I
93°00'W
•27°20'l
PROPOSED SITE
L_
-27°00'
-26°40'
-26°20'
1974-1975 INCINERATION SITE
•26°00'
Fig. 1-3. Location of the proposed site in relation to
the 1974-75 incineration site.
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17
chemical monitoring can be performed, (2) situated far enough offshore so as
to minimize the possibility of incineration products reaching land, (3) located
within an area acceptable to the Coast Guard and Corps of Engineers, (4) re-
moved from areas of commercial or recreational activity or biological signi-
ficance, and (5) possess favorable oceanographic and meteorological features
that will facilitate dispersal of the incineration products (EPA, 1974b;
EPA, Permit No. 730D008c(3), 1974; Pequegnat, 1974).
FINAL SELECTION AND ASSESSMENT OF THE PROPOSED INCINERATION SITE
When the need for a designated site for ocean incineration developed in this
area of the Gulf of Mexico, the test incineration site was evaluated using
the proposed revisions to the Ocean Dumping Criteria, which are listed later
in this section. The proposed incineration site meets or exceeds each of the
criteria. The assessment of the proposed incineration site in relation to the
criteria is addressed in Chapter III - Alternatives to Designation of an Ocean
Incineration Site.
The specific location of the proposed incineration site is essentially the same
as "the one used in the 1974-75 research burns. The proposed site is simply
reorientated to coincide with the LORAN-C time delay line grid (the LORAN-C
time delay numbers which are represented by the four coordinates previously
listed will be published by the Coast Guard at a later date following verifi-
cation) . This orientation will eliminate the navigational calculations neces-
sarv wi^h Cue original geographical grid system. The four time delay numbers
vi?.l -represent the boundaries of the site, thus giving greater assurance that
the ship will remain within the boundaries and facilitating more accurate sur-
veillanca with a higher degree of confidence. An additional benefit which
will be realized by the reorientation will be the simplification in design
of the. electronic equipment for the Ocean Dumping Surveillance System (ODSS)
being evaluated by the Coast Guard. This simplification will result in a
less costly system and, more importantly, one of increased reliability.
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SITE DESIGNATION PROCEDURES AND GENERAL CRITERIA
The following sections outline the site designation procedures and provide
a detailed list of General Criteria for the Selection of Sites.
SITE DESIGNATION PROCEDURES
Section 228.4 of the proposed revisions to the Ocean Dumping Regulations
and Criteria specifies for the first time, procedures used when ocean dumping
sites are designated. 228.4(d) specifically applies to sites used for material
being disposed of under either special or interim permit conditions. Such
designations will be made based on environmental studies of each site, regions
adjacent to the site, and on historical knowledge of the impact of waste dis-
posal on areas similar to such sites in physical, chemical, and biological
characteristics. All studies for the evaluation and potential selection of
dumping sites will be conducted in accordance with the requirements of Sections
228.5 and 228.'6.
«
GENERAL CRITERIA FOR THE SELECTION OF SITES
The dumping of materials into the ocean will be permitted only at sites or in
areas selected to minimize the interference of disposal activities with other
activities in the marine environment, particularly avoiding areas of existing
fisheries or shellfisheries, and regions of heavy commercial or recreational
navigation.
Locations and boundaries of disposal sites will be so chosen that temporary
perturbations in water quality or other environmental conditions caused by
disposal operations affecting mixing zones anywhere within the site can be
expected to be reduced to normal ambient seawater levels or to undetectable
contaminant concentrations or effects before rea'ching any beach, shoreline,
marine sanctuary, or known geographically limited fishery or shellfishery.
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If at anytime during or after disposal site evaluation studies, it is deter-
mined that existing disposal sites presently approved on an interim basis for
ocean dumping do not meet the criteria for site selection set fort.h in Sections
228.5-228.6, the use of such sites will be terminated as soon as suitable al-
ternate disposal sites can be designated.
The sizes of ocean disposal sites will be limited in order to localize for
identification and control any immediate adverse impacts and permit the im-
plementation of effective monitoring and surveillance programs to prevent ad-
verse long-range impacts. The size, configuration, and location of any dis-
posal site will be determined as a part of the disposal site evaluation or
designation study.
EPA will, wherever feasible, designate ocean dumping sites beyond the edge of
the continental shelf.
SPECIFIC CRITERIA FOR SITE SELECTION
') '*
i ,
"II ' •
(a) In the sel^ztion of disposal sites, in addition to other necessary or
appropriat^ |f actors determined by the Administrator, the following fac-
tors will -ft considered:
(1) Geographical position, depth of water, bottom topography and
v '
dist nee from coast;
V
i
(2) Location in relation to breeding, spawning, nursery, feeding,
or passage areas of living resources in adult or juvenile phases;
(3) Location in relation to beaches and other amenity areas;
(4) Types and quantities of wastes proposed to be disposed of, and
proposed methods of release, including methods of packing the
waste, if any;
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(5) Feasibility of surveillance and monitoring;
1
(6) Dispersal, horizontal transport and vertical mixing characteristics
of the area,.including prevailing current direction and velocity,
•if any;
(7) Existence and effects of current and previous discharges and
dumping in the area (including cumulative effects);
(8) Interference with shipping, fishing, recreation, mineral extraction,
desalination, fish and shellfish culture, areas of special scien-
tific importance and other legitimate uses of the ocean;
(9) The existing water quality and ecology of the site as determined by
available data or by trend assessment or baseline surveys as des-
cribed in the Guidelines for Ocean Disposal Site Baseline and
Trend Assessment Surveys;
(10) Potentiality for the development or recruitment of nuisance species
in the disposal site;
(11) Existence at or near the site of any significant natural or
cultural features of historical importance.
(b) The results of a disposal site evaluation and/or designation study based
on the criteria stated in paragraphs (1) - (11) will be presented in
support of the site designation promulgation as an environmental assess-
ment of the impact of the use of the site for disposal, and will be used
in the preparation of an environmental impact statement for each site
where such a statement is required by the National Environmental Policy
Act or EPA policy. By publication of a notice, an environmental impact
statement, in draft form, will be made available for public comment
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not later than the time of publication of the site designation as pro-
posed rulemaking, and a final EIS will be made available at the time of
final rulemaking.
IMPACT CATEGORIES
In addition, the proposed ocean dumping regulations and criteria define two
impact categories which will be used by EPA to determine whether a designated
site can be used on a continuing basis. When the results of monitoring in-
dicate that the impacts of incineration fall into Impact Category I then sub-
sequent use of the designated site must be modified or terminated. The im-
pact categories and the regulatory interpretation of the criteria for evalu-
ating the need to modify site use are as follows:
(a) Impact Category I; The effects of activities at the disposal site
shall be categorized in Impact Category I when one or more of the
following conditions is present:
(1) There is identifiable progressive movement or accumulation,
in dectectable concentrations above aormal ambient values,
of any waste or waste constituent from the disposal site
within 12 nautical miles of any shoreline, marine sanctuary
designated under Title III of the Act, or critical area
designated under Section 102(c) of the Act; or
(2) The biota, sediments, or water column of the disposal site, or
of any area outside the disposal site where any waste or waste
constituent from the disposal site is present in detectable
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concentrations above normal ambient values, are adversely
affected to the extent that there are statistically significant
decreases in the populations of valuable commercial or recrea-
tional species, or of specific species of biota essential to
the propagation of such species, within the disposal site and
such other area as compared to populations of the same organisms
in comparable locations outside such site and area; or
(3) Solid waste material disposed of at the site has accumulated
at the site or in areas adjacent to it, to such an extent that
major uses of the site or of adjacent areas are significantly
impaired and the Federal or State agency responsible for
regulating such uses certifies that such significant impair-
ment has occurred and states in its certificate the basis for
its determination of such impairment; or
(4) There are adverse effects on the taste or odor of valuable
commercial or recreational species as a result of disposal
activities; or
(5) When any toxic waste, toxic waste constituent, or toxic
byproduct of waste interaction, is identified in toxic concen-
trations above normal ambient values outside the disposal site
more than four hours after disposal.
(b) Impact Category II; The effects of activities at the disposal site
which are not categorized in Impact Category I shall be categorized
in Impact Category II.
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MODIFICATION IN DISPOSAL SITE USE
(a) Modifications in disposal site use which involve the withdrawal of
designated disposal sites from use or permanent changes in the total
specified quantities or types of wastes permitted to be discharged to a
specific disposal site will be made through promulgation of an amend-
ment to the disposal site designation set forth in this Part 228 and
will be based on the results of the analyses of impact described in
Section 228.10 or upon changed circumstances concerning use of the site.
(b) Modifications in disposal site use promulgated pursuant to paragraph
(a) of this Section 228.11 shall not automatically modify conditions
of any outstanding permit issued pursuant to this Subchapter H, and
provided further that unless the EPA management authority for such site
modifies, revokes or suspends such permit or any of the terms or condi-
tions of such permit in accordance with the provisions of Section 223.2
based on the results of impact analyses as described in Section 228.10
or upon changed circumstances concerning use of the site, such permit
will remain in force until its expiration date.
(c) The EPA management authority shall use the following criteria in evaluating
the need to modify, revoke or suspend any outstanding permit with respect
to disposal site use and in recommending permanent changes in disposal
site use to the Administrator:
(1) Impact Category I; Reduce disposal volumes or concentrations at the
site to levels which will allow the environment to recover.
(2) Impact Category II: Maintain or increase existing rates of disposal
if necessary or appropriate.
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(d) The determination of the Administrator as to whether to terminate or
limit use of a disposal site will be based on the impact of disposal
at the site itself and on the Criteria.
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II. ENVIRONMENTAL DESCRIPTION OF THE SITE
PHYSIOGRAPHY OF THE NORTHERN GULF OF MEXICO
GEOLOGIC NATURE OF THE GULF
The Gulf of Mexico is a semi-enclosed sea with an approximate surface area
of over 1,600,000 square kilometers and a maximum depth of about 3,840 meters.
Most of the oceanic input is from the Caribbean Sea via the Yucatan Strait
(160 km wide and 1650-1900 meters deep) with outflow being primarily through
the Florida Straits (less than 160 km wide and only around 800 meters deep).
The facts that both of these connections with the parent Atlantic are confined
to the southeastern sector and that runoff from approximately two-thirds of
the United States and more than half of Mexico also empties into the basin
contribute greatly to the characteristics of the Gulf in general and the
western Gulf in particular. Those vastly different influences are used as a
basis for dividing the Gulf into two major provinces: a carbonate province
to the east and a terrigenous one, containing the proposed site, to the west
(Uchupi, 1967). These provinces are delineated by De Soto Canyon in the
northeast quadrant and by Campeche Canyon off the Yucatan Peninsula in the
southwestern region (Antoine and Bryant, 1968). Significant characteristics
of this basin are the great width of the shelves, the steepness of the lower
part of the continental slope (the scarps) and the flatness of the floor of
the main basin with its exceptionally thick sequence of sediments.
TOPOGRAPHY OF THE NORTHERN GULF SLOPE
The continental slope of the northern Gulf of Mexico represents the seaward
part, or the growing margin, of the Gulf Coast geosyncline where geologic
processes that helped to shape the basin are active today. (Lehner, 1969).
The slope is broken in many places by ridges, knobs, canyons, troughs and
basins; however, the proposed incineration site is in an area of relatively
low relief where the sea-floor gradient is somewhat uniform and gradual (see
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26
Fig. II-l for the site's generalized topography).
The continental slope off Texas and Louisiana consists of at least two seg-
ments, a relatively steep lower slope known as the Sigsbee Escarpment and an
irregular upper segment identified by its hummocky topography (Uchupi, 1967).
As one can see in Fig. H~l» the proposed site is positioned between these two
major topographic features. Antoine (1972) associates the roughness and
irregularity of the upper slope to underlying diapiric structures of Triassic-
Jurassic salt and suggests that the Sigsbee Escarpment represents the present
frontal edge of the salt migration.
A feature peculiar to the shelf break in the northwest Gulf is a series of
prominent banks or topographic highs rising abruptly from the generally smooth,
sediment-covered bottom (Parker & Curr.ay, 1956) . Several investigators have
offered explanations for their origin, dating from Shepard (1937) who sug-
gested that these banks may be related to salt-dome structures. Others have
I '
explained them on the basis of biohermal structures which have kept pace with
changing ,-^.a levels (Stetson, 1953; Mathews, 1963). One of the more interest-
i !
ing and intensively studied of the banks is the West Flower Garden, a possible
I»
element o£ a discontinuous arc of reefal structures occupying the Gulf's
*'i
southern i.np western continental shelves (Bright & Pequegnat, 1974;- Edwards,
1971). It* md the similar East Flower Garden Bank are capped by what are
considered,1 l.o be the northernmost thriving tropical shallow water coral reefs
! j
on the east' rn coast of North America; however, they are located 133 km north
if
of the proposed incineration site.
SEDIMENTOLOGY BELOW THE PROPOSED INCINERATION SITE.
Bottom sediments are dominantly fine-grained in the deep-water portion of the
Gulf of Mexico whereas complex patterns and mixtures of fine and coarse-grained
sediments characterize the continental slopes and shelves. The dominant con-
stituent of deep-water sediments is post-glacial alluvial silt and clay (see
Appendix A) which overlies glacial alluvial material (U.S.N.O.O., 1972).
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Calcareous remains of pelagic foraminifera are mixed with the sediments and,
for a major part of the Gulf, tend to mask other sediment types by means of
a thin cover of Globigerina ooze (Bouma, 1972). ¥ithin the perimeter of the
proposed incineration site this cover ranges in thickness from less than 10
to more than 40 cm (see Appendix A, Fig. A-8 — an isopach mapping of the top
Globigerina ooze). The carbonate content of the sediment below the ooze cover
in that region averages between 14 and 25 percent (Appendix A).
A major portion of the proposed site's bottom sediment contains heavy minerals
from the Mississippi Province and the remainder, approximately one-third of
the total area, has those of the Central Texas Province. In general, the basic
sediment is clay particle in size except for a small region of "clay-silt-sand
undifferentiated" in the southwestern corner (Appendix A). Sediment maps com-
piled by U.S.N.0.0. (1972) also reveal a muddy sand in the southwest corner
of the area but no data are offered that would eliminate Globigerina^ ooze as
being the source of the sandsized particles. However, one should note that
the Central Texas heavy mineral assemblage occupies that general region and
abuts the .more extensive Mississippi suita to the east. This factor or past
influence of the Rio Grande River, especially during the Pleistocene, might
possibly account for the larger sediment found there. Bouma (1972) notes that
the extent of the Rio Grande Province is decreasing in areal coverage with
time.
A more detailed description of the structure, morphology, topography, and bot-
tom sediments of the Gulf of Mexico is given in Appendix A.
METEOROLOGICAL ASPECTS OF THE PROPOSED INCINERATION SITE
VISIBILITY
According to data received from the National Climatic Center for the two degree
square bounded by 26°-28°N, 92°-94°W (Appendix F), the site has a very low fre-
quency of poor visibility. The annual percent frequency of visibility less
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29
than 1 mile for the site is 0.23 compared with 1.0 for Corpus Christi, 0.9
for Galveston and 1.6 for Mobile (Brower et al., 1972). For visibility of
less than 5 miles the annual percent frequency for the site is 2.6 compared
with'3.7 for Corpus Christi, 3.4 for Galveston, and 4.7 for Mobile (Brown
et al., 1972).
RELATIVE HUMIDITY
Relative humidity along the northern Gulf coast is high as a result of abun-
dant rainfall and prevailing southeasterly winds which have a long fetch over
the warm waters of the Gulf of Mexico. This has been exemplified by Stone
(1972) who shows that annually relative humidity is above 90% more than 50%
of the time during the early morning hours at New Orleans. Further offshore,
in the vicinity of the site, the relative humidity is much lower, i'.e., rela-
tive humidities more than 90% occur less than 15% of the time annually in the
morning hours. Seasonally at the site, relative humidity tends to be higher
during January-May and lowest coring July-August. On a daily basis the site's
relative humidity is lowest in.the afternoon (Appendix F).
- '
WINDS AND STORMS > \
1
It
Historically, winds at the propped site are the calmest during July and
August with average wind speedstcf 7-10 knots (U.S. Navy Hydrographic Office,
1972). Wind speeds increase SOB'-What during September-October having average
speeds of 10-12 knots. Wind speeds are highest in November-February averaging
13-15 knots. Winds tend to subside in March-June and by July-August they are
back to their lowest average velocity.
In addition to the average wind speeds the table below taken from Marcus (1973),
gives percentile distribution of observed wind speed (in knots) by month for
National Climatic Center Subregion 34; the proposed site is in the northwestern
part of this Subregion. The table reflects only observed data; thus wind
speeds reached in tropical storms and hurricanes are generally not reflected
-------
30
since mariners try to avoid these conditions. Tropical storms and hurricanes
will be addressed later. This table is to be read as per the following ex-
ample: 25% of the wind speed observations in January were equal to or less
than 9 knots.
Extremes &
Percentiles
Observed Wind Speed in NCC Subregion 34
MAMJJASON
0
0
4
9
0
0
4
9
0
0
5
9
0
0
5
9
0
0
3
7
0
0
1
5
0
0
0
5
0
0
0
4
0
0
3
7
0
0
4
8
0
0
4
8
0
0
4
8
Min.
01
05
25
50 14 14 13 13 11 10 10 9 11 12 13 13
75 20 19 18 18 16 14 13 12 17 18 18 18
95 27 25 25 24 21 19 17 16 24 25 25 25
99 35 35 30 27 25 25 21 22 40 40 31 33
Max. 40 46 37 35 30 40 28 30 60 37 45 40
In the region of the proposed incineration site, winds throughout the year
prevail from the eastern quadrant, however, strong northerly components are
evident from November through February (Appendix F).
Abnormally high speed winds may occur in the proposed site during winter
(as northers) or late summer (as tropical storms or hurricanes). A norther
is a strong cold wind coming from the northeast-northwest and may extend
into the Gulf area between November and April. This cold air mass is usually
preceded by a warm and cloudy or rainy spell with southerly winds. From one
to six northers are likely to be severe over the Gulf during individual years.
Northers generally last about a day and a half, but severe storms may endure
for three or four days (Brower et al., 1972).
Tropical storms (winds of 34 to 63 knots) and hurricanes (winds of 64 knots
or higher) are more active in the Gulf during the months of August and
September. The great majority of tropical storms and hurricanes in the area
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31
of the proposed site come from the southeastern quadrant and move at a mean
speed of approximately 10 knots.
The number of tropical storms and hurricanes expected to occur in a 100 year
period within the 2 1/2° square subregion enclosing the proposed site is
given by Marcus (1973). These data as well as the data on contiguous 2 1/2°
square subregions are given in Appendix F; however, in summary, 43 tropical
storms and 26 hurricanes are expected to occur within or very near the in-
cineration site in a 100 year period.
PHYSICAL AND CHEMICAL PROPERTIES OF THE WATER
The proposed site is located in oceanic waters and the physio-chemical para-
meters of. the site's water column are typical of that found in the west
central Gulf. The site's water column, as well as that of the west central
Gulf, is vertically layered with five recognized water masses which are dis-
tinguishable by distinct values or gradients in specific parameters. Of these
five layers the uppermost, Surface Mixed Layer, undergoes greater seasonal
changes in physio-chemical parameters than do the deeper water masses. How-
ever, the seasonal changes in the site's Surface Mixed Layer are muted in
comparison to waters closer to shore.
Wind, waves, and currents prevail to the westnorthwest with the calmer period
of the year being June-August.
CURRENT PATTERNS
GENERAL
Several attempts have been made from time to time to describe the general
circulation ofsurface waters in the Gulf of Mexico (Nowlin 1971 and 1972;
Leipper, 1970; Ichiye, 1962). From thes.e studies it can be seen that the
-------
32
flow in the eastern Gulf is dominated, especially in late spring and summer
by the Loop Current; water enters through Yucatan Strait as the Yucatan
Current and flows in a clockwise loop which extends well north into the
Gulf (varying considerably from year to year) and exits principally via the
Florida Straits. In late summer or fall large rings of circulating water
(an eddy) may separate from the Loop and generally move westward taking per-
haps several months or a year before they lose their integrity (Leipper,
1970; Cochrane, 1972). So far as is known now, the flow of surface water in
the western Gulf is somewhat less dynamic but is thought to be more predicta-
ble than that of the eastern Gulf (Nowlin, 1972) . Essentially there are
three sizable gyres from north to south in the western Gulf. Only the central
and northern ones are of concern in this study. In winter a large clockwise
(anti-cyclonic) cell is centered over the west-central Gulf. Obviously its
southern limb will be flowing westward and its northern limb will flow north-
eastward where it veers into and reinforces the southern limb of a counter-
clockwise cell. As it continues to move, it comes to be flanked by a south-
westward current flowing along the outer Texas-Louisiana shelf.
CURRENT PATTERNS OF THE PROPOSED SITE
The flow of surface water over the proposed site varies only a small amount
seasonally (Fig. II-2 ). The prevailing current is to the west or northwest.
Data of the U.S. Naval Oceanographic Office (1972) for the area around the
proposed site show that during January-March currents to the northeast
quadrant occur with almost equal frequency as those to the western quadrant
(Appendix F). Currents during the remainder of the year (April-December)
show a strong affinity for westward flow. Current speed within the area is
within a moderate range of 0.6-0.9 knots; seasonal as well as an annual cur-
rent speed summary are given in Appendix F.
Only a very small amount of data have been published on the Gulf's subsurface
currents. Moore (1973) reported currents ranging in speed from 0.1 to 0.6
knots move along or obliquely across the upper continental slope of the
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33
PROPOSED INCINERATION
SITE
Fig. H-2. Possible patterns of flow of surface waters in the western part
of the northern Gulf shown by fine arrows on a monthly basis.
Heavy arrows show submarine flow (compiled from U.S. Hydrographic
Office, 1972 and Moore, 1973).
-------
34
northwestern Gulf (Fig. II-2 ). His data show subsurface currents and counter -
currents with shears at depths of approximately 120 m and 450 m. It is
important to note that Moore (1973) believes that these over-the-slope cur-
rents are not regulated by tidal movements. In addition, Moore (1970) showed
that submarine currents of velocities ranging from 0.1 to 0.6 knots are able
to move medium to coarse sands (0.7 to 4.0 mm).
WATER MASSES
~ ~ ~~ ~ ^^^~~™ r
The principal inflow of water into the Gulf of Mexico is from the Caribbean
Sea through the Yucatan Strait. These waters are a mixture of South Atlantic
water (transported northwestward by the Guiana and Equatorial current systems)
with North Atlantic water (from the west Sargasso Sea). The ratio of South
Atlantic to North Atlantic water has been estimated to be between 1:4 and 1:2
(Harding and Nowlin, 1966). Most of the outflowing water passes through the
Florida Straits into the North Atlantic.
Five water masses are recognized in the Gulf and all occur within the site's
water column. These water masses are vertically layered as follows: (1) Sur-
face Mixed Layer, (2) Subtropical Underwater, (3) Oxygen Minimum Layer,
(4) Subantarctic Intermediate Water, and (5) Gulf Basin Water. Each of these
water masses can be distinguished in the Gulf by distinct values, gradients,
or relative maxima or minima in specific parameters (see Appendix F).
SEA AND AIR TEMPERATURE
Throughout the year, variations in shelf surface temperature closely follow
those of coastal air temperature; however, farther offshore in the vicinity
of the site, surface temperature corresponds with air temperature in the spring
and summer, but deviates somewhat in the fall and winter. This seasonal re-
lationship between surface temperature and air temperature for the proposed
site is given in Table II-l. Probable vertical distribution of isotherms
-------
35
during March for the proposed site is given in cross-section and are shown
in Appendix F. From the table mentioned above it can be seen that the annual
variation in average monthly surface temeprature -is some 10°C. Data of
Etter and Cochrane (1975) and TerEco (1976) indicate that at a depth of 150 m
the difference in annual temperature extremes is some + 3°C. The difference .
in temperature extremes is approximately + 1.5°C at 500 m, + 1°C at 750 m,
+ 0.5°C at 900 m, and less variation below the latter depth.
Table II—1. Average monthly sea surface and air temperatures for 5° square
(25°-30°N, 90°-95°W) number 50 of Marsden Square number 82
(taken from data furnished by the National Climatic Center,
Asheville, N.C.).
Sea
Surface Air
Jan 20.8 18.4
Feb 20.6 ' 19.0
Mar 20.9 19.8
Apr 22.2 22.0
May 25.3 25.3
Jun 28.1 27.9-
Jul 29.6 29.0
Aug 29.8 29.1
Sep 29.0 ' 28.0
Oct 27.3 25.3
Nov 24.4 21.3
Dec 22.2 19.3
SALINITY
Over the site the salinity of the surface waters is generally within the
range of 36.0 - 36.4 ppt (Nowlin and McLellan, 1967). Surface salinities
may depart from this range since lower values (river influenced) have been
detected in the Gulf as far south as the site; however, their influence is
limited only to the upper part of the Mixed Layer, (Abbott and Bright, 1975).
In the vicinity of the site, vertical difference in salinity is only about
1.5 ppt from the surface to the bottom (Appendix F).
-------
36
Approximately 80 surface samples were collected at the site during the October-
December, 1974 incinerations of organochlorine wastes. Except for one sample,
37.0 ppt, all were in the range of 35.9 - 36.4 ppt (Appendix G).
DISSOLVED OXYGEN
In the Surface Mixed Layer, dissolved oxygen concentration is fairly uniform
and tends to be at saturation values. If the upper part of the water column
is relatively stable (little mixing), a subsurface maximum in dissolved oxy-
gen concentration is frequently present somewhere in the first 50 m as a
result of oxygen production by photosynthesis. Below the photosynthetic zone,
oxidation and respiration tend to reduce the dissolved oxygen content. This
process contributes to the formation of the oxygen minimum layer. The degree
to which this core of low dissolved oxygen is depleted depends mainly on
(1) its original dissolved oxygen content at formation, (2) the amount of
oxidizable matter within the layer, and (3) its residence time. The Gulf's
.oxygen minimum layer is derived primarily from the outside and enters the
Gulf via the Yucatan Strait (Wust, 196^. This entering layer, with a dis-
solved oxygen content of approximately:>.6 ml/1, spreads northward and becomes
! i
contiguous with the sediment along the.JTjlope (Appendix F) . According to
Nowlin (1972) the core of the oxygen ndoimum layer in the vicinity of the site
is at a depth of around 250 m and has i- dissolved oxygen content of slightly
less than 2.4 ml/1 (See Appendix F). \ .
'tv
ACIDITY AND ALKALINITY
The definition of pH is given by the following equation: pH = -log (H+) . The
term alkalinity, as used by oceanographers, is defined as the number of milli-
equivatents of H"1" necessary to titrate the anions of weak acids in one liter
of seawater. Unfortunately this usage of the term alkalinity is confusing
because chemists have long used the same term to describe the OH~ concentration.
-------
37
Since the H"*" concentration in sea water is involved in numerous equilibria,
local, seasonal, and diurnal variations are often found. For example, one
of the many factors on which pH is dependent is the amount of dissolved CC^,
which in. turn depends on photosynthetic activity and thus on the amount of
solar radiation. Therefore, in the assessment of environmental perturbations
using pH measurements, it is necessary to have controls.
During the October-December 1974 monitoring of the incineration of organo-
chlorine waste approximately 185 pH samples and controls were analyzed from
the proposed site. Except for one sample (pH 3.05) all were within the
range of pH 8.2-8.4. In addition, diurnal variations were noted in the pH
values (Appendix G). Alkalinity values determined from 23 samples collected
at the proposed site during December 1974 ranged from 2.46-2.54 meq (H*)/!.
Statistical treatment of the data showed no significant differences between
in-plume test and up-wind control values (TerEco, 1975) .
WAVE HEIGHT AND DIRECTION
There has been no long term study of wave heights specifically within the
proposed site; however, the site is within National Climatic Center sub-
region 34 and adjacent to the northwest of miniregion 341 (Marcus, 1973).
Wave heights are generally greater during December-February and reach their
low during June-July. From Table II-2 (taken from Marcus, 1973, for Mini-
region 341) it can be seen that during December-February wave heights > 5 ft.
occur 45-53/0 of the time and those > 3 fc. occur 8-13% of the time. In
June-July the occurrance of > 5 f.t, v.'«ves is 12-17% of the time and those
> 8 ft. occur 0-0.5% of the time (f');r additional information see Marcus,
1973).
Wave direction in the proposed site corresponds closely to wind direction.
According to U.S. Naval Oceanographic Office (1963), throughout the year
generally less than 10% of the waves have a westerly component. In April-
September waves come mainly from the southeast quadrant. During October-
-------
38
March there is an increase from the northeastern quadrant with the south-
eastern component (Marcus, 1973).
Table II-2. Wave height by month for miniregion 341 (25-26°N, 92-93°W).
Med . Wave
Height
4.9
3.3
3.3
3.3
3.3
3.3
1.6
3.3
3.3
3.3
3.3
3.3
7, Freq.
> 5 ft.
53.4
49.5
43.8
41.1
36.7
16.5
12.2
17.5
37.2
37.7
41.7
45.1
% Freq.
> 8 ft.
13.1
11.2
9.4
6.8
6.3
.5
.0
2.1
7.0
7.9
7.0
8.3
% Freq.
> 12 ft.
1.9
2.1
1.0
.0
.5
.0
.0
1.3
2.8
3.9
1.5
1.0
No. of
Obs
206
180
203
192
207
212
180
234
215
228
199
193
JAN
FEB
MAR
APR
MAY
JUNE
JULY
AUG
SEPT
OCT
NOV
DEC
THE BIOLOGICAl COMPONENT
PELAGIC BIOTA OF THE PROPOSED INCINERATION SITE
From the data available for the proposed incineration site, one can specu-
late that it is not within as productive an area as either the adjacent
continental shelf or upper continental slope regions. Such a finding holds
true for both the phytoplanktou and zooplankton components of the pelagic
realm (Appendices B it C) . TJ..':a cro-oi TerEco (1974) show the relative abundance
of phytoplankton cells c^iioc^sd within the limits of the study area to be
from one to four orders of magnitude less than counts obtained from the
vicinity of the continental shelf break and landward (see Thomas and Sim-
mons, 1960; Kulburt and Corwxn, 1972; and Fucik, 1974). Zaitsev (1970) re-
corded a maximum biomass for zocplankton taken during a night neuston tow at
a shallow station (30 m) and speculated that in waters toward the center of
the Gulf the normal zooplankton density was less than that of the shelf region.
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39
Constituents of the nekton, i.e. fishes and cephalopod mollusks, will tend
to concentrate in areas of abundant food supply since they are free-swimming
forms. It seems likely that a number of the less important nektonic species
inhabit the proposed incineration site waters as year-around residents, where-
as many predatory species of commercial and sport's interest (e.g. billfishes,
tuna, dolphin) are probably only seasonal transients in the area, but little
direct information on this point exists.
PHYTOPLANKTON
Although there has been extensive sampling in the Gulf of Mexico for deter-
mination of phytoplankton standing crop and productivity (El-Sayed, 1972)
and to a lesser extent for species distributions (Balech, 1967), only a few
samples have been taken near the proposed site. El-Sayed (1972) has one
station within this area for a phytoplankton standing crop measurement (as
surface chlorophyll-a_ concentration) taken in 'August. Chlorophyll-a concen-
tratioh'at this station was low (0.11 mg/m^). ! 'fchlorophyll-ji values (mg/nH
7 j i
for discrete samples; mg/m^ for integration oft 'all discrete samples over the
euphotic zone) represent the amount, or biomas^, of phytoplankton present
in the water. At several stations peripheral :•» the proposed site, surface
chlorophyll-a values were also low in August rtfll-0.18 mg/m ), but slightly
*5 I
higher in February (0.18-0.32 mg/nr). Chloropi>ll-a concentrations integrated
over the euphotic zone are absent for the site/, but at four stations west of
• 7
and two stations east of the site, values ranged from 8.20 mg/m in February
2 3
to 20.98 mg/m during August. (The latter values would average 0.102 mg/m
and 0.26 mg/m , respectively.)
El-Sayed (1972) presented no surface primary productivity values for the site,
2
but at four near-by stations values were in the range of 0.17-0.32 mgC/m /hr
o
during August and September. Primary productivity values (ingC/m /hr for dis-
ry
crete samples; mgC/m /hr for integration of all discrete samples over the
euphotic zone) represent the photosynthetic activity of the phytoplankton.
-------
40
At one station east of the site, primary productivity integrated through the
2
euphptic zone was also low (1.0-3.16 mgC/m /hr) during August.
'i
It appears that the low primary productivity and chlorophyll-a_ values are
related to low nutrient levels. At several stations in the vicinity of the
study site, phosphate, nitrate, and silicate concentrations at the surface
were 0.05-0.32 ^ug-at/1, 0.17 >ig-at/l, and 1.7-6.4 pg-at/1, respectively.
A recent quantitative phytoplankton study at the proposed incineration site
was conducted in the fall of 1974 (TerEco Corporation, 1974). At six stations
occupied in October between 26°26'N-26°52'N and 93°55'W, 29 diatoms, 16 dino-
flagellate, 2 silicoflagellate, and one cyanophyte species were recorded.
The most abundant species was Oscillatoria sp. (probably Oscillatoria erythraea)
o
with 0.35-48.8 x 10 cells/1. Relative abundance of other combined species
o
ranged from 1.30-4.88 x 10 cells/1. The most abundant diatom species in-
cluded Bac t er ias t rurn delicatulum, Chaetoceros^ affine, £. atlanticum,
Navicula sp., Nitzschia seriata, Rhizosolenia calcar-avis, R. hebetata,
R.. jstyliformis^ and Synedra sp. Nine species of the genus Ceratium,
Peridinium sp. and Prorocentrum sp. were the most abundant dinoflagellates
collected during the study.
A detailed presentation of Gulf of Mexico phytoplankton species distributions,
standing crop distributions, primary production, and seasonal cycles is
given in Appendix B.
ZOOPLANKTON
Zooplankton of the proposed incineration site almost wholly consist of oceanic
forms. The site's distance from shore in conjunction with it's water depth
preclude most larval forms of commercially valuable continental shelf organ-
isms such as the shrimps and crabs. The most abundant zooplankton groups
occurring within the proposed site are copepods, chaetognaths, euphausiids,
-------
41
and ptcropods. Zooplankton species enumeration, geographical distribution,
and standing crop biomass are given in Appendix C. Although the numbers of
zooplankton species and individuals listed from the open Gulf waters in
the vicinity of the proposed site may seem large, the site's fauna in com-
parison to nearshore regions is considered depauperate.
NEKTON
Nekton includes marine mammals, most fishes and cephalopod mollusks, and
certain crustaceans which, because of their powerful swimming abilities, are
able to move independently of water currents. These species are often able
to escape most nets and other collection gear, hence knowledge of the geo-
graphic and vertical distribution patterns of nektonic species is often in-
complete. The predominant components of this fauna are cephalopods, shrimps,
and fishes.
It is doubtful that incineration activities will have adverse effects on this
active component of the fauna at the proposed site. Few larvae of commercially
important shrimp species are present, and larger nektonic species are not
known to be abundant. Neither the site itself nor the proximal area should
support a productive fishery due to the absence of hard banks in that locale.
Appendix D gives a more detailed coverage of the nekton of the Gulf of Mexico.
NEUSTON
Neuston designates the fauna that lives on, in, or just below the surface
film of water bodies. This biotope is not clearly separated from the rest
of the water column nor is the neuston itself strictly separated from the
plankton. Under certain conditions (e.g., during dim light, in turbid waters,
and at night) the neuston community becomes less distinct or even almost
identical to the zooplankton community of the adjacent strata.
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42
The surface layer of aquatic bodies differs from the underlying water in
a number of ways, notably the inflow and accumulation of dead organic matter,
the biological activity of the foam, and the presence of ultraviolet and in-
frared rays from solar radiation. Among the abiotic factors which strongly
influence the surface biotope are temperature, wave action, currents, and
man's pollutants (e.g., pelagic tar, plastic, DDT, and PCBs). Therefore,
marine neustonts must be adapted to, or at least capable of adjusting to,
fluctuating degrees of environmental stress in their ecological niche.
Principal Living Components
Examination of the catch of a typical neuston tow from the slope region of
the Gulf of Mexico would reveal a fauna of varying complexity, dependent
upon both diel and seasonal times of collection. Included in the samples
would be a general assortment of siphonophores and medusae, chaetognath and
polychaete worms, pelagic gastropod mollusks and fishes, and the larvae and
adults of numerous crustaceans.
Early neuston samples from the northwestern Gulf were taken in order to as-
certain the abundance of pelagic tar within a semi-enclosed sea that has
extensive offshore oil production and tanker traffic (Jeffrey et al., 1974).
During the removing of tar lumps for laboratory analysis, these investigators
sorted the neustonts, classified them to major taxa, and enumerated the
organisms on the basis of relative abundance (see Table II-3 for those
stations near the limits of the proposed incineration site).
A more detailed study of neuston samples was conducted by TerEco Corporation
during the fall of 1974 in conjunction with incineration activities over
oceanic waters of the Gulf. These data are most valuable since that study
constitutes one believed to offer complete enumeration of organisms collected
during neuston tows from the proposed incineration site. These stations are
designated as A through H and the specimens are enumerated in Table II-4.
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43
Table II-3. Relative abundance of neustonts from samples
taken for pelagic tar study.
Specimen
Cnidaria
Hydroid (parts)
Medusa
Siphonophore (parts)
Porpita sp.
Chaetognatha
Polychaeta
Gastropod Mollusca
Prosobranchia
Atlanta sp.
Opisthobranchia
Pteropods
Crustacea
Amphipoda
Copepoda
Decapoda (larvae)
Brachyuran
Natantian shrimp
Sergestid shrimp
Lucifer sp.
Euphausiacea
Isopoda
Mysidacea
Stomatopoda
Echinodermata (larvae)
Insecta
Chordata
Thalliacea
Pisces
Eggs
Juvenile
Adult
Sargassum
Actinaria
Serpulidae
Station
12345
X X X X
X
X
X X
.XXX
X XX
X X
X
X X X XX X
X X X XX X
X
X
X XXX
X X
X X
X X
XXX
X X
X XX X X X
XX X X X X
X X
XXX
6 7
X
XXX
X X
X
X
X X
X X
X
X
X
XX
X XXX
XX X
X X
X X
XX '
XX
X X
X
X XX
X X
XX XXX
X X
X X
8 9
X X
X
X
X X
X X
XXX XXX
X
XX
X X
X X
XX X
XXX XX
X X
X
X
x = present
xx = abundant
xxx = very abundant
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44
Table
Enumeration of organisms collected In neuston net tow*
from northwest Gulf of Mexico.
Cnldarla
Medusa
Slphonophore (parts)
Porpita sp.
Chaetognatha.
Polychaeta
Hollusca
Gastropoda
Prosobranchia
Betcropods
Oplsthobrachla
Pteropods
Cephalopoda
Argonauta »p.
Larvae
Arthropoda
Crustacea
Amphipoda
Copepoda
Pontella ap.
Candacea ep.
Coptlla sp.
Decapoda
Brachyuran (larvae)
Natantian shrimp
Carl dean shrimp
Latreutes fucorum
Leander tenuicornis
Palaemonld (larvae)
Other Caridea (larvae)
Sergestid shrimp
Lucifer sp.
Palinurldae
Larvae
Juvenile
Euphausiac,ea
Isopoda
Mysldacea
Slriella thoapsonll
Stomatopoda (larvae)
Insect*
Halobates sp.
Terrestrial forms
Echinodermata (larvae)
Chordata
Pisces
Antennariidae (Sargassum fish)
Hlstro «p.
Balistidae (Trigger fish)
Coryphanldae (Dolphin)
Coryphana sp.
Exocetidae (Flying fish)
Cypselurus sp.
Parexoeoetus sp.
Gonostonatidae (Viper fish)
Hugilldae (Mullet)
Hugll sp.
Myctophidae (Lantern fish)
Gonichthys sp.
Hygophym sp.
Hyccophma sp.
Pleuronecclformes (Flatfish)
Sternoptychidae (Hatchet fish)
Sternoptyx diaphana
Others (juvenile)
Sargassum
Actlnara
17
5
24
11
14
4 68 42
1 6
59 30
11
x
11
C B
1
XX XX
3
21 51
171 22
247 1
5 5 33 456 15 41
1
4
153 106
1 1
1
1 20
4 6
2 • 56
1
33
12
2
1
1
62 26
59 3
45 61
2 7
1
2 13
I
1
2 1
• 7 8
3 5
148
2
4
251
3
12
7
5
83
83
9
7
2
165
19
107
2
579
17
20
1
128
112
1
55
109
60
4
23
1
88
1
179
14
7
3
176
39
2
110
38
4
1
31
1
1
129
69
12
18
8
16
18
X
10
X
3
present
» abundant
-------
45
Another very pertinent study is that of Berkowitz (unpublished thesis) which
also includes stations within the perimeter of the site. Based on his col-
lection data and analysis, he states that "the neustonic zone of the open
Gulf of Mexico is an impoverished area". A comparison of TerEco (1974)
data with findings of Zaitsev (1970) or Hempel and Weikert (1972) tends to
support such a speculation.
Abiotic Substances
Floating tar in the open ocean has been observed for at least twenty years,
but no concentrations were determined until Horn et al. (1970) made a survey
of pelagic tar in the Mediterranean. It has become evident in the past 10
years that tar is a common component of the neustonic environment and it is
a rare neuston tow that does not contain tar lumps (Morris, 1971). It re-
mains to. be seen what effects this material may have on organisms living in
association with it.
For additional information concerning abiotic substances collected from the
ocean surface, one should refer to the works of Morris and Butler (1973),
Sherman et al. (1974), Jeffrey et al. (1974), and Butler (1975).
BENTHIC BIOTA OF THE PROPOSED INCINERATION SITE
The benthic environment is in general affected and defined by the same factors
that influence the waters above the bottom. Additional factors to consider
for the sea bottom alone are: 1) nature of the substrate, 2) nature of the
sediment, and 3) sub-bottom temperatures, salinity, oxygen and pH. The
substrate may be hard or soft depending on the amount and nature of the sedi-
mentation, and the degree of scouring by horizontal currents. Sediment type
is usually described by percentages of carbonates, evaporities, sand, silt,
and clay. Sub-bottom temperature, salinity, oxygen, and pH can be much dif-
ferent than overlying waters, especially the oxygen and pH values. The
benthic environment becomes more stable at greater depths, i.e. it is less
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46
affected by physical forces such as currents, waves, and storm surges.
Temperature and salinity data tend to fluctuate less and have smaller ranges
of values than in shallow water areas closer to the air-sea interface.
Whereas the planktonic biota of the surface waters over the proposed site
may be viewed primarily as transitional between that of the shelf and that of
the deep Gulf, such is probably not the case with the benthic fauna. Most of
the benthic inhabitants of the slope are not found elsewhere, and together
they constitute a complex, true slope fauna (TerEco, 1976). Major depth-
related faunal breaks were cited between 175-225 m, 500-550 m, and 750-800 m
on the upper continental slope, along with speculation of additional assem-
blages on the deeper slope beyond the depth range of their study. Unpublished
data from benthic stations near the proposed incineration site tend to verify
further zonation with faunal breaks around 1000 m (550 fm), between 1450-
1750 m (800-950 fm), and near 2500 m (1350 fm). That is to say, there are
probably two different benthic assemblage zones occupying the depth' range of
the proposed site. Nonetheless, it should be noted that these datil 'show
agreement with Thorson (1971) who observed an obvious, decrease in t.ie number
of individuals with increasing depth. .,
ZOOBENTHOS
Numerous benthic stations have been sampled in the near vicinity of/he
proposed incineration site by TerEco personnel, however, none were within
i
its perimeter. Those samples have been worked, i.e. species identified and
enumerated, but these data have not been presented in published form. It
was deemed appropriate to select several stations closely adjacent to the
site (shallower, deeper, and flanking) and enclose them as a portion of the
present study in order to offer one a conception of the zoobenthos of that
area. The collections, obtained by means of either dredging or trawling
during the period between 1969 and 1973, are presented in Appendix E.
That tabulation contains the following numbers of species of the designated
suprageneric categories:
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47
Suprageneric Category Number of Species
Caridean shrimp 13
Penaeid shrimp 8
Brachyuran crabs 4
Galatheid crabs 9
Pagurid crabs 1
Polychelid crustaceans 4
Nephropid crustaceans 2
Isopod crustaceans 1
Holothuroids (sea cucumbers) 6
Asteroids (starfish) 12
Bivalve mollusks 1
Cephalopod mollusks 7
Demersal fish 35
Even though this appears to be a large number of species, it does not approach
the more than 400 species found on the upper slope (TerEco, 1976) nor the
number that has been collected from the continental shelf region.
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48
(This page intentionally left blank.)
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49
III. ALTERNATIVE TO PROPOSED DESIGNATION OF AN OCEAN
INCINERATION SITE
•
"NO ACTION" ALTERNATIVE
DEFINITION OF "NO ACTION" ALTERNATIVE
The "no action" alternative in this EIS is the alternative of not selecting
or postponing the selection of an ocean incineration site in the general
area of the 1974-75 incineration site in the Gulf of Mexico. An important
justification for choosing this alternative would be the lack of environmental
data on the site area, the lack of a demonstrated need for ocean incineration
in the general area, or sufficient evidence to eliminate ocean incineration
as a viable alternative for the disposal of wastes.
i
REJECTION OF "NO ACTION" ALTERNATIVE ,' 'i
1 •?
1 '
Under Section 102(c) of the MPRS Act the Administrator of th«S 'Environmental
Protection Agency is given the authority to designate recommeiided sites for
ocean disposal pursuant to addressing the guides set forth in Section 102(a)
of the MPRS Act. Exercise of this authority will occur only |i*ter need-for a'
site is evident and it has been demonstrated that the disposa method is en-
vironmentally sound. " '
'i,
;'
The burgeoning growth of the petrochemical industry in the western Gulf states
has resulted in the accumulation of highly toxic organic waste by-products,
especially of the organochlorine type.
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50
Numerous problems have arisen in finding environmentally safe methods of
disposal of these wastes. Since conventional barging and dumping of these
wastes into the ocean in untreated form is generally prohibited under
Section 227.27 of the Ocean Dumping Regulations and Criteria, other methods
have been studied and tested by the EPA. Data from EPA's study of rese'arch
burns of Shell's organochlorine wastes in the area of the proposed site in
late 1974 and early 1975 support EPA's determination that ocean incineration
is an environmentally sound alternative for disposal of some highly toxic
wastes, especially some of those being generated in that area of the Gulf.
EPA's concurrent studies of the 1974-75 ocean incineration site also provided
environmental data on the proposed site. Accordingly, the EPA has determined
there is sufficient need for the designation of an ocean incineration site in
this area of the Gulf of Mexico. Thus the "no action" alternative was rejected
by EPA.
DESIGNATION OF THE PROPOSED SITE
The criteria set forth in section 228 of the proposed revisions to the Ocean
Dumping Regulations and Criteria, listed in Chapter I, were used by EPA in
the evaluation of the proposed site. The following, a summarization of the
results of this evaluation, briefly gives the reasons for deciding that the
proposed site fully satifies the criteria. The more detailed information
used in this evaluation can be found in the chapters on the existing environ-
ment and effects of the proposed action (Chapters II and IV and Appendix G).
(1) Geographic position, depth of water, bottom topography and distance
from the coast.
The proposed site is positioned over the continental slope of the
northern Gulf of Mexico, some 300 kilometers from the nearest coast,
where the minimum depth of water is more than ample (1100 meters).
This satisfies the requirement of Section 228.5, that "EPA will,
wherever feasible, designate ocean dumping sites beyond the edge
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51
of the continental shelf." Also, it is located as near as feasible
to the industries that produce substantial quantities of highly toxic
organic wastes.
(2) Location in relation to breeding, spawning, nursery, feeding, or
passage areas of living resources in adult or juvenile phases.
Available evidence suggests that in the waters of the proposed site
nutrient levels are low, phytoplarikton standing crop is low, few
larvae of commercially important shrimp species are found, and
larger nektonic species are not known to be abundant.
(3) Location in relation to beaches and other amenity areas.
Results of testing indicated no detectible concentrations of pollu-
tants reaching the beaches. The proposed site is so distant from
shore that only under the most unlikely of physical conditions would
products of the incineration process reach Gulf beaches and then
only in such high dilution as to be undetectable by the most advanced
of chemical analytical techniques.
(4) Types and quantities of wastes proposed to be disposed of, and pro-
posed methods of release, including methods of packing the waste.
Should the proposed site be used for the incineration of chemical
wastes it is anticipated that they would be of the organochlorine
variety. (Permits for incineration at the site will be issued only
after full public notice and opportunity for public hearing at which
the public will have ample time to express their opinions.) The re-
sults of the research burns demonstrated that combustion efficiencies
of greater then 99.9% (as required by the permit) are achievable,
meaning that less than 0.1% of the waste will be discharged to the
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52
environment. The principal products of combustion were HC1, any
organachlorines not destroyed and trace metals. It has been demon-
strated that no detectable deleterious effects on the marine environ-
ment occurred during 1974-75 research incineration when organochlorine
were incinerated.
(5) Feasibility of surveillance and monitoring.
The location of the site posed no special problems of monitoring the
1974-75 incinerations either from sea level or in the air. The
present configuration of the site has been established congruent with
specific Loran C lines in order to facilitate navigation and sur-
veillance.
(6) Dispersal, horizontal transport and vertical mixing characteristics
of the area, including prevailing current direction and velocity.
The prevailing winds and currents of the site are normally of suf-
ficient magnitude as to promote effective atmospheric and oceanic
transport and dispersal of incineration products. The thickness
of the surface mixed layer at the proposed site is sufficient to
allow effective dilution of plume fallout.
(7) Existence and effects of current and previous discharges and dumping
in the area (including cumulative effects).
The flow and resultant short residence time of the waters at the
site preclude the possibility that the 1974-75 incinerations could
produce measurable effects upon pelagic life while within the site
boundaries. In view of the great depth of water at the site and the
nature of the plume fallout no effects on bottom life will occur within
the site boundaries. Additionally, since no known dumping has previous-
ly occurred at the site the only effects would be from incineration and
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53
and these have been shown to be nonexistant or negligible.
(8) Interference with shipping, fishing, recreation, mineral extraction,
desalination, fish and shellfish culture, areas of special scientific
importance and other legitimate uses of the ocean.
The proposed site is beyond shipping fairways and the normal reach of
recreational pursuits and does not support viable shellfisheries or
finfisheries. It is also a safe1distance, 90 kilometers or more,
from the 180 meter bottom contour inshore of which numerous submarine
banks of scientific interest such as the East and West Flower Garden
Banks, occur.
(9) The existing water quality and ecology of the site as determined by
available data or by. trend assessment or baseline surveys as described
in the Guidelines for Ocean Disposal Site Baseline and Trend Assess-
ment Surveys.
Data obtained from earlier studies and from monitoring observations
carried out during the 1974-75 incinerations reveal that the water
quality at the site is typical of normal oceanic Gulf waters both
chemically and biologically.
(10) Potentiality for the development or recruitment of nuisance species
in the disposal site.
It is unlikely that the growth of nuisance species of any type would
be encouraged by incineration at the site in view of the fact that
the plume products are sterile and the water quality is not changed.
(11) Existence at or near the site of any significant natural or cultural
features of historical importance.
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54
There are no known natural or cultural features of historical im-
portance located within or near the boundaries of the proposed site.
DESIGNATION OF AN ALTERNATIVE SITE
The proposed site meets or exceeds each and every one of the section 228 criteria
for site selection. Additionally, the results of the research burns indicated
that no detectable adverse environmental impacts resulted from use of the site.
Thus, no additional safeguards to the environment would be gained by studying
and evaluating additional sites in the vicinity of the proposed site.
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55
IV. ENVIRONMENTAL IMPACTS
DESIGNATION OF THE PROPOSED SITE
i
The proposed designation of a site in the Gulf of Mexico for the incineration
of highly toxic organic wastes will not of itself result in any direct environ-
mental impacts. This action merely delineates an area in the Gulf in which the
disposal of certain chemical wastes by incineration may be accomplished in the
most environmentally sound manner. The impacts that may occur would result
from the actual incineration of wastes at the site, and as such would be the
secondary impacts of the proposed action. In other words, the use of the site
for incineration does not necessarily follow from the action of designation.
The designation of the site only makes the-site available for use; the actual
use will be determined through the EPA's ocean dumping permit evaluation process,
A discussion of the environmental impacts of ocean incineration in terms of the
results of the research burns conducted at the 1974-75 ocean incineration site
by the M/V VULCANUS is provided in this section in order to better understand
the significance of the proposed action. The incineration of other chemical
wastes or the use of another vessel is possible under this proposed designation,
however, this would be subject to the testing and monitoring requirements of
the permit. Further, Section 220.3(f) states that "permits for incineration
of wastes at sea will be issued only as research permits or as interim permits
until specific criteria to regulate this type of disposal are promulgated,
except in those cases where studies on the waste, the incineration method and
vessel, and the site have been conducted and the site has been designated for
incineration at sea in accordance with the procedures of Section 228.4."
USE OF THE PROPOSED SITE
PHYSICAL FACTOR IMPACTS
Visibility. The possibility of accidental collision at the proposed
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56
site is very much reduced by the fact that the percent frequency of poor
visibility is extremely low. In addition, humidity at the site may cause
the plume to be more visible, and contributes to the visibility of the
operations.
Winds. Prevailing winds over the proposed site are from the eastern
quadrant and at a velocity such that total atmospheric dispersion of the plume
will take place before reaching land some 300 km away. This eliminates all but
the remotest possibility of any effects of the incineration plume affecting
land areas. In addition high velocity winds (hurricane speed) are relatively
infrequent and are predictable far enough in advance so that appropriate action
may be taken to suspend or defer ocean incineration operations and thus will
have minimal effect on incineration at the site. Under all but the most unusual
wind conditions, the plume will touch the sea surface within 1 to 2 nnutical
miles downwind of the incinerator ship, distances well within the site boundaries,
Currents. Current flow at the proposed site prevails-to the west or
northwest. Water movement in this direction assures additional mixing and
travel time before reaching shallow water since these waters enter a counter-
clockwise gyre west-northwest of the proposed site.
Surface Mixed Layer. The thickness of the surface mixed layer at the pro-
posed site is sufficient to provide an adequate mixing layer for the relatively
low concentrations of chemicals being added by the incineration process.
Waves. Waves should have little or no effect on incineration at the
proposed site since the percent frequency of high waves is low. In addition
high waves are sufficiently predictable from weather forecasts so that vessel
operations may be suspended or deferred.
Distance Off-shore. The proposed site is far enough removed from shore
and from commercial shipping lanes to insure incineration will have little or
no effect on (1) beach and shore recreational areas (2) unique submarine
coral banks, i.e., Flower Gardens, and (3) shipping activities.
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57
CHEMICAL FACTOR IMPACTS
From the analysis of data collected during research burns of organochlorine
wastes at the proposed site under average meteorological conditions, Wastler
et al. (1975) concluded that the constituents carried aloft in the incineration
plume that might damage the marine environment were (1) HC1, which is a major
constituent of the waste plume; (2) any organochlorines not destroyed during
incineration; and (3) trace toxic metals in the waste (copper at 510 ppb was
the metal at the highest concentration in the waste incinerated during the
first research burn).
Hydrogen Chloride. Stoichiometric calculations (EPA, 1974a; Shain, 1974),
for Shell's organochlorine wastes, which contained approximately 63% chlorine,
show that at a feed rate of 25 metric tons per hour the amount of HC1 emitted
into the atmosphere would be 4,700 grams per second (3,800 grams per second
at a feed rate of 20 metric tons per hour). The dispersal of this material
depends very much upon wind speed; therefore, to insure adequate dispersion,
permit conditions stated that the wind speed across the incinerator stacks
must be at least 10 knots to be achieved by ambient wind speed and/or ship's
speed. Aerial monitoring under these conditions showed that the lens of
maximum atmospheric concentration of HC1 (1-5 ppm) was approximately 400 to
500 meters down-wind at elevations between 120 and 250 meters above sea level
(Appendix G). Plume monitoring by the OREGON II, with a probe 6 meters above
the sea surface, showed that down-wind concentrations of HC1 generally were
in the range of 1-2 ppm. A maximum concentration of 7.3 ppm was detected
once (Appendix G). In regard to human response to HC1, the odor detection
limit is 1 ppm. In addition, Department of Labor standards allow 8 hours
per day exposure to 5 ppm HC1 (Mattern, 1975a).
Unburned Organochlorines^ At a minimum destruction efficiency of 99.9%
(required by permit) the unburned organochlorines will represent 0.1 percent
of the waste discharged to the atmosphere. During the 1974 research incin-
erations the maximum short-term peak atmospheric concentration of the major
chlorine-containing combustion product, HC1, was 7.3 ppm. Therefore, based
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58
on the stoichiometry of the incineration process, if 0.1 percent of the
waste were not destroyed the maximum atmospheric concentration of unburned
organochlorines would be approximately 13 ppb (Mattern, 1975b) . With an
effective wind velocity across the incinerator stacks of 10 knots, the
ocean surface fallout area would be 22 million square meters (18,520 meters x
1200 meters - which is 10 nautical miles x width of plume) during each
hour of incineration. Thus, with a feed rate of 25,000 kg per hour at a
minimum distruction level of 99.9 percent, the maximum fallout rate for
unburned organochlorines would be approximately 1 mg per square meter.
Assuming the mixing layer to be 20 meters thick, the above quantity would
equal 0.05 mg per cubic meter, which is substantially below the permissible
1/100 96 hour TLM concentration of 200 mg per cubic meter (EPA, 1974b).
Trace Toxic Metals. The third constituent, toxic metals, was in ver^ low
concentration in the chemical waste incinerated during the research burns.
Copper at 510 ppb was the metal present at the highest concentration (Appendix
G). At such low concentration, and considering both atomospheric and oceanic
dilution factors, no detectable increases above background levels'were expected
and indeed none were encountered (Appendix G). The amount of toxic metal
contained in wastes for disposal is closely scrutinized and permits will not
be issued if metals are in concentrations greater than the limiting permissible
concentrations as defined in the proposed Revisions to the Ocean Dumping
Regulations and Criteria (Sections 227.6, 227,7 and 227.27).
Mclntyre (1974), in discussing the top millimeter of the ocean, states
that this microlayer concentrates heavy netals such as lead, mercury, copper,
etc. and also retains slow-degrading chlorinated hydrocarbons such as DDT
and PCBs. However, if such conditions are a reality laboratory testing of
surface sea water showed that past incinerations did not alter the water
quality existing at that time. This assertion steins from the results of
water samples taken from both the up-wind control area and down-wind
fallout area of the plume during actual incineration and then analyzed
for organochlorines and heavy metals.
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59
PHYSICO-CHEMICAL ENVIRONMENTAL RESPONSE TO INCINERATION PRODUCTS
^
The three of the potentially damaging incineration products, viz., HCL,
organochlorines, and toxic metals can have immediate or short-term impacts
in the area directly affected by the plume, but they may also have long-range
impacts in the general area (Wastler et al., 1975).
Determination of pH, chlorinity, organochlorines, and trace metals were used
to evaluate both short-term and long-term effects. Phytoplankton and zoo-
plankton counts, and determination of chlorophyll-a and adenosine triphosphate
(ATP) concentrations were used to assess possible long-term effects.
SHORT-TERM EFFECTS
Changes in pH. Hydrogen chloride, acting as a strong acid could depress
the pH; however, data collected in the down-wind fallout area during research
burns at the site showed no significant pH change when compared with up-wind
control areas. In fact, the greatest change noticed was 0.15 pH unit which
represents only 1/3 of the permissible change of 0.5 pH units (see Appendix G).
Chlorinity Test. During the incineration of organochlorine wastes,
chloride ions from HC1 are permanently added to the water; but any immediate
change would be slight and unharmful since the natural background level
of chloride ion in sea water is 20,000 ppm compared with the maximum of
7.3 ppm being added. In addition, no significant difference was found
in chlorinity between in-plume and control stations by either R/V OREGON
or R/V ORCA (Appendix G).
Alkalinity Determinations. As a result of the negative findings noted
in both pH and chlorinity determinations, alkalinity was measured by R/V
ORCA during Research Burn II. Alkalinity determinations provide a very
sensitive approach to ascertaining even very small changes in the buffering
capacity of sea water, as a result in this case of the addition of HC1 to
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60
the surface waters, Again no significant changes were found, since the
fallout area test samples ranged from 2.46 to 2.56 (meq [H+]/l), whereas
the up-wind controls overlapped in a range from 2.46 to 2.48 (see Tables
IV-1 and IV-2). Note that impacts from HC1 would have caused a decrease in
in alkalinity values for the fallout area.
Organochlorine Determinations from Sea Water Samples^ Water samples
collected at control and fallout stations were analyzed for organochlorines
by two different techniques. The limit of detection of organochlorines by
the two techniques was 0.5 ppb and 25 ppb. The results of the analyses
showed no detection of organochlorines from either control or fallout
stations (Appendix G). In other words, any concentration of organochlorines'
that may have been present were far below the permissible concentration of
200 ppb (1/100 96 hour TLM).
Trace Metals. During the incineration of Shell orgaonchlorine wastes,
which were very low in toxic, metals, surface water samples were collected in
the region of maximum fallout and in up-wind control areas by the OREGON II
and the ORCA. Those collected by the OREGON were analyzed for eight toxic
metals (arsenic, cadmium, chromium, copper, lead, mercury, nickel and zinc)
and the results showed no detectable impact on the surface waters.. Samples
gathered by the ORCA were analyzed for copper and zinc (copper was used as
a tracer since at 510 ppb it was the metal present in highest concentration
in the organochlorine waste). Results of the analysis showed no significant
differences between fallout area and control stations, and thus no detectable
impact on the surface waters (see Appendix G).
Summary of Short-Term Effects. It is evident that in places where
maximal concentrations were expected, no short-term effects of plume con-
stituents upon the surface waters of the Gulf could be detected by sensitive
tests for pH, chlorinity, alkalinity, organochlorines and the eight trace
metals found in the waste feed.
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61
Table IV-1. Results obtained from samples taken during ORCA Test Run II.
Note that alkalinity values were determined here and in Control
Run II. All parameters tested by TerEco personnel (TerEco, 1975)
Date: 4 December 1974
VULCANUS Speed and Direction: 1104 to 1200 hrs - 3 knots at 090°
1200 to 1400 hrs - Adrift
when dead in water, its position was: 26 46'N, 93 39.5'W
Wind Speed and Direction: 12-14 knots from 090°
Relative Humidity: 667» (Dry Bulb 67 °, Wet Bulb 60 °F)
Time
(local)
1112
1139
1141
1213
1214
1308
1309
1311
1314
1325
1326
1328
1331
1333
1345
1351
1352
1357
Distance from
VULCANUS (n.mi.)
0.5
3.0
3.1
4.3
4.2
3.0
2.8
2.8
2.8
2.5
2.5
2.6
2.4
2.0
1.5
1.1
1.1
0.5
True Bearing
to VULCANUS
100°
097°
101°
107°
103°
087°
088°
095°
105°
092°
090°
086°
082°
091°
- . 090°
088°
091°
094°
pH
8.37
8.37
8.37
8.36
8.36
8.35
8.35
8.36
8.37
8.37
8.37
8.37
8.37
8.37
8.36
8.37
8.37
8.37
Chlorinity
(ppt)
20.05
20.12
20.07
20.07
20.10
20.07
20.10
20.19
20.12
20.05
20.10
20.10
20.03
20.03
19.94
20.14
20.10
20.07
Alkalinity
(meq [1^] /I)
2.54
2.48
2.50
2.48
2.56
2.51
2.54
2.50
2.52.
2.53
2.50
- 2.52
2.52
2.50
2.54
2.48
2.46
2.46
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63
LONG-TERM EFFECTS
Physico-chemical Responses. ^Although no short-term effects or impacts
of incineration products on the open ocean were detected during monitoring
studies of the research burns, there can be some long-term impacts from
the incineration emissions. These impacts are, of course, much more difficult
to detect in the field, especially in the case of a fluid medium that is in
continual motion. Then, too, impacts'of this type would occur primarily,
if at all, in the biota rather than in the physico-chemical system where time
would be a mitigating rather than a magnifying factor. That is to say,
in the physico-chemical system the amount of pollutants per unit volume
would decrease by virtue of mixing and transport, whereas given time organisms
might acquire steadily increasing burdens of the pollutants.
During the research burns some samplings were carried out to ascertain
whether or not such slower developing effects were occurring. A sampling
grid of 16 stations was laid out down-wind and down-current of the incineration
site to encompass the area which the plume was observed to cover during
the last 24 hours of the first burn. Sampling points were 11.1 kilometers
apart; hence, the grid covered an area of 1109 square kilometers. These
16 stations and six other control stations (up-wind, up-current) were
sampled during the OREGON'S second cruise. No significant differences were
found in pH, chlorinity, organochlorines, and trace metals between plume-
grid and control samples (Appendix G).
Biological Effects. Other tests were conducted on the phytoplankton in
conjunction with cell counts per liter of sea water. Both analysis for
chlorophyll-a and adenosine triphosphate (ATP) were run in order to determine
the relative viability of phytoplankton cells in the plume and control
areas. Since both ATP and chlorophyll break down rapidly after death of the
cell, it was reasoned that although the cell counts ger unit volume of sea
water might be the same in plume and control samples, the amounts of ATP
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and/or chlorophyll-^ might be lower in cells that had been exposed to plume
emissions than in those that had not. Analyses of 20 samples for chlor-
ophyll-a^ and 21 for ATP gave no evidence that any long-range impact from
the incineration of organochlorine wastes would occur (Appendix G).
Admittedly some conditions surrounding these experiments were less than ideal.
In the first place cell counts were very low in both control and experimental
areas, ranging between 500 to 1140 organisms per liter of water. Perhaps
more importantly, a current moves through the proposed site - a fact that
is a positive attribute of a good site, but not one that facilitates
studies of chronic effects since no parcel of water is exposed for long to
fallout and it is difficult if not impossible without special devices to
identify and sample a parcel of water after an interval of one or more
days. Such special devices are presently being tested by the EPA (see
Part VI herein).
The R/V ORCA made tows in the test and control areas for phytoplankton and
zooplankton during the early period of combustion on the second research burn •
in December, 1974. No organochlorines were detected in phytoplankton nor in
the solid phase of zooplankton samples (detection limit 3-ppm). Organochlorines
unlike those in the wastes burn at-sea were found in tar balls collected with
the zooplankton and in the liquid phase decanted from zooplankton samples.
The tar balls contained 500-900 ppm organochlorines. The liquid phases from
the zooplankton samples contained 0.2-2.0 ppm organochlorines (see Appendix G,
Table V-12). No systematic differences in organochlorine concentrations were
observed for test or control samples. Whereas the level in Test 1 was 1.4 ppm
with a control level of 0.4 ppm, the level in Test 4 was 0.2 with a much
higher control of 2.0. This appears to be related to differential amounts of
tar balls in the zooplankton samples. Shell Development Company personnel
analyzed some of the tar materials and found that the organochlorines in the
tar balls were not the same as the waste burned; they were higher molecular
weight than the organochlorines in wastes burned at-sea. In addition, analyses
for copper and zinc in plankton samples revealed nothing to indicate with
certainty that the plume fallout had caused any appreciable increases (Appendix G)
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Possible Effects on Birds. The existence of trans-Gulf migration of
birds is now an established fact. Apparently irrefutable evidence for this
phenomenon did not surface until Lowery's works were published in 1945 and
1946. Even so this type of migration was not accepted by all ornithologists,
notably Williams (1945, 1947, 1950). The negative argument was based on the
supposition that small birds (Fringillidae, for example) did not have
sufficient fat depots to make a non-stop flight. Odum and colleagues (1961)
established that if small birds have fat deposits of 25 percent of their
body weight, they have a flight range of 1200 kilometers. The distance
from.the Yucatan Peninsula to the northern Gulf coast is approximately
1000 kilometers.
Stevenson (1957) lists 76 bird species that have been observed crossing
the Gulf during the spring migration in parts of March, April and May
or the fall period during parts of August, September, and October. In
Louisiana the earliest migrants appear in the fourth week of March and
peak during early May when as many as 50,000 birds per mile of front per
day have been observed. It is questionable that these birds would near
the proposed site.
There are apparently three routes that trans-Gulf migrants follow:
(1) Lowery (1946) shows one route to be from Progreso (Yucatan) to the
Delta region; (2) Lowery and Neuman (1954) indicate a second route is
from Yucatan to a region between Corpus Christi and Freeport, Texas; and
(3) Stevenson (1957) believes that some birds winter in the Caribbean area
then cross the West Indies and the Gulf on a more or less northwesterly
route in the spring. Some of the birds following paths 2 and 3 could pass
near or over the proposed site. However, as Gusey (1974) has pointed
out, most of the migrating birds fly at elevations between 310 meters and
1530 meters where concentrations of any stack emissions would be very-low
or non-existent. It is interesting to note that during the spring migration
birds do not cross the Gulf when cold fronts are moving south over it
(Gauthreaux, 1971).
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Stratospheric Ozone. At-sea incineration} of the total world-wide
production or organochlorine wastes would not produce sufficient strato-
spheric chlorine (HCl/C^) to perturb the ozone layer (Lieder 1975) . It
would be necessary to double the stratospheric chlorine, typically 0.2 ppb
or less, to have an observable effect on plant life in certain regions of
the world. Because of low-altitude scrubbing processes which remove most of
the HC1/C12, it would be necessary to incinerate annually more than a billion
tons of organochlorine wastes to double the stratospheric chlorine concentration.
Total US production of organochlorine wastes is estimated to be 1/1000 of that
necessary to have an adverse effect on the ozone layer. Furthermore, only a
fraction of this waste would be incinerated at sea.
THE SOCIO-ECONOMIC IMPACTS
The selection and the use of the proposed incineration site in this impact
statement is expected to have only minimal socio-economic costs. Yet, the
short run and long run benefits in terms of land use may be substantial.
In the following we discuss the specific impacts on (1) beach and shore-
line recreation; (2) recreational uses of the Gulf; (3) demographic impact;
(4) economic impact; (5) land use; and (6) required public services.
Beach and Shoreline Recreation. No impact on beach and shoreline
recreation activities carried out on any of the coastlines of the Gulf of
Mexico would be expected to result from the designation of or the incineration
at the proposed site. Since the site is 305 kilometers (164 nautical miles)
from the nearest coastline it is doubtful that ocean incineration at the
proposed site will have any adverse effects upon the coastal water or beach
areas. The only possible effect would be the result of an accidental spill
in port or while the ship is underway near the coast. Any ship operating
under an EPA permit to incinerate chemical wastes must meet Coast Guard
regulations requiring protection appropriate to the hazardous cargo which
minimize loss of cargo resulting from collisions or stranding and reduce
the likelihood of sinking.
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Recreational Use of the Gulf. The effect of the designation and use of
the proposed site on sport fishing in the Gulf will be minimal. The data
indicate that none of the sport fish have been sighted in significant numbers
in the area of the proposed site. In fact, the sheer distance of the proposed
site from the nearest landfall (164 nautical miles) insures that use will
not have measurable impact because transit time to and from the area, even
in a fast fishing boat, will exceed 10 hours.
In addition, the proposed site is not near the major shipping lanes. Accord-
ingly, pleasure craft are also not likely to transit this area of the Gulf.
Even if such vessels stray into the area during a burn the concentrations
of toxic materials at any one point is such that no harm would result.
Furthermore, past permits require the incineration vessel to position itself
down-wind from any vessel other than those engaged in environmental monitoring.
Thus, the impact of the designation and use of this site will have little
or no effect on pleasure craft on the Gulf.
The only possible impact of significance of the designation and use of the
proposed site on the recreational value of the Gulf of Mexico would be from
accidental discharge of waste chemicals while the ship is in transit to the
site. Such an accidental discharge if in significant quantity would result
in a localized kill of marine life. For this reason the route of the ship
to the site will be controlled so as to keep the vessel out of recreational
areas. In addition, the design of the ship meets the Coast Guard require-
ments for carrying hazardous cargo thereby minimizing the probability of
the discharge of the cargo even if the ship is involved in accident at sea.
Population Characteristics. Neither the designation nor the use of
the proposed site will have demographic effects of any significance. The
only ship having performed incineration of chemical wastes (the VULCANUS)
in the Gulf of Mexico is of foreign flag and carries a crew of no more
than 22. These crew members would not be permanent residents of any Gulf
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Coast state. The ports in which the ships would be fueled an^ loaded are
major seaports, e.g., Houston, Corpus Christi, New Orleans Mobile, so that
the effect of the use of this ship would not significantly affect the
population of land based support personnel.
Economic Impact. The short run direct economic impact of the site
designation and its use will be minimal. The ship VULCANUS, which has
been utilized for such incineration, already exists and is of foreign
registry with a foreign crew. The loading of the ship will utilize existing
dock facilities and employees and the additional load on these facilities
is minimal due to the small amount of such waste products relative to the
tonnage of commodities already handled by these facilities. For example,
in 1974 the Port of Houston alone handled in excess of 34 million shore
tons of cargo in foreign trade. Approximately 3.4 million short tons, or
10% of this total was chemicals. These figures, of course, do not include
the large amount of domestic cargo handled by the Port. Moreover, by the
very nature of the cargo, the incinerator vessel will take on waste at the
chemical plant's private dock.
Neither the designation nor the use of the proposed site will have any
measurable economic impact on the commercial fishing and shrimping in the
Gulf of Mexico. One effect of the use of the proposed site could be a
possible temporary, minor fluctuation in commercial fishing resulting
from incineration of the chemical wastes, however, this is mitigated by
the fact that commercial fish in the Gulf are very thinly distributed in
the area of the proposed site. In addition, the concentrations of wastes
remaining after incineration are so small that little if any damage would
be done to any fish in the immediate area. Shrimping in the Gulf will
not be affected since the proposed incineration site is well beyond the
depths of the commercial shrimp industry. Even the red shrimp are not
found in significant numbers much beyond the 200 meter isobath.
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Impact on Land Use and Land Use Trends. Neither the designation nor
the use of the proposed site would have a significant impact on existing
land use or trends in land use in the Gulf of Mexico land masses. No
additional land is required for the project. The existing port facilities
are adequate for the loading of the wastes.
Land-based disposal methods require substantial land use; incineration at
sea does not. Designation of the proposed site could open the way for ocean
incineration of suitable materials that are now incinerated on land or
deep-well injected. Also, as a beneficial impact, improved air and water
quality is expected when land treatment is shifted to ocean incineration.
Public Service. Neither the designation nor the use of the.proposed
site will have impact on required public services. The loading in all
probability will be carried out from existing facilities using the existing
labor force. Thus, .no additional public services will be necessary.
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V. PROBABLE ADVERSE ENVIRONMENTAL. EFFECTS THAT CANNOT BE AVOIDED
ENVIRONMENTAL POLLUTION
FROM THE PROPOSED ACTION
The action of designating a site for incineration of organochlorine wastes
in the Gulf of Mexico will in itself have no direct effect upon the natural
environment.
FROM THE USE OF THE PROPOSED SITE
Deterioration of Air Quality
Some largely local impacts on air quality from the incineration process are
unavoidable. Among these are a large output of hydrogen chloride with far
lesser amounts of carbon monoxide, chlorine, and unburned organochlorines.
At 99.9 percent destruction efficiency of the waste, the maximum concentration
of organochlorines would be approximately 13 parts per billion. The maximum
air concentration of hydrogen chloride of 7.3 ppm was found only on one occasion
in the research burns. Most frequently values ranged between 1-5 ppm. Sea-
level concentrations of hydrogen chloride generally were in the range of 1-2
ppm several kilometers down-wind. These low atmospheric concentrations of
hydrogen chloride pose no hazard to birds or personnel in the area (Mattern,
1974a; Gusey, 1974). The concentrations of carbon monoxide and chlorine in the
atmosphere are negligible.
Within 5-10 miles of the incinerator ship acid rain from incineration could
equal or exceed that normally produced when rain washes out the naturally
occurring acidic sulfur (SOx) and nitrogen (NOx) as well as chloride in
salt spray. In this case the acid rain would be neutralized immediately
by the natural carbonates in the ocean.
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Beyond 10 miles any hydrogen'chloride remaining in the air would be so
dilute that it would be insignificant compared to naturally occurring
acidic components of the atmosphere. Aerial monitoring of at-sea
incineration in 1974 showed that the maximum concentration of hydrogen ,
chloride in the air five miles downwind was on the order of 0.1 ppm. This
concentration is much lower than the 5 ppm workplace limit for an 8-hour
exposure set by the Department of Labor (OSHA). Eight miles downwind the
concentration was below detection limits (0.005 ppm). This concentration
is lower than the concentration of other acidic components allowed under
the most stringent air standards for either SOx (60 ug/m^f 0.02 ppm)
or NOx (100 ug/rn^j 0.05 ppm). There are no specific criteria which set
limits on acidic components from salt spray.
At any greater distance than 10 miles, the effect would be even less with
continued dispersion and neutralization of that hydrogen chloride which
contacts the ocean or reacts with naturally occurring ammonia (20 ppb)
in the atmosphere. For these reasons the acidity of rainfall on coastal
locations would not be increased due to at-sea incineration in the proposed
site.
Deterioration of Water Quality
The ability of sea water to assimilate hydrogen chloride without measurable
change is well known and was clearly demonstrated during monitoring activities
of Research Burns 1 and 2. Analysis of sea water samples for organochlorines
during the research burns resulted in values somewhere below the 0.5 ppb limit
of detection using gas chromatographic-mass speccographic techniques. In
addition, surface water samples collected during the research burns showed
no significant differences in trace metals between test and control stations
under normal meteorological conditions ' (see Appendix G).
A "worst case" condition would be the rapid fallout of HC1 caused by rainfall.
Rainfall occurs less than 25 days per year at the site (United States Naval
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Oceatiographic Office, 1959). If rainfall occurred in the immediate
vicinity of the incinerator vessel, Shain (1974) has estimated for Shell's
organochlorine wastes (63% chlorine) that the maximum fallout rate of
HC1 would be between 30 and 60 grams per square meter of ocean surface. A
depression in pH would occur but would have short term and local effects
since neutralization would occur within the first few meters of the water
column. If the rain occurred directly downwind at a distance of 5-10 miles
from, the incinerator vessel, acid rain would be neutralized immediately by
natural carbonates in the ocean. At distances greater than 10 miles,
acidity due to input of HC1 from incineration of organochlorines would be
neutralized by ambient ammonia in the atmosphere.
Effects on Marine Organisms
No demonstrable short or long-term effects on marine organisms were detected
during the research burns. It is possible that some long-term (chronic)
effects may be observed when more effective means of following development
>:>£ these effects in the field are employed.
il
flOM. ACCIDENTAL SPILLAGE
*\
n\en though incineration at sea has been found to have no demonstrable
esLeterious effects upon the upper portion of the water column and its
bjota (TerEco, 1974;1975) , the possibility of environmental damage resulting
IrJ '
fiy'm an accidental spill does exist. The ocean incinerator ship could
experience adverse weather conditions which might jeopardize the safety of
the vessel. The ship could, also, be involved in a collision with another
vessel which has strayed from the shipping lanes.
The climatological conditions in the vicinity of the proposed ocean incinera-
tion site would rarely hinder the operations of a vessel which would be
operating under an EPA permit to incinerate chemical wastes . Winds ape at
their highest in November - February, averaging 13-15 knots, but pose no
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problems to sea-going vessels. Tropical storms and hurricanes are expected
to occur 43 and 26 times, respectively, within or near the incineration
site in a 100 year period, but are predictable far enough in advance to
suspend or defer ocean incineration operations. Waves should have little
or no effect on the incinerator ship, since the percent frequency of adverse
wave conditions is low and sufficiently predictable in advance to suspend or
defer ocean incineration operations. Additionally, only vessels which meet
all U.S. Coast Guard requirements for the transport of chemicals at sea would
be permitted to operate under an EPA permit to incinerate chemical wastes.
The usage of the site will be stricted to one incinerator ship at a time,
except under extreme emergencies.
The same Coast Guard requirements for vessel construction safety, and opera-
tion will also ensure the maximum protection against loss of ship or cargo
in case of a collision, stranding, or other vessel casualty. As further
protection against collisions within the proposed site, the EPA will request
a "Notice to Mariners" to be published by the Coast Guard prior to each use
of the site to warn vessels that the site is in use. As an additional
protection the proposed site has been located greater than 75 kilometers
from the nearest shipping fairway to reduce the likelihood of vessels
straying into the proposed site from charted fairways.
The possibility of the vessel's accidental collision, stranding, or sinking
while loaded with chemical wastes is of considerable environmental concern.
Such an accident could occasion moderate or serious consequences, depending
in large measure upon where it occurred. For instance, a major spill near
shore affecting an estuary would destroy many organisms (including bottom-
living forms) and contaminate the area for a substantial period of time. A
spill on the continental shelf could have a significant short-term impact on
the organisms, however, the wave and current actions would greatly disperse
the contaminant and the large volume of water would dilute the contaminant,
thus significantly reducing the long term-impacts at the site.
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In the event that the preventive measures mentioned above fail to preclude
an accident situation from developing, the U.S. Government is working both
nationally and internationally do develop the measures necessary to prevent,
mitigate, or eliminate the danger to the marine environment from such an
accident causing pollution by substances other than oil. Nationally, there
is a bill before Congress to amend the Intervention on the High Seas Act
(P.L. 93-248) to include the authority to intervene on the high seas in
the case of a marine casualty involving substances other than oil, such as
chemical wastes, which threaten to endanger the coastline or related interests
of the United States. The bill would implement the Protocol Relating to
Intervention on the High Seas in Cases of Marine Pollution by Substances
Other than Oil, 1973. Internationally, the U.S. Government is participating
in the United Nation's Intergovernmental Maritime Consultative Organization's
Marine Environment Protection Committee (MEPC).' The MEPC is developing
guidelines for possible intervention under the 1973 Intervention Protocol.
The guidelines would establish a recommended procedure by which the assess-
ment of grave and imminent danger of pollution damage could be made. The
assessment would include the identification of the circumstances of the
casualty, the environmental situation, the possible pollution damage, and
the type of intervention proposed to be undertaken. If it is determined that
the vessel operator in the case of a marine casualty threatening the coast-
line or related interest of the U.S. is not taking adequate measures to
counter the grave and imminent danger of pollution determined by the assess-
ment, the U.S. would be able to take whatever measures necessary to prevent,
mitigate, or eliminate the danger.
For further information regarding regulations for the protection of the
marine environment from pollution due to chemical tank vessel operations,
the reader is directed to the Maritime Administrations Final EIS on
Chemical Waste Incinerator Ship Project.
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FROM PRESENCE OF INCINERATOR VESSEL AT THE PROPOSED SITE
The incinerator vessel will produce engine exhausts that will have some
minor impacts on both air and water quality. Actually the vessel will use
far. less fuel on the site than a vessel in transit. This results from the
fact that sufficient wind ordinarily blows across the site to meet the permit
requirement for an effective 10-knot movement of air across the incinerator
stacks.
INTERFERENCE WITH OTHER ACTIVITIES AT THE PROPOSED INCINERATION SITE
SHIPPING
The proposed site is at least 75 kilometers from the nearest shipping
farway; hence it poses no problem to vessels moving across the Gulf.
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COMMERCIAL FISHING
The site is far seaward of the continental shelf and of any shrimp or other
bottom fishing activity. At the present time a commercial fishery for pelagic
fishes has not been established in the site. It is not likely that it will
be. Moreover, it is unlikely that incineration would interfere with such
activities in any significant manner.
SPORT FISHING AND OTHER RECREATIONAL ACTIVITIES
Remembering that the site is over 300 kilometers offshore, it is highly un-
likely that any but an occasional sport fishing vessel or a sailing vessel
out of Galveston for recreation would ever transit the area. No serious
effects would result in any event, since the incinerator vessel is required
to orient itself down-wind should such a vessel occasion to pass nearby.
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VI. RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF THE
ENVIRONMENT AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY
\
During the organochlorine waste incineration tests in the Gulf of Mexico,
the EPA undertook a sampling and analysis program to acquire, the data neces-
sary for evaluating the incinerator waste destruction efficiency. Although
these efforts provide an assessment of the acute effects of incinerating
organochlorine waste, a better understanding of the potential long-term
effects of ocean incineration is needed. Evaluation of long-term effects
is dependent upon the advancement of at-sea monitoring technology which is
in its early stages of development.
To enable refined analysis of the potential for long-term impacts of ocean
incineration, the EPA is developing a test program which will serve three
purposes:
A. Evaluate a test protocol for ocean incineration based on a similar
protocol developed for land incineration. If successful, the test pro-
tocol may then be used to standardize source assessment equipment and
techniques for monitoring ocean incineration.
B. Conduct tests to determine if additional criteria for stack gas
emissions are needed which could serve as guidelines for limiting
emissions, if appropriate.
C. Acquire additional information to determine if further assessments
and evaluations of potential long-term impacts to the environment are
required.
The test program being developed for the incineration process at sea is based
on recent studies of land-based incineration sponsored by the EPA and other
Federal agencies. These studies have resulted in the development of a method-
ology to characterize the effluent from organochlorine incineration and the
adequacy of new waste incineration technology. This new methodology, if
successfully applied to ocean incineration, would extend the current state-
of-the-art for the monitoring incineration at sea. Each new incinerator design
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and each category of waste with, different thermochemical properties could
then be evaluated by a single standard or protocol thus providing a uniform
basis of comparison of the projected impacts to the environment.
The EPA has also undertaken a test program to develop floating enclosures
called Biotal Ocean Monitors (BOMs) in which studies of the long-range impacts
of ocean disposal of industrial and municipal wastes can be performed. The
BOMs range in size from 4 to 21 feet in diameter and 14 to 42 feet long. They
consist of cylinders constructed of woven nylon mo nofilament fabric each of
varying size mesh to retain large fishes and invertebrates (1000-micron mesh),
small fishes (500-micron mesh), zooplankton (76-micron), phytoplankton (37-
micron), and nannoplankton (10-micron). The BOMs permit ambient waters and
their chemical burden to circulate freely through the cylinder fabric. The
BOMs would be placed at disposal sites during ocean disposal activities and
filled with representative species, which would be checked for viability every
48-hours, while larger organisms would undergo histological examination for
indications of cellular deterioration.
The BOMs would be used primarily to ascertain whether or not incipient chronic
responses of test organisms occur as a result of burn products and residues
entering the surface waters of the ocean. In addition, investigations would
be directed toward determining whether or not changes in pH and chlorinity
of exposed surface waters occur as a result of plume fallout.
In addition to the test programs outlined above, the sits selection and manage-
ment criteria of Section 228 will ensure that the marine environment at the
disposal site is not overstressed during its use. The disposal site use will
be regulated by setting limitations on times of disposal and rates of dis-
charge, establishing a disposal site monitoring program, and modifying the
disposal site use based on annual evaluations of disposal impact.
The primary purpose of the monitoring program will be to evaluate the impact
of disposal on the marine environment by referencing the monitoring results
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to a set of baseline conditions. EPA management authority will develop and
maintain monitoring programs for the continuing evaluation of the disposal
site* If the disposal site is used on a continuing basis, such programs
may consist of trend assessment surveys conducted at intervals frequent
enough to assess the extent and trends of environmental impact and special
studies conducted by the permittee to identify immediate and. short-term
impacts of the disposal operation. These surveys may be supplemented, where
feasible and useful, by data collected from the use of automatic sampling
buoys, satellites, and from experimental programs.
The determination of the overall severity of disposal at the site on the
marine environment will be based on the evaluation of the entire body of
pertinent data. The use of the disposal site may be limited or terminated
based on the impact of disposal at the site and impact classification system
criteria. The basic rationale for the impact classification system is that,
some changes in the composition of water and sediments may be tolerated, but
any significant sign of damage to any of the biota may be a forerunner of
adverse changes affecting the entire ecosystem and steps should be taken to
reduce waste loadings to levels at which no changes in the biota are detectable.
Thus; the EPA recognizes that there is some impact on the biota that may presage
some form of significant long-range impact and regards this level of impact as
being "unreasonable degradation" and will take appropriate steps to preclude
this from happening.
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VII. IRREVERSIBLE AM> IRRETRIEVABLE COMMITMENTS OF RESOURCES
The action of designating a proposed incineration site for chemical wastes
in the Gulf of Mexico does not constitute a commitment of any physical or
biological resource in an irreversible or irretrievable manner. The use of
the proposed site would not involve the irrevocable use of resources other
than fuel, that quantity required to drive the incinerator vessel and the
small amount required to bring the incinerator to proper operating temperature.
Neither the action nor the use would involve changes in land use, destruction
of archaeological or historical sites, or unalterable disruptions in ecosystems.
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VIII. LITERATURE CITED IN TEXT AND IN APPENDICES A-F
ABBOTT, R. and T. J. BRIGHT. 1975. Benthic communities associated with nat-
ural gas seeps on carbonate banks in the northwestern Gulf of Mexico.
Report for study of naturally-occurring hydrocarbons in the Gulf of
Mexico, Texas A&M Univ. , Oceanogr. Dept. Tech. Rept. 191p.
ADELMANN, H. C. 1967. The taxonomy and summer and fall vertical distribution
of the Chaetognatha off Galveston, Texas. Texas A&M Univ., Biology
Dept. Ph.D. dissertation, 108p.
ANDERSON, G. C. 1969. Subsurface chlorophyll maximum in the northeast Pacific.
Limnol. Oceanogr. 14: 386-391.
ANTOINE, J. W. 1972. Structure of the Gulf of Mexico, p. 1-34. In R. Rezak
and V. Henry, (eds.), Contributions on the geological and geophysical
oceanography of the Gulf of Mexico. Texas A&M Univ. Oceanographic
Studies, vol. 3. Gulf Publ. Co., Houston, Texas.
ANTOINE, J. W. and W. R. BRYANT. 1968. Major transition zones of the Gulf of
Mexico: DeSoto and Campeche Canyons. Trans. Gulf Coast Assoc. Geol.
Soc. 18: 55.
ANTOINE, J. W. and W. R. BRYANT. 1969. Distribution of salt and salt struc-
tures in Gulf of Mexico. A.A.P.G. Bull. 53(12): 2453-2550.
ARNOLD, E. A., Jr. 1958. 'Gulf of Mexico plankton investigations 1951-1953.
U. S. Fish Wildl. Serv. Spec. Sci. Rept. Fish. No. 269: 53p.
AUSTIN, H. M. 1971. The charactersitics and relationships between the calcu-
lated geostrophic current component and selected indicator organisms
in the Gulf of Mexico Loop Current System. Ph.D. dissertation, Oceanogr.
Dept., Florida State Univ. 369p.
BADLEY, J. H., A. TELFER, and E. M. FREDRICKS. 1975. At-sea incineration of
Shell Chemical organic chloride waste, stack monitoring aboard the
M/T "Vulcanus". Technical Progress Report BRC-CORP 13-75-F. Shell
Development Co., Bellaire Research Center, Houston, Texas.
BAGG, A. M. 1948. Barometric pressure-patterns and spring migration. Auk,
65: 147.
BAIRD, R. C. 1971. The systematics, distribution and zoogeography of the •
marine hatchetfishes (Family Sternoptychidae). Bull. Mus. Ccmp. Zool.
Harvard 142(1): 1-128.
BALECH, E. 1967. Microplankton of the Gulf of Mexico and Caribbean Sea.
Texas A&M Res. Found. Ref. 67-10-T, 144p.
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BALLAKD, R. D. and E. UCHUPI. 1970. Morphology and Quaternary history of the
continental shelf of the Gulf coast of the United States. Bull. Mar.
Sci. 20(3): 547-559.
BENNETT, F. M. 1909. A tragedy of migration. Bird-Lore 11: 110-113.
BERKOWITZ, S. P. 1976. A comparison of the neuston and near-surface zooplank-
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the Caribbean Sea and Gulf of Mexico, Vol. II - Marine environment.
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D. C., 190p.
U. S. NAVY HYDROGRAPHIC OFFICE. 1959. Climatological and oceanographic
atlas for mariners. Vol. I. North Atalntic Ocean. Washington, D. C.
U. S. NAVY HYDROGRAPHIC OFFICE. 1972. Atlas of pilot charts, central Ameri-
can waters and South Atlantic Ocean. Washington, D. C.
VENRICK, E. L. , J. A. McGOWAN, and A. W. MANTYLA. 1973. Deep maxima of
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41-52.
VOSS, G. L. 1967. The biology and bathymetric distribution of deep-sea
cephalopoda. Stud. Trop. Oceanogr., Inst. Mar. Sci. Univ. Miami
5: 511-535.
WASTLER, T. A., C. K. OFFUTT, C. K. FITZSIMMONS, and P. E. DesROSIERS. 1975.
Disposal of organochloride wastes by incineration at sea. U. S.
Environmental Protection Agency. EPA-430/9-75-014.
WATKINS, J. S., J.^L. WARZEL, M. H. HOUSTON, M. EWING, and J. B. SINTON.
1975. Deep seismic reflection results from the Gulf of Mexico:
Part I. Science 187: 834-836.
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95
WILHELM, 0. and M. EWING. 1972. Geology and history of the Gulf of Mexico.
Geol. Soc. Amer. Bull. 83(3): 575-600.
WILLIAMS, G. C. 1945. Do birds cross the Gulf of Mexico in spring? Auk, 62:
98-110.'
WILLIAMS, G. C. 1947. Lowery on trans-Gulf migration. Auk, 64: 217-237.
WILLIAMS, G. C. 1950. The nature and cause of the coastal hiatus. Wilson
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M
WUST, G. 1964. Stratification and circulation in the Antillean - Caribbean
basins. Part. 1: Spreading and mixing of water types. Columbia Univ.
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ZAITSEV, Yu. P. 1970. Marine neustonology. Transl. Israel Program for Scien-
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Second Revised Edition, 1963, Interscience Publishers
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96
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97
IX. COMMENTS AND RESPONSES
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OIF °7f I
TIGS AS
:L,. .HI/, x,
Ma. 4, 1976
Mr. Kenneth E. Biglani, Director
Oil and Special Mate.1 ials Control Division
Office of Water and Hazardous Materials
Environmental Protection Agency
Washington, D. C. 20460
Dear Mr. Biglane:
We appreciate the opportunity you have given us to
comment on the draft impact statement on the designation
of a site in the- Gulf of Mexico for incineration of chemi-
cal wastes. Vt have reviewed the document and we feel
that the proposed procedure with regard to issuing permits
is reasonable.
We, at tr e Texas Attorney General's Office, feel
that we are in full agreement on this matter and we would
like also to take the opportunity to commend you on the
valuable material published in your July, 1975, report on
the disposal of organochlorir.e wastes by incineration at
sea.
Pleast? keep us informed on any developments on any
offshore inc.ineration matters in the Gulf of Mexico. Thank
you for your cooperation.
Sincerely years,
John Malouf, Ph.D., P.E.
•i-pecial Environmental...Assistant
: o the Te::as Attorney General
JM/lf
An Equal Opport - nity Employer
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Response to let-bar of May 4, 1976, from the Attorney General of Texas
Garments on the Draft EIS by the Attorney Generals Office!
are hereby noted.
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National Wildlife Federation
2 16TH ST, N.W., WASHINGTON, D.C. 20036 Phone: 202—797-6800
May 13, 1976
Mr. Kenneth Biglane
Director, Oil & Special
Materials Control Division (WH-5^8)
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Re: Comments on EPA Draft Environmental Impact
Statement on "Designation of a Site in the
Gulf of Mexico for Incineration of Chemical
Wastes"
Dear Mr. Biglane:
The National Wildlife Federation has a number of recommen-
dations for improving the above-noted site designation EIS. These
recommendations concern the need to spell out in some detail the
types of wastes which EPA deems suited and unsuited for ocean
incineration, anticipated levels of use of the site once it is
designated (beginning with Shell's pending application), potential
long-term ocean incineration impacts, the availability of alternatives
to ocean incineration of organochlorine wastes (e.g., exhaustive
chlorination and UV photolysis), the potential use of an open-water
ocean incineration site in the South Atlantic as opposed to .a site
in the semi-enclosed Gulf of Mexico, the nature of and restrictions on
the types of fuel oils 'to be used as supplementary fuels for ocean
incineration (and the nature and implications of sulfur and other contami-
nants which may be present in these fuel oils), and the possibility
of taking steps to either locate the ocean incineration site totally
outside of migratory bird pathways, or of restricting ocean incineration
to times of the year during which bird migration does not occur.
\J Our first criticism of the DEIS is that it is too abstract.
Although everyone connected with its preparation realizes that Shell
Chemical Company is waiting in the wings to ocean-incinerate
additional shiploads of organochlorine wastes, the Impact Statement
makes no reference to Shell's pending (or held-in-abeyance) application
for an ocean dumping permit. What are Shell's Immediate and long-term
plans for the proposed ocean incineration site? What information does
EPA have on the plans of other waste-generators to make use of an
ocean-incineration site in the Gulf of Mexico? How does the location
of the proposed site relate to the locations of the most likely potential
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National Wildlife Federation
Mr. Kenneth Biglane
May 13, 1976
Page Two
users of ocean, incineration? Is the proposed site accessible to potential
users other than Shell (which plans to ocean-incinerate wastes from its
Deer Park, Texas plant)? What is the bearing of the Maritime Admin-
istration's "Chemical Waste Incinerator Ship Project" on the likely need
for and future impacts of an incineration site in the location proposed?
What is the status and relevance of the Air Force's one-time plans to
ocean-incinerate Agent Orange herbicide stockpiles?
One unfortunate consequence of the Impact Statement's abstractness
is the inability to assess long-term consequences of ocean incineration
at the proposed site. Although the Impact Statement acknowledges (p. 72)
the possibility "that some long-term (chronic) effects may be observed
when more effective means of following development of these effects in
the field are employed," the Statement wrongly concludes (p. 77) that
"[ejvaluation of long-term effects is dependent upon the advancement of
at-sea monitoring technology ...." While it may well require improved
technology to allow the measurement of long-term changes, the evaluation
(i.e., assessment, projection) of long-term consequences requires no
more than estimates of how much of various materials is likely to be
ocean-incinerated in a given time-frame, expected levels of resultant
unburned combustion residues, and projected buildups of persistent
residues. The Impact Statement reflects no effort even to assess
industry interest in and/or demand for ocean incineration. It may be
that meaningful information of this kind simply cannot be obtained — in
which case the Impact Statement ought to consider the long-term impacts
of several hypothetical levels of ocean incineration at the proposed
site. This would at least furnish EPA and readers of the EIS with some
concrete range of potential long-term impacts.
The Impact Statement's lack of specificity is especially
serious, in terms of rendering evaluation of impacts difficult, in its
failure to indicate the waste types which EPA will and will not regard
as suitable candidates for ocean incineration. Concentrated organo-
chlorine wastes (which are persistent and highly toxic, have a high
fuel value, and are subject to nearly complete combustion) are almost
ideal candidates for ocean incineration (at least, where recycling and
other methods of destruction are not feasible). Dilute wastes with
significant levels of heavy metals are, on the other hand, good examples
of wastes which should not be ocean-incinerated (because heavy metals
are not subject to thermal breakdown and because of the poor fuel value
of dilute wastes). The criticism (by EPA's Office of Federal Activities)
of the Maritime Administration's DEIS on its incinerator ship project,
for implying that "the successful results of testing [of ocean incinera-
tion of organochlorine wastes] in the Gulf of Mexico indicate acceptability
of the process for all candidate chemicals," applies no less to the
present DEIS. The Impact Statement's passing reference (on p. 59) to
the assertion that "permits will not be issued if metals are in concen-
trations that would cause detriment to the environment" should be expanded
and clarified.
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National Wildlife Federation
Mr. Kenneth Biglane
May 13, 1976
Page Three
In a related vein, the Impact Statement ought to discuss
EPA's timetable for developing specific ocean incineration criteria
as part of its present ocean dumping regulations and criteria. Many
provisions of the ocean dumping criteria (both the present and the
draft revised versions) would be difficult or impossible to apply to
ocean-incinerated wastes (e.g., the "limiting permissible concentration"
criterion). The EIS should indicate when ocean incineration criteria
can be expected and what steps will be taken in the meantime (e.g.,
limitation of approvals to interim and research permits) to ensure
adequate screening of candidates for ocean incineration.
Ocean incineration for the foreseeable future will likely
be confined (and properly so*) to organochlorine wastes. This being
the case, the Statement ought to address (at least in general) the
availability of alternatives to ocean-incineration of such wastes,
including: incineration on land, exhaustive chlorination, ultraviolet
photolysis, etc. It should be noted in this regard that the October 9,
197^ Report of the Presiding Officer (Taylor 0. Miller) on the EPA
Public Hearing held on October 4, 1974 in Houston, made specific
reference to the possibility of "chemical conversion of the chloro-
carbon wastes into useful and marketable chemicals through a process
termed exhaustive chlorination" (p. 32), expressing the view that
"[fjurther study of these possibilities may prove useful in the long
run." As we noted in our August 22, 1975 letter to the Region VI
Administrator on Shell's reapplication for ocean incineration permit,
any reason or justification for precipitous action which may have
surrounded the initial at-sea incineration of Shell wastes no longer
exists. "Alternatives must be carefully weighed and ocean incineration
chosen only if it really is the best approach." The present- Impact
Statement should spell out the kinds of alternatives which must be
considered and ruled out before ocean incineration can be seriously
entertained by EPA for organochlorine waste generators.
Three other matters should have been addressed or addressed
more fully in the Impact Statement.
The Statement should have considered as an alternative at
least the designation of an ocean-incineration site in the South
Atlantic. Such a site would have the signi'ficant advantage over a
Gulf of Mexico site of not being within a semi-confined body of water.
The Impact Statement's attitude that, because no short-term impacts
were found in one series of Gulf of Mexico burns it is not necessary
to look elsewhere, is not a sufficient basis for failing to consider
other, potentially even better, options. Although no law compels EPA
bo always choose the best of a range of environmentally acceptable
options, nothing in NEPA allows an EIS's discussion of alternatives
to stop once one environmentally acceptable alternative has been
identified. Clearly, all reasonably available alternatives must be
considered.
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National Wildlife Federation
Mr. Kenneth Biglane
May 13, 1976
Page Four
7j The Statement should also have given at least some attention
to the supplementary fuels to be used to get ship-borne incinerators
up to operating temperatures and, if necessary, to sustain combustion and
keep operating temperatures in the proper range. The grades and
characteristics of fuel oils which could be used for this purpose vary
considerably, with correspondingly variable potentials for environmental
impact. The EIS should discuss or specify the types and characteristics
of fuels (e.g., in terms of sulfur and heavy metal contents) which may
or must be used in ship-borne incinerators.
Finally, the Impact Statement dismisses rather summarily
(pp. 65, 71) the potential for adverse impacts of ocean incineration
on birds migrating across the Gulf of Mexico. Louisiana officials had
expressed great concern over this potential in connection with the
ocean incineration of Shell Chemical Company organochlorine wastes.
The EIS should, at minimum, more fully document its assertion that
emissions from incinerator ships at the proposed disposal site "pose
no hazard to birds ... in the area." Among other things, the Statement
should provide data on levels of HC1 which are irritating and
damaging to birds and on the likelihood of their actively avoiding HC1
plumes which they may encounter. One ornithologist has suggested to
us, for example, that migratory birds may be so intent on migrating
that they would probably fly right through such a plume. The Statement
should also discuss the feasibility of designating an incineration
site (e.g., in the South Atlantic) which would totally eliminate the
risk of interference with migration patterns, as well as of specifying
permissible and impermissible times of the year for conducting burns
to avoid overlap with periods of migration.
Copies of EPA's February 7, 1976 comments on MarAd's DEIS
and the National Wildlife Federation's August 22, 1975 comments on
Ocean Dumping Public Notice No. 730D008E are attached hereto and
incorporated by reference herein.
We appreciate the opportunity to express these views and
request that we be sent a copy of the final impact statement, when
available, which we trust will be responsive to our concerns.
Si/ic-erely,
KSK: j b 'Kenneth S. Kamlet '''"'""'""'
Attachments (2) Counsel
cc: Mr. John C. White
Regional Administrator, Region VI
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National Wildlife Federation
16TH ST , N.W , WASHINGTON, D.C 20036 Phone: 202-483-1550
August 22, 1975
Mr. John C. White
Regional Administrator
Region VI
1600 Patterson
Dallas, Texas 75201
Re: Ocean Dumping Permit Application by Shell
Chemical Company, July 30, 1975 Public
Notice (Application No. 730D008E)
Dear Mr. White:
In accordance with the invitation to comment contained in
the above Public Notice, the National Wildlife Federation wishes to
make the following points:
1. Although Shell has applied for a "special permit" to
ocean-incinerate its organochlorine wastes, there is no means at
the present time for determining whether Shell can satisfy the rather
specific requirements laid out in the ocean dumping criteria for
obtaining such a permit. Wastes of the Shell type (both before and after
incineration) must meet "the limiting permissible concentration of
total pollutants" (as defined in 40 CFR § 227-71) before they may be
disposed of at sea under a special ocean dumping permit. The "LPC"
in turn, is defined in terms of bloassay tests carried out on "appro-
priate sensitive marine organisms ... in accordance with approved
EPA procedures", and a computation of "mixing zone" size. Although the
Shell wastes might well meet any reasonable "LPC" standard that was
imposed, the fact is that the present ocean dumping criteria are net
capable of establishing an "LPC" value for wastes that are incinerated
at sea. It necessarily follows, therefore, that since one cannot
even define the "LPC" for incinerated Shell waste, one certainly has
no basis for deciding whether the "LPC" value, has or has not teen
exceeded. Compliance with the "LPC" limitation being the sine qua non
of special permit receipt, EPA is simply precluded from giving Shell a
special ocean dumping permit. This need not affect Shell's ability to
obtain an "interim ocean dumping permit", however. -Indeed, given the
Interim nature of Shell's plans for ocean incineration (i.e., only
until a land-based incinerator becomes operational in mid-1977), the
interim permit approach makes more sense anyway (and does not prejudice
Shell's interests in any way). Accordingly, we recommend that Shell
be considered for, at most, an interim ocean dumping permit.
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Wildlife Federation
•t P. 11 e
1975
2. Oiven EPA's tentative determination to prepare an
Envlr^nr.rttta] Impact Statement, on the proposed ocean incineration
site r,e"ore taking further action on Shell's permit request, it
seems a bit anomalous that the period for public comment on Shell's
application should be cut off 30 days after issuance of tho public
notice. If public comment on the Shell application is to be mean-
ingful =nd informed, the opportunity for comment must continue until
the contemplated EIS is completed and there has been time to review it.
We, therefore, propose that either the period for comment on the
July 30, 1975 public notice be extended until at least 30 days following
the filing of the final EIS, or, alternatively, that a brand new
public notice be issued, with additional time for public comment,
upon completion and filing of the FEIS.
3. While we applaud EPA's decision to precede its desig-
nation of an ocean disposal site with an EIS, as required by applicable
regulations, we would urge that the EIS not be narrowly limited in
its scope to matters related solely to the properties of the site and
the anticipated impacts of ocean incineration at the site. At the
very least, the EIS should carefully consider the need for designating
this ocean incineration site in the first place, in terms specifically
of the availability of non-thermal processing alternatives for wastes
of the Shell type. Exhaustive chlorlnation and ultraviolet irradiation
are among the processing approaches that should be explored. Other
techniques, investigated In connection with Air Force plans to ocean
incinerate stores of Agent Orange herbicide (an organochlorine compound
not unlike Shell's waste-mix), appear to have made ocean incineration
unnecessary In that case. These should be considered here, as well.
Since we understand that EPA headquarters has undertaken to prepare
the EIS for the Shell site designation, a copy of this letter is
being sent to Messrs. Biglane and Wastler of the Water Program Operations
division at EPA headquarters.
In conclusion, while the National Wildlife Federation supported
the ocean incineration of Shell wastes under the applicable circum-
stances of a year ago, it is our firm view that each new ocean
incineration proposal must be closely scrutinized, and should be
approved only if it is best for the environment and public health.
Unlike a year ago, we no longer have a binding contract between
Shell and the Vulcanus entered into In good faith at a time when EPA's
regulatory Jurisdiction was ambiguous. Above all, there is no longer
any reason or justification for precipitous action. Alternatives
must be carefully weighed and ocean incineration chosen only if it
really is the best approach. The fact that it was successfully used
before is not enough. That is where the Inquiry must begin, not end.
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.tonal Wildlife Federation
..'I 22, 197'
Although, the Shell public notice was somehow never sent
to u.v by Region VI (.-cne'or.e else called it to our attention), we
nevertheless appreciate tne opportunity to express our views on
t hi.- natter.
Very truly yours
J v_> MA o •
I-KJur
Kf-nnet:, S. Kamlet
Counsel
^r. Kenneth Biglane
I-'r. T.A. Wastler
James Rogers, Esq.
'iark Chandler, ESQ.
"'lr. Robert E . A p p 1 c-
^r. P.H. Farrar
Mr. Cecil Reid
Richard Stai.eK
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
7 FEB 1376
OFFICF Or TH£
ADMINIS1 RATCft
Captain George Steinman
Chief of the Environmental Group
Maritime Administration
U.S. Department of Commerce
Washington, D.C.' 20235
Dear Captain Steinman:
The Environmental Protection Agency (EPA) in accordance
with its responsibilities under the National Environmental
Policy Act and Section 309 of the Clean Air Act has
completed its review of the Department of Commerce draft
environmental impact statement entitled, "Chemical Waste
Incinerator Ship Project." Our general and specific
comments are enclosed.
We are concerned that the environmental impact
statement (E1S) docs not present adequate information to
evaluate the impacts of projects other than the incinera-
tion of organochlorides on the VULCANUS. The implication
in the EIS is that the successful results of testing in
the Gulf of Mexico indicate acceptability of the process
for all candidate chemicals. Since the list of candidate
chemicals encompasses a wide range of characteristics,
issuance of an EPA permit will be predicated on the basis
that, each chemical to be incinerated has been fully
tested to assure safe disposal by incineration at sea.
The safety and control measures that are presented
as mitigative features do not specifically address the
case of a chemical incineration ship. We are concerned
that the EIS does not discuss those measures that will
be applied to the proposed action. The impression given
is that any or all of these measure*; may apply, but those
that definitely will are not known at this time. In
particular, the IMCO Code for the Construction and
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Equipment of Ships Carrying Dangerous Chemicals in Bulk
and the 1973 Convention for the Prevention of Pollution
from Ships have not been ratified or come into force, and
the provisions listed arc not now in effect.
In accordance with our procedures for rating impact
statements, we have placed this statement in category
ER-2. A description of our rating system is enclosed.
Thank you for the opportunity to participate in the
review of this proposed action.
Sincerely yours,
Rebecca W. Hanmer
Acting Director
Office of Federal Activities
A-104
Enclosures
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Environmental Protection Agency
Comments on the
Marine Administration
Draft EIS for the
Chemical Waste Incinerator Ship Project
General Comments
\
The draft Environmental Impact Statement (EIS) provides information
that has been developed from the incineration test burn of organo-
chlorin*? waste from the Shell Chemical Company conducted in the Gulf
of Mexico during October 1974 through January 1975. While these tests
generally support the conclusion that thermal oxidation of the organo-
| chlorines can achieve efficiencies greater than 99. 9%, they do not
adequately reflect the kinds of conversion ratios that can be expected
with other chemical wastes that may be encountered.
Since the waste characteristics of the chemicals to be incinerated can
vary considerably, we believe that the EIS should provide a detailed
discussion of the procedure by which a specific waste %vill be evaluated
for an ocean disposal permit. Of particular interest during the evalua-
tion of a permit application will be the information on the chemical
wastes that are candidates for incineration as well as the toxicity
information of all potential products of combustion before the full
scale incineration process takes place. This information will require
testing and monitoring of small amounts of the candidate chemical
wastes in the specific incinerator, either land based or shipboard,
before full scale disposal procedures are carried out.
•
2. The final EIS should state that a site specific EIS will be prepared by
EPA for each proposed disposal area prior to the issuance of an EPA
disposal permit. Although EPA. through the VULCANUS permit,
authorized the incineration of one type of waste with one incinerator
• design, inference should not be of a blanket approval.
3. The need for, and future use of, incinerator ships for the disposal of
chemical wastes have not been adequate!}' discussed. Specifically, the
economic viability and demand for incinerator ships have not been
analyzed, nor have the effects of possible phasing out of the ocean
dumping program been discussed. Before a commitment is made for
Federal assistance for these ships, these factors should be analyzed.
4. The section on safety and control measures is merely a synopsis of
acts, regulations, and international conventions and codes that may
apply to chemical incinerator ships. No specific recommendations
are made, nor are the aspects of the measures that will specifically
apply made evident. We suggest that this section be rewritten to
reflect only those mitigative measures that are relevant to chemical
incinerator ships. Other regulations and international conventions
which will become applicable for n<:"/ shirks upon ratification or coming
into force.- at some future date should be- discussed under a separate
heading, if so desired.
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Specific Comments
Pg. 1-1 The statement is made that the VULCANUS has been success-
fully used in Europe for several years. The only records of
successful operation presented in the EIS are from the tests
performed in the Gulf of .Mexico. Data from operations in
Europe should be included to explain the statements about
its'previous operations.
Pg. 1-12 The statement that compliance with IIMCO requirements
guarantees that no unprocessed wastes will reach the sea
conflicts with the statement on page 1-14, which allows for
emergency discharge of cargo in accordance with International
regulations. A qualifying statement is needed on page 1-12.
•An estimate should be made of the quantities of gas or diesel
oil that will be used to establish and maintain combusion
: temperatures.
According to the EIS the proposed incineration ship will not
need a scrubber because the incineration achieves 99. 9% com-
bustion and I1C1 omissions will not impact adversely on the
/ ocean environment. Assuming that 99. 9% efficiency is main-
tained, we would agree with this' argument. However, if a
flame-out, pump failure, or some other type of mishap occurred
which causes the efficiency to drop, harmful emissions would
escape unchecked into the environment. Considering the very
nigh feed rates proposed for these incinerators (20 tons/hr. ),
! .even a small or short-lived drop in efficiency could create a
, .considerable environmental impact.
Therefore, without the insurance provided by scrubbers, such
problems must be prevented by other means. As a minimum,
we would suggest the following steps.
1. In order to achieve efficient combustion, the air and fuel
must be thoroughly mixed and exposed to a high temperature
for as long as possible. The risk of inadequate mixing is
even greater in incinerators of the size proposed. Thus,
the design should employ some1 type of turbulence enhancing
devices to improve the mixing characteristics. Examples
of such devices include baffle systems and tangential firing.
Another feature which would improve the design would be an
air pre-heat. The combustion air fed into an incinerator has
a significant cooling effect on the temperature in the combus-
' tion chamber. Cold air can even have a quenching effect when
it contacts the flame. Thus, an__air pre-heat would aid in main-
taining the temperature and provide more efficient combustion.
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2. We strongly support the stated plans to automatically monitor
the temperature and feed rates. In addition to the EPA
recommendations in Appendix IV, the stack emissions should
be continuously monitored with on-line analyzers for key
compounds such as CG^, HC1, and metals. Both the tempera-
ture monitors and the on-line analyzers should be used to
activate an automatic waste feed cut-off in the event an unsafe
temperature or emission level is detected.
3g. 1-13 According to the EIS, the fumes from the combusion process
will fall into the immediate wake of the vessel by design and
will be completely mixed and diluted with sea water. Page 4
and Firure V-5 of Appendix IV, however, described a plume
extending considerably beyond the wake of the ship. The
statement on page 1-13 should be corrected.
'g. III-2 Another characteristic of chemicals that is important in
determining the hazards involved is its persistence in the
environment. This should be included in the discussion, and
assurances given that this parameter will be monitored.
*g. IIi-9 Three categories are described under each of the chemical
ratings. Appendix II, however, which gives the specific
hazard rating for each chemical, include a category "4" for
all types of hazards. This requires clarification.
In addition to reactivity of chemicals with water and other
chemicals, the reactivity with air should also be considered.
(g. 111-13 Change "inconclusive" to "inclusive".
'g. 111-27 The statement is made that bilge water is discharged at
regular intervals. On page IV-4, however, reference is made
to Coast Guard regulations that require on board retention of
oily bilge water. This conflict needs to be resolved. .
'g. 111-28 Reference should be made to the proposed regulations for the
"Marine Sanitation Device Standard, "which appeared in the
Federal Register on October 10, 1975. , ' .
g. IV-2 The final U.S. Coast Guard Regulations for Tank Vessels
Carrying Oil in Domestic Trade exclude chemical carriers
and apply only to oil tankers. Discussion of those regula-
tions should be amended accordingly.
g. IV-8 The specific citing of the regulations which implement the ,
statutes described should be included with a brief explanation
of significant controls and impacts on the construction am!
operation of these vessels.
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Pg. IV-10 T'nder the typical approaches for minimizing risks for
sinking, or hull rupture, several provisions arc listed as
being 'normally considered for new vessels. " The specific
provisions to be made for chemical incineration ships should
be listed.
Pgs- IV-14 to IV-33. The IMCO standards discussed in this section
have not yet been ratified, as mentioned on page IV-27. The
applicability of these standards to the proposed action is not
clear, since the discussion is only a synopsis of the provisions
of the IMCO code and convention. Unless MA RAD intends to
make these a part of their requirements, a point not stated
in the EIS, \vc suggest they be excluded or discussed under
a separate heading if so desired. See General Comment -1.
Pg. IV-41. See the comment on Pane IV-28 regarding proposed
regulations for Marine Sanitation Devices.
Pg. IV-43. Provisions (6) and (7) of the National Oil and Hazardous
Substances Contingency Plan are used only in the event of
strict environmental conditions and then only as a last resort.
The wording used implies a normal procedure and should be
revised.
Proposed EPA regulations for the Designation of Hazardous
Substances have been issued as of December 30, 1975.
Pg. IV-46 and 47. The final U.S. Coast Guard Regulations for Tank
Vessels Carrying Oil in Domestic Trade, issued October 14,
1.975 apply to oil tankers only. They are not applicable to
chemical carriers. See comment on Page IV-2. The final
EIS on the regulations was available as of October 14, 1975.
Pg. V-l Parts A through E should be identified as alternatives
available to industry, and part F as the alternative available
to MAHAD.
Pg. V-7 The rotary kiln incineration alternatives are difficult to
compare as the economics are discussed in widely varying
units. A consistent approach should be followed.
Pg. V-15 The statement that a national disposal site will "undoubtedly
be required in the future" must be thoroughly explained.
-------
Response to letter of May 13, 1976, from the National Wildlife
Federation
1. On April 23, 1975, Shell Chemical Company requested a special
permit to incinerate up to 22,000 metric tons per year of waste
material, which is the predicted yearly generation rate during
1975-1977. The scheduled completion date of Shell's land-based
incinerator is mid-1977, dependent on the receipt of key long-
delivery equipment. Thus Shell wishes to incinerate at sea
their inventory now on hand and that which will accumulate until
their land-based incinerator is at sustaining capacity. At
this time, no other applications have been received by EPA for
the use of an incineration site in the Gulf of Mexico.
The Gulf coast and especially Texas are the center of the
petrochemical industry of the United States. Accordingly, the
principal producers of vinyl chloride, viz., Shell Chemical
Corporation, Tenneco, and Dow Chemical Company are located
primarily in the Houston-Galveston-Freeport region. At the
present time the organochlorine wastes derived from production
of this compound are the chief candidates for ocean incineration.
Figure 1-2 in the EIS reveals the site to be equally accessible
to the entire Texas coast from Brownville to Orange and that via
the Southwest Pass of the Delta it is also convenient to the
Louisiana petrochemical industry located along the Mississippi
River.
-------
The Maritime Administrations "Chemical Waste Incinerator Ship
Project" is proposed for the general needs of the affected industry
and is not in any way site specific. The site proposed in this
EIS was selected based on the criteria and the immediate needs
of the Gulf coast waste producers. No impact is anticipated from
the Maritime Administration project other than the possibility
of using domestic rather than foreign vessels for incineration
at the site.
According to correspondence from the Department of Defense
to the Administrator, dated June 4, 1976, the reprocessing of
Herbicide Orange is still being pursued as an alternative to
incineration at sea. The company involved, Agent Chemical,
Incorporated, has been given extension of time to continue
research in this direction. At this time, no decision has been
made. The Air Force has not expressed an interest in the Gulf
of Mexico as a possible incineration site and has in fact submitted
an application to the EPA, on January 9, 1974, for a permit to
incinerate at a site 1000 miles west of the Hawaiian Islands.
On March 24, 1975, notice was given in the Federal Register of
a proposed rulemaking to designate this site.
2. While estimates of the material likely to be incinerated at the site
could be made, and indeed have been, their relationship to any
long-term impacts is not known. The likelihood of a "buildup" appears
to be remote due to wind and current actions in the area, but the
monitoring and testing program described in Section VI will be used to
evaluate any long-term impacts from incineration. Hypothetical
-------
levels of ocean incineration, and resultant hypothetical emissions,
would lead to no itiore than very speculation evaluations of impacts.
For these reasons, such estimates have not been presented in the
EIS. Rather, the provisions of the Ocean Dumping Regulations
and Criteria, specifically the Impact Categories and Modification
of Disposal Site Use on pages 21 and 22 of the EIS, will be used
to assure that continued use of the site will not be permitted
should the monitoring program reveal any long-term impacts.
3. Since only one type of chemical waste has been tested and monitored
for incineration at sea, EPA cannot at this time categorize the
suitability or unsuitability of other candidate wastes. Until
forthcoming specific criteria to regulate this type of disposal
are promulgated, the Permit Program (as presented in the text)
will serve as the mechanism for assuring that each candidate
chemical will be fully tested prior to its acceptance. The results
of the monitoring for long-term impacts as described in Section VI
will be used to provide further information on required testing.
The statement on page 58 regarding the denial of permits if
metals are in concentrations that would cause detriment to the
environment has been expanded. The text now reflects the conditions
of the Proposed Revisions to the Ocean Dumping Regulations and
Criteria.
4. The testing program that is anticipated to be performed during
the use of the site will be used as a basis for developing specific
at sea incineration criteria and regulations. The development of
these are considered a high priority item by the contracting parties
of the Ocean Dumping Convention, including EPA.
-------
5. The alternatives to ocean incineration are considered during the
evaluation of individual permit applications. The proposed
action as described in this EIS is the designation of a site for
ocean incineration/ not the actual incineration (see page 55 of
the EIS). Mditions have been made in the text in Section I to
reflect this procedure. Also, as stated in Appendix G, Shell
plans to have a high-temperature land-based incinerator in
operation in 1977.
6. The impacts of the use of the site in Section IV of the EIS are
related to the conditions found in the semi-enclosed Gulf of
Mexico as described in Section II. Since no short-term impacts
were found as a result of the research burns, and because the
site met or exceeded requirements of the criteria, no disadvan-
tages were evident from using such a semi-enclosed area. This
site also had the advantage of being near the center of the
petrochemical djndustry, the probable users of such a site. A
site in the Atlantic would have increased the chances of a spill
of unburned wastes through collision or storm due to the greater
distance to be traveled. This designation does not preclude
the future designation of a site elsewhere, including the Atlantic.
7. The types of supplementary fuel oils to be used for the incinera-
tion process will be determined through the evaluation of the
permit application. This will be dependent upon the nature of
the waste being incinerated and the characteristics of the incin-
erator ship.
-------
8. Sane observations indicate that the Gulf site is not in a major
flyway utilized by passerine and other avian specifies in either
fall or spring. For instance, Peguegnat (1966) reports in the
chief scientist's log of Texas ASM University's R/V Alaminos
that during a March-April oceancgraphic cruise from the west to
east Gulf significant numbers of migrating birds were not
encountered until the ship reached about 28° 20'N and 87° 03'W
to the east of the Mississippi Delta. During this cruise the
ship's track crossed the region of the designated site. Again
in 1969, but this time in the fall (October), Peguegnat reports
few birds in crossing the locus of the site. But, on the night of
14 October 1969 , thousands of passerine (warblers, thrushes,
thrasher, etc.) birds were encountered at sea near 28° 50.5'N
and 87° 36.0'W, again well outside of the site boundaries. For these
reasons, it-seems unnecessary to place calendar restrictions on
ocean incineration at this site.
Patty (1963) reported eye irritation in pigeons on extended
exposure (6 hrs/day, 50 days) to a hydrogen chloride concentration
of 100 ppm. Concentrations of 100 ppm have been calculated as
only mathmatically possible and then in narrow plumes at altitudes
up to 500-600 feet immediately downwind of the incineration for '
distances of a few hundred yards (Shain 1974); however, maximum
concentrations reported by the EPA (1975) during 17 separate
contacts with the incineration plume from the VULCANUS ranged from
0.01 to 7.0 ppm. From these data, it seems very unlikely that
incineration of organochlorines would pose any hazards to birds
-------
migrating over the Gulf of Mexico. Moreover, with strong physio-
logical drives to complete their migration, the birds would
probably not linger in the incineration site.
-------
DEPARTMENT OF TRANSPORTATION
MAILING ADDRESS:
UNITED STATES COAST GUARD
PHONE: 202-426-9573
5922/9. a.104
• 2 ' JUN 1976
.Mr. Kenneth E. Biglane
Director, Oil and Special Materials
Control Division, (OSMCD) (WH-548)
Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Dear Mr. Biglane:
This is in response to your undated letter addressed to Captain Schubert
concerning a draft environmental impact statement for the Designation of
a Site in the Gulf of Mexico for Incineration of Chemical Wastes.
The concerned staff elements of the Coast Guard have reviewed the material
submitted. We have one point worth noting:
Page 57, second paragraph - Properly, the quantity of HC1 released
per unit time using a fixed feed rate of chlorinated hydrocarbons depends
on the weight fraction of chlorine atoms in the feed. The release rate
of HC1 will therefore depend on the chemical composition of the feed.
The opportunity to review this draft statement is appreciated.
Sincerely,
8. J.
?afn, U. S. S332* £-2
-------
Response to letter of June 2, 1976/ from the United States Coast Guard
Correction suggested by the U.S. Coast Guard noted and accepted.
The Draft EIS calculations were based on the Shell Chemical organo-
chlorine waste, which contained 63% chlorine. The proper changes
have been made in the text of the Final EIS.
-------
TEXAS WATER QUALITY BOARD
J. DOUGLASS TOOLE
CHAIRMAN
FRANK H. LEWIS
, VICE CHAIRMAN
M.F. FROST
FRATIS L. DUFF, MD
CLAYTON T. GARRISON
BEN RAMSEY
JAMES M. ROSE
HUGH C. YANTIS, JR
EXECUTIVE DIRECTOR
PH. (512) 475-2651
1700 NORTH CONGRESS AVE.
P.O. BOX 13246 CAPITOL STATION 78711
AUSTIN, TEXAS
June 2, 1976
Re: Draft Environmental Impact
Statement - Designation of
Site in Gulf for Incineration
of Chemical Wastes
Environmental Protection Agency
401 M Street, S.W. (WH-548)
Washington, D. C. 20460
Attention:
Mr. John Rhett, Director
Oil and Special Materials Control Division
Dear Mr. Rhett:
The staff of the Texas Water Quality Board has reviewed the draft
environmental impact statement covering the designation of a site in
the Gulf of Mexico for incineration of chemical wastes and have con-
cluded that the proposal appears to cover the important environmental
issues.
The draft environmental impact statement concerns itself principally
with the designation of a site approximately 200 miles off the Texas
coast in the Gulf of Mexico, and would consequently be outside this
agency's jurisdiction. Even though the possibility of an oil spill
may seem to be somewhat remote if it should occur and oil spillage
reach the Texas Coast, the Texas Oil and Hazardous Substances Pollution
Contingency Plan would become effective.
We appreciate the opportunity to review this proposed activity. If we
can be of further assistance, please let us know.
V^jsy truly yours, r,
' -•/ /-. ^ -^.'-S
(7^7 v—•;
' / /-"^ ' • - -
f ~~^ ' / -' •*" •
>.•-,•-< .':'•/) ^ ^/ f ., '.
. , , •:•'.' '»_• , >—' '
Emory G. Long, Director
Administrative Operations
cc: Mr. Charles T. Travis, Governor's Budget and Planning Office
-------
Response to letter of June 2, 1976, from the Texas Water Quality Board
Comments on the Draft EIS by the Texas Water Quality Board are
hereby noted.
-------
PHONE 512/451-5711 CHARLES R. BARDEN, P. E.
8520 SHOAL CREEK BOULEVARD EXECUTIVE DIRECTOR
JOHN L BLAIR, Chairman AUSTIN> TEXAS ~787S8 CHARLES R. JAYNES
V1LLIAM N. ALLAN , D. JACK KILIAN, M.D.
JOE C. BRIDGEFARMER, P.E. WILLIAM D. PARISH
FRED HARTMAN E. W. ROBINSON, P.E.
WILLIE L. UL1CH, Ph.D., P.E.
June 3, 1976
Director
Oil and Special Materials Control
Division (OSMCD)
Environmental Protection Agency
401 M Street, S.W. (WH-548)
Washington, D. C. 20460
Re: Draft Environmental Impact Statement: Designation of a Site
in the Gulf of Mexico for Incineration of Chemical Wastes
Dear Sir:
We have reviewed the above cited document. The site designated for
incineration in the Gulf appears to be acceptable for this type of
operation. It is requested that periodic surveillance be used to
assure that the incineration is being carried out in accordance with
the provisions of the permit. The site should be restricted so that
only one incinerator ship is allowed to burn waste at any time and
a maximum burn rate should be specified.
Adequate monitoring systems must be provided to verify that the in-
cinerators are operating properly so that complete combustion is
achieved. Only wastes which have been thoroughly tested and approved
through a research project equivalent to the Shell Oil Company Vulcanus
Research Project should be allowed to be burned. The research project
should determine what controls are necessary to assure complete com-
bustion, and must verify that burning the waste will not cause adverse
air quality effects.
Thank you for the review opportunity. If we can assist further, please
contact me.
Sincerely yours,
Stewart, P.:
Deputy Director
Control and Prevention
cc: Mr. Lloyd Stewart, Regional Supervisor, Bellaire
Mr. Ray Lozano, Environmental Protection Agency, Region VI, Dallas
-------
Response to letter of June 3, 1976, from the Texas Air Control Board
As stated on page 13 of the EIS, surveillance and enforcement
of permit conditions will be accomplished by the Coast Guard.
The designation of the site, as published on April 30, 1976,
in the Federal Register, Vol. 41, No. 85 (40 CFR Part 227), as a
proposed rulemaking, will be modified to restrict the usage of the
site to one incinerator ship at a time, except under extreme
emergencies. This is also reflected by a change in the text on
page 73. A maximum burn rate will be specified as a part of indivi-
dual permit conditions.
Recommendations for monitoring of the combustion efficiency are
discussed in Appendix G of the EIS.
As stated in the proposed rulemaking, the use of the site will
be primarily for the incineration of organochlorine wastes.
Incineration of other wastes will require research studies or equiva-
lent technical documentation to determine acceptability. Also, on
page 55 of the EIS, the statement is made that other chemical wastes
could be incinerated at the site, subject to the testing and monitoring
requirements of the permit.
-------
DEPARTMENT OF THE ARMY
GALVESTON 01STRICT,CORPS OF ENGINEERS
P.O.BOX 1229
GALVESTON. TEXAS 77553
REPLY TO
ATTENTION Of,
SWGED-E
4 JUN 1976
Director
Oil and Special Materials Control
Division (OSMCD)
Environmental Protection Agency
401 M Street, S,W. (WH-548)
Washington, D.C. 20460
Dear Sir:
The draft environmental impact statementy "Designation of a
Site in the Gulf of Mexico for Incineration of Chemical Wastes/1
submitted to the Chief of Engineers was referred to this office
for review and comment.
The proposed project would not affect any present or proposed
projects of the Corps of Engineers. The draft adequately
presents the environmental effects of the activity insofar as
our interests are concerned.
Sincerely yours,
JON C. VANDEN BOSCH
Colonel, Corps of Engineers
District Engineer
-------
Response to letter of June 4, 1976, from the Array Corps of Engineers
Comments on the Draft EIS by the Corps of Engineers are hereby
noted.
-------
SHELL OIL COMPANY
ONE SHELL PLAZA
P.O. BOX 2463
HOUSTON, TEXAS 77001
June 4, 1976
Mr. T. A. Wastler
Chief, Marine Protection Branch
U. S. Environmental Protection Agency
401 M Street SW
Washington, B.C. 20460
Dear Mr. Wastler:
As provided in Federal Register 41:18094-95, April 30, 1976 we are
submitting the attached comments relative to the draft Environmental Impact
Statement (EIS), "Designation of a Site In the Gulf of Mexico For Incineration
of Chemical Wastes".
We understand that these comments will be considered in the prepara-
ation of a final EIS.
Very truly yours,
u . - ••? —
R. E. Van Ingen
Manager - Manufacturing
Environmental Conservation
Attachments
-------
-------
SHELL OIL COMPANY
ONE SHELL PLAZA
P.O. BOX 2463
HOUSTON, TEXAS 77001
June 3, 1976
Comments Relative to the Draft
Environmental Impact Statement
"Designation of a Site In the Gulf of Mexico
For Incineration of Chemical Wastes"
1) Deletion of Impact Category I Subclassification
Paragraph (a)(2) on page 21 should be deleted. Application of
this classification of Impact Category I would preclude at-sea incineration
even when such an operation has been shown to be environmentally acceptable.
The term toxic is too broad to be useful as a control parameter, particularly
when coupled with "detectable" concentrations rather than concentrations
having physiological effects.
For example, products of combustion such as hydrogen chloride,
carbon monoxide and carbon dioxide are detectable in the disposal site and
are toxic under certain conditions. However, extensive tests during
incinerations in 1974 showed that the presence of these materials in the
disposal site did not adversely affect living species in the area.
2) Clarification of Wording on page 64.
The description of the analyses of plankton on page 64 implied that
organochlorines were detected in phytoplankton when in fact organochlorines
were not detected in phytoplankton. The following wording for the third
paragraph on page 64 is suggested to accurately describe the test results.
"The R/V ORCA made tows in the test and control areas for phyto-
plankton and zooplankton during the early period of combustion on the second
research burn in December, 1974. No organochlorines were detected in phyto-
plankton nor in the solid phase of zooplankton samples (detection limit 3 ppm)
Organochlorines unlike those in the wastes burned at-sea were found in tar
balls collected with the zooplankton and in the liquid phase decanted from
zooplankton samples. The tar balls contained 500-900 ppm organochlorines.
The liquid phases from the zooplankton samples contained 0.2-2.0 ppm organo-
chlorines Csee Appendix G, Table V-12). No systematic differences in organo-
chlorine concentrations were observed for test or control samples. Whereas
the level in Test 1 was 1.4 ppm with a control level of 0.4 ppm, the level in
-------
Page 2
Test 4 was 0.2 with a much higher control of 2.0. This appears to be related
to differential amounts of tar balls in the zooplankton samples. Shell
Development Company personnel analyzed some of the tar materials and found
that the organochlorines in the tar balls were not the same as the waste
burned; they were higher molecular weight than the organochlorines in wastes
burned at-sea. In addition, analyses for copper and zinc in plankton samples
revealed nothing to indicate, that the plume fallout had caused any appreciable
increases (Appendix G)."
3) Elaboration of Section on Deterioration of Air Quality
It is suggested that the section on Deterioration of Air Quality
(page 71) be expanded to address the extent of acid rain and the effect of
combustion products on stratospheric ozone. Elaboration of these points would
complement earlier conclusions in the EIS that societal impacts are insignificant.
Acid Rain
Within 5-10 miles of the incinerator ship acid rain from incineration
could equal or exceed that normally produced when rain washes out the naturally
occurring acidic sulfur (SOx) and nitrogen (NOx) as well as chloride in salt
spray. In this case the acid rain would be neutralized immediately by the
natural carbonates in the ocean.
Beyond 10 miles any hydrogen chloride remaining in the air would be
so dilute that it would be insignificant compared to naturally occurring acidic
components of the atmosphere. Aerial monitoring of at-sea incineration in 1974
showed that the maximum concentration of hydrogen chloride in the air five miles
downwind was on the order of 0.1 ppm. This concentration is much lower than the
5 ppm workplace limit for an 8-hour exposure set by the Department of Labor
(OSHA). Eight miles downwind the concentration was below detection limits
(0.005 ppm). This concentration is lower than the concentration of other acidic
components allowed under the most stringent air standards for either SOx
(60 ug/m3, 0.02 ppm) or NOx (100 ug/m3 0.05 ppm). There are no limits on acidic
components from salt spray.
At any greater distance than 10 miles, the effect would be even less
with continued dispersion and neutralization of that hydrogen chloride which
contacts the ocean or reacts with naturally occurring ammonia (20 ppb) in the
atmosphere. For these reasons the acidity of rainfall on coastal locations
would not be increased due to at-sea incineration in the proposed site.
Stratospheric Ozone
At-sea incineration of the total world-wide production or organo-
chlorine wastes would not produce sufficient stratospheric chlorine (HC1/C12)
to perturb the ozone layer (Lieder 1975). It would be necessary to double the
C. A. Lieder, "Effect of HC1/C12 from Ocean Incineration on the Stratospheric
Ozone Layer", Shell Development Company Memorandum, August 26, 1975.
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Page 3
stratospheric chlorine, typically 0.2 ppb or less, to have an observable effect
on plant life in certain regions of the world. Because of low-altitude scrubbing
processes which remove most of the HC1/C12, it would be necessary to incinerate
annually more than a billion tons of organochlorine waste to double the
stratospheric chlorine concentration. Total US production of organochlorine
wastes is estimated to be 1/1000 of that necessary to have an adverse effect
on the ozone layer. Furthermore, only a fraction of this waste would be
incinerated at sea.
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S H C L L DEVELOPMENT CO M P A N Y
to . CHEMICAL ENGINEERING
DEPARTMENT - MANAGER
AUGUST 26, 1975
FttOM C. A. LIEDER
SUBJECT EFFECT OF HC1/C12 FROM OCEAN INCINERATION
ON THE STRATOSPHERIC OZONE LAYER
A letter to the editor appearing in Chemical and Engineering News
(December 23, 1974) raised the question of stratospheric ozone destruction via
ocean incineration of organic chlorides (Attachment 1). The large quantity of
recent research on perturbations to the stratospheric ozone layer permits this
point to be answered with some confidence. Such an analysis reveals that even
the sea-level incineration of the total world-wide production of organic chlorides
would have a negligible effect on the stratospheric layer. The total amount of
waste accumulated in producing organic chloride amounts to four percent of the
total world-wide production. Thus, the incineration of one-tenth of one percent
of the total world-wide production (22,000 tons of Shell waste) will have no
observable effect on the stratospheric layer.
»
In assessing the impact of the waste chloride incineration, the relevant
questions are: what are the natural and man-made sources of atmospheric chlorine;
how efficiently is atmospheric chlorine transported from the lower atmosphere to
the stratosphere; what effect chlorine levels have on the stratospheric ozone
layer. The following discussion answers these questions and relates the impact
of wa^te Chloride incineration to these phenomena.
Sources of Atmospheric Chlorine and Transport to Stratosphere
Atmospheric chlorine (HC1, Cl2) is predominantly released from natural
sources.1"5 The best estimates of atmospheric loading indicate the following
sources of HC1/C12:
TABLE 1
RELATIVE STRENGTHS OF ATMOSPHERIC CHLORINE SOURCES
Mass Loading
At Ground Level
(tons/yr)
Percent Ground
Level Emissions
(% of Total)
Relative Mass
Loading of
Stratosphere
Percent of Total
Stratospheric
Loading
Marine
Aerosols
Volcanoes/
Fumaroles
Industrial
TOTAL
2 x 108
107
107
2.2 x 108
91
4.5
4.5
100.0
20
^ 100
1
0\> 121)
'relative total'
17
82
1
100.0
These sources give rise to a ground level atmospheric chlorine concentration of
^ 1 ppb (also termed by atmospheric scientists as a mixing ratio of 1 x 10~g).
These ground level sources are the origin of the approximate <^ 0.2 ppb atmospheric
-------
•Kl-TECT OF 11C1/C12
chlorine level existing in the stratosphere between 20 and 40 kin. However, since
the volcanic sources often inject HC1 and C12 via an extremely hot eruption, they
are 10 to 200 times more effective as sources of stratospheric chlorine.'1 Both
the industrial and marine aerosol sources are severely constrained by the very
efficient rain wash-out of chlorine species.5 Other low-altitude, HCl-scavenging
processes include the formation of NH4C1 aerosols5*7 and absorption by soil and
vegetation.1'8 The consideration of tlie.se factors was used to calculate the last
column in Table 1. Specifically, industry's 107 tons per year contributes only
0.45 to 2.6 percent of the "total chlorine loading" of the stratosphere. Thus,
a 100 percent increase in industry's emissions would increase the stratospheric
chlorine level by between 0.45 to 2.6 percent.
The above analysis of the possible increase in industrial emissions has
assumed the U. S. ocean dumping figure of 1.65 * 107 tons/yr quoted in Attachment 1.
However, examination of actual chlorinated hydrocarbon (Cl-HC) production casts
some doubt on this quantity. First, numerous references9'11"13 quote 1 * 107 tcns/yr
as the total U. S. production of chlorinated hydrocarbons (Cl-HC). Estimates of
worldwide production are £ 2 x 107 tons/yr.10'11 Second, the "direct" waste pro-
duction from the worldwide production is estimated as between 4 to 8 x 105 tons/yr.9"1
Therefore, the U. S. ocean dumping figure of 1.65 x 1Q7 tons/yr more nearly
approaches the total worldwide production of Cl-HC than that of waste by-products.
Since many of the Cl-HC (vinyl chloride, allyl chloride) are polymer
precursors,9"13 there is little probability that the worldwide production of
<_ 2 x 107 tons/yr becomes ^_ 2 v 107 tons/yr of "indirect" liquid or gaseous waste
to be incinerated at sea. From the cited references, a more realistic estimate
of the possible amount of waste Cl-HC seems to be 6 to 10 x 10° tons/yr as opposed to
165 x 105 tons/yr.
A possible explanation of the quoted figure of 1.65 x 107 tons/yr of
"ocean-dumped" waste Cl-HC may be obtained by recognizing that 1.3 x 1Q7 tons
was approximately the total amount of material (sewage and all industrial wastes)
dumped into the ocean under EPA permits during 1973. 11+ This estimate is arrived
at by assuming that the Region II total of 9.4 x 106 yd3 of all waste is 60 to
70 percent of total U. S. ocean-dumping. Certainly this fact casts some doubt on
the total "ocean-dumped" quantity quoted in Attachment 1.
Effect of Stratospheric Chlorine on the Ozone Layer
With the concern over the environmental effects of the supersonic trans-
port, a great amount of information has recently been gathered about the strato-
sphere. One important characteristic is that the properties of stratosphere are
almost entirely determined by simple gas-phase chemical reactions (including the
action of solar radiation).1'2 For this reason, the effects of chemical pollutants
on the stratosphere can be calculated via a limited reaction network (^ one
hundred reactions). In the stratosphere, the effect of chlorine species results
from the photodissociation of Cl? and HC1 and reaction OH + HC1 -> Cl + H20, which
produce the Cl free radical. Then rhc catalytic cycle;
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EFFECT OF HC1/C12
Cl + 03 -»• CIO + 02
CIO + 0 -*• Cl + 02
03 + 0 -*• 202 ,
destroys ozone and oxygen (0 is precursor of 03). Ozone is important since
the reaction,
hv
OB •* o2 + o ,
shields life on earth from harmful ultraviolet radiation. Thus, any injection of
chlorine into the stratosphere should alter the earth's ultraviolet filtering
system.
Recently, the question of aerosol-can propellant's (CFC13 and CF2C12)
effects on the ozone layer has spurred a number of careful studies of the
chlorine reaction network for stratospheric conditions. Results from two studies
indicate that a 100 percent increase in the stratospheric chlorine level would
most likely reduce the overall ozone concentration of 0.5 percent to 2.5 percent
(i.e., 0.5 percent to 2.5 percent more harmful ultraviolet radiation would reach
the earth's surface). In general, it is postulated that a persistent 2 percent
ozone concentration decrease might have some observable effects on plant life in
certain regions of the world. 2~l*
Impact of Ocean Incineration of Organic Chlorides on Stratospheric Ozone
Since the Vulcanus stack gases attain ambient density below .2000 feet,
the resultant HC1/C12 release should be included in the category of industrial
chlorine emissions.4'5 Thus, (with reference to data in Attachment 1), incinera-
tion of 1.5 * 1010 kg per'year or 1.65 * 107 tons per year of organic chlorides
(assume 65 percent Cl by weight) would increase the industry contribution from
107 tons (Cl) per year to 2.1 * 107 tons (Cl) per year (see Appendix 1). From
the arguments above, this increase would add 0.48 percent to 2.8 percent to the
stratospheric chlorine level with subsequent ozone concentration decrease of
0.0025 percent (1 part in 40,000) to 0.07 percent (1 part in 1,500). Even the
most pessimistic estimate of this massive amount of incineration (carried on for
long term) is an order of magnitude below an observable effect.
Some idea of the magnitude of the task of incinerating 1.65 * 107 tons
per year of organic chloride is that 97 ships (comparable to the Vulcanus) would
be required to operate year-round. The Shell Chemical wastes burned by the
Vulcanus (4 voyages) amounted to 1.6 x 101* tons (approximately one year's waste
for Deer Park Complex).
Conclusion
Therefore, even massive, long-term ocean incjneration of organic chlorides
(^ 2 x 107 tons per year) should have an unobservable effect on the stratospheric
ozone concentration.
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EFFECT OF HC1/C12
References
1. Wofsy, S. C. , and McElroy, M. B. (1974), Can. J. Chemistry 52_, 1582. •
2. Wofsy, S. C. (1974), "Proceedings of the Third Conference on the Climatic
Impact Assessment Program," A. J. Broderick and T. M. Hard, editors,
February 26-March 1), p. 364.
3. Farmer, C. B., et al, Ibid, p. 234.
4. Stolarski, R. S. and Cicerone, R. J. (1974), Can. J.- Chemistry _52, 1610.
5. Duce (1969), J. Geo. Res. 7±, 4597.
6. Kiang, C. S. Stauffer, D., and Mohnen, V. A. (1973), Nature (Phys. Sci.) 244,
53.
7. Lodge, J. P. and Pate, J. B. (1966), Science 153, p. 408.
8. Chesselet, R., Morelli, J., and Baut-Menard, P. (1972), "Some Aspects of the
Geochemistry of Marine Aerosols" in "The Changing Chemistry of the Oceans",
Wiley Interscience, New York, pp. 93-114.
9. Des Roisiers, P. E. and Swank, R. R. (September 17-20,-1974), "Industrial
PolluLiuu CuuLrul - By-Product Recovery through ExhausLive-Chlorination of
Halogenated Hydrocarbon Wastes", presented at Joint AIChE-Gesellschaft
Verfahrenstechnik and Cheraeingemerwesen Meeting, Mlinchen, Deutschland.
10. Chemistry and Industry, lj> (June 1973), pp. 567-569.
11. Chemical Week, 26_, (July 1973), p. 61.
12. Chemical Week, _6, (November, 1974), p. 31.
13. Environmental Science and Technology (May 1975), p. 412-3.
14. "Ocean Disposal in the New York Bight" (April 1975), Technical Briefing
Report, No. 2, U. S. EPA Region II.
CAL:co C. A. Lieder
-------
ty-
chemistry support by acocemia and
try. As chairman ot ths education
r>iltee ol the ACS Division ol Polymer
listry inc.. I would like to ot'er the
:es ol our committee to those institu-
and/or individuals who wisn to con.
the development o( appropriate un-
•aduale and/or graduate courses and
•ams. We hrwa currently supported the
aradon of a new ACS Interaction
se—"Polymer Science and Tcchnol-
—An Interdisciplinary Aporoach"; are
aring a laboratory manual with experi-
ts suitable lor incorporation into under-
uate organic and physical chemistry;
developing a reference bibliography on
mers; and have recently published a
ey ol polymer education in various in-
tions.
ention should also be mads at this
t of the tact thai in addition to Dr. Flo-
receiving (he Nobel Prize, another sig-
;ant occasion is on the horizon for poly-
• science and education—tha celcbra-
: C! Pro!. Worrtian P Mark's ftOth birth-
on May 3. 1975. Among Mark's many
:ompli5hments was the establishment of
world's first academic program grant-
graduate degrees in polymer chemistry
Polytechnic Institute of New York (nee
loklyn). Signiiicantly, Flory will chair an
jrnationai symposium In honor of this
:asion on May 2 and 3. It is planned to
lounce the Prolessor Herman F. Mark
air in .Polymer Science at that time.
onds of Mark, the Polytechnic institute.
d polymer chemistry can contribute to
» success ot this event, important to the
:>wth and recognition of polymer chomis-
. by contacting me.
EllM.Pcarco
ia/rman. Education Comminet, Polymer
Division, ACS. Dcpt. ot Chemistry, Poly-
technic Institute ol New York. New York,
W.y. 77207
;
rinking water study
B: Your report of the Environmental Pro-
ction Agency drinking water study
i&EN. Nov. 18. page 44) Illustrates that
gnilicant prosiems stiil exist in this coun-
y with respect to trace contaminants in
ur natural waters. Particular concern still
enters around the n.iture ot. tho various
rgamc compounds tnnt h?v»» \-.°t,n
d. especially ing potential (or tox
if carcinogenic behavior.
Howevir. caro must b<» exercised as to
10V mochnniims lor Iho production of viri-
lus halogenoted orqamcs in wntor sys-
omj. It Is liKoly that chloroform is indeed
present In Now Gtle.mV rJnnVinrj w.itcr, ,is
EPA has found tiut i'> it possible that ciVu-
rotorm i'. lormod by cti!orir.i(ron processes
In Mentor or w.is'.^-water ttc.Mrnont plants'5
Mor.t c"Q-ln'C c.hi:'V\i-,try lo>'.:. discuss \t.<*
chlorln.'ttion o! tr.c-th.l-.o (3 liKijIy constitu-
ent ol wai.'.o-wnter (r«.itni'.'nt plnnt cl-
tluenls) In terms ol a fro-.- r/id:cnl mecha-
nism under conditions ol uitr.iviotul hcht or
high tempvraturu (250 (0 <100* C). Thoso
cotictitions nto not met by tho chlonna-
tion processes as currently practiced in
such plants.
It is highly possible that chloroform is
present in irin iniaKo water lor tho city
water supply but tho origin would scsm to
be primarily from industrial effluents up-
stream rather than in, situ forrnnlion. There
is no dov:bt, however, that certnin chlori-
nated orgnmc compounds could bo formed
when waste- water is chlorinated but it
would seem thai more research is needed
to identity the mechanisms involved.
Joseph J. Dellmo, Ph.D.
Assistant Professor f, Chi til. Environmental
Health Section, State Laboratory ot Hy-
giene, Madison, \'/is.
Disposing of waste at sea
SIR: I vfduid like to point out a possible prob-
lem with an environmental measure almost
universally endorsed. I am referring to the
incineration of orcjanic chlorides (without
an alkali trap) at sea as a means ol dis-
posing of these compounds (C4EN, Oct.
14, parjo 5; Nov. 18, pace 43). The maior
ch!orins-conlaming product of combustion
amounts of small volatile chiorocarbons
seem probr.ble. One should obviously be
concerned with how the locally high ac;City
will affect the local oceanic and atmo-
spheric lilo forms (e.g. plankton, fish, mi-
gratory birds). However, these are not the
only problems. Undoubtedly, some of these
combustion products will make their way
into the higher atmosphere. Once there,
photochemical decomposition and reaction
• with atomic oxygen would then yield chlo-
rine atomi. Atomic chlorine is a highly cor-
rosive modification ol war gas from World
War I. More important, however, it js an
efficient catalyst for the destruction ol at-
mospheric ozone (C&EN, Sept. 30, page 2:
Science. Oct. 25, 1974. page 335). Such
destruction is highly undesirable as In-
creased skin cancer incidence, plant
flrowth' retardation (including plankton),
and climatic modification have been sug-
gested as by-products of ozone depletion.
Admittedly. I cannot provide the numeri-
cal increase in chlorine atom concentration
due to tho proposed burning of organic
chlorides. However, notg that som-) 1.5 X
10'° kg ol organic chlorides were dumped
in'.o tho Cull of Mexico and the Atlantic
Ocoan in 1973. Also, note that the contri-
bution from tho NH^lOi prooollant for ths
pl;inr.r-d spaco bhut'.l-? ho1? b'?-*n lobol'-'d
"smr.ll Put nonnijr.iirji'.tin." It snyms incon-
ceivable that burning all the orqamc chlo-.
ndos lhal wore dumped could produoo a
smaller increase.
I will conclude with a discussion of pos-
siblo solutions to llio (iroblom. Perhaps tho
iimjitcst is lo dCMfjn I'M" tiurn'o"; pV/'orri
to include an r-Hcctivi .ilk.ili ir.io -\!'i nM;ts
to dnd nltcrnotivo destruction scn"m»s (or
orgonic chlo.'.uos have bcon su-; -,o-.;<.'d in
CAEN. Sept 10. r'ino 1? Also • '.i. ''i-s ',.',
converting organic chlondei n%:o c'.ij'u!
procuc:^ J'e in pfooreis (eld~.y.'iv)Od A'iO-
nal). On-* migut think ono coui'i oiw.iys ru-
plomsh the ozono layer should !^>'i Ci'3'o-
'ion become dangprous. Hcwevr ;it tojr.l
tor processct, on tho corth's surlact-, in-
creasing tne 0:0111; concor.tr.v.ion r.'ao h.is
severe problems (C&EN, Oct ?3. pjo.e
22). Since we know of this darker aheoid
of time, lot us thus avoid deyi?t.ng the
ozone layer in tho first place.
Joel F. Liebman
Assistant Protossor ol Chemistry. Untvjrstiy
ot t.tarylsnd. Baltimore
Ion transport
SIR: I should like to "comment en your re-
cent article (CdEN. Nov. 18. paps 35)
concerning the potential practical uses of
carrier-mediated ion transport.
The examples given represont exciting
new applications ol perrr.seiec;.va liquid
membranes. However, there is at least ono
precedent (M. Pinkerton. L. K. Siomrauf.
and P. Oawk»ns. Bioc^ern. Sop'ivs Res.
Commun.. 35. 512 (1959)) to the use cl a
memorane-active endbiot'c to produce
transport of an ion against its concentre;.on
gradient. In tr.is paoer, experi.T.sn'.s were
presented which led the auihors to con-
clude: "Using valinornycin as a carrier, we
havo cnns;ruc!-jd a device lor couoled ion
transport which wilt concentrate one ion
across a barrier using the concentration
gradient of a second ion as '.no driving
source." Thus, trie principle ot "uphill" ion
transport in vitro is not reaily a novelty.
Bal'.haser F. GiSin
Associate Protsssor, P.ocknlallcr University.
New York. N.Y. .
Commercial prostaglandin
SIR: I would like to correct an error In your
issue ot Nov. 18 (Concentrates, page 3-0).
The first comm'erciat prostncilar.am to b«
approved lor use in animals was not pros-
taglandin F?0 but a synthetic analog. 16-
(3-trifluoromethylpheroxy)-17.13.19.20-
tctranor-prostaglandm Fjo. which was
launched in the U.K. in March 197* under
tho tradename Ec.uim.ito.
N. S. Crossley
Pharmaceuticals Division, imperial Chemi-
cal Induslrias. U.K.
Cyclamatea
*'••'
ot
SIR: Three cheers tor Miko Sveda1 He has
tho courage lo stand up arid toll it liko it n
(CSEN. .Nov. 25. pj-jo 14) con=;?rninn cy-
clnm.itos. Uiq Brother in W.-j'f:'.-y;:or. ('"CCJ
& Drug AcmipiMr.ition) s.iir<;ii/ '•''
.ig.nn. is dead wrong, ar.o ha-jn t
guts to admit it.
A. R- Morgan
Pros/dcrtf. Thormn Technology. Tul:a, 0'
-------
Response to letter of June 4, 1976, from Shell Oil Company
1. In the Proposed Revisions to the Ocean Dumping Regulations and
Criteria, published in the Federal Register on June 28, 1976, the
condition for Impact Category I has been corrected to read
outside of the disposal site.
2. The intent was not to imply that organochlorines were detected
in phytoplankton samples but simply that organochlorine might
have been present in concentrations below the limit of detection
which was 3 ppm. The wording in the text concerning organo-
chlorine determinations was changed as suggested.
3. As suggested, the points are addressed in the text.
-------
Louisiana Air Control Commission
State Off ice Building
Phone (504) 527-5115
P.O. BOX 6063O
New Orleans 70160
June 4, 1976
Environmental Protection Agency
401 M Street, S.W. (WH-548)
Washington, D. C. 20460
Attention: Director, Oil and Special Materials Control Div., (OSMCD)
Re: Comments on the Environmental Protection Agency's Environmental
Impact Statement (EIS) on "Designation of a Site in the Gulf of
Mexico for Incineration of Chemical Wastes:
Gentlemen:
Per your request this agency has reviewed the EIS for the Gulf of Mexico Incin-
eration Site. As far as can be determined, the burning of the waste will not cause
the air of the State of Louisiana to be compromised. However, the evaluation we
conducted indicates some standard operating procedures should be developed for
the site, namely:
I. The concentration of the HCI in the air down wind the incinera-
tion ship was allowed to approach the Threshold Limit Value of
5 ppm (v). Provisions should be made to insure the ship's crew
wi11 not be subject to such concentrations for periods longer
than 8 hours.
2. Limitations should be set on the number of incinerator ships that
will be allowed in the burning area at once.
3. Provisions should be made to restrict operations during adverse weather
conditions i.e. inversions, air stagnations, high seas, etc.
4. The only provision found relating to dispersion was the requirement of
a relative wind of 10 kts or greater across the stack. Standard
"stack" conditions should be mandated i.-e. release contaminants at
a height of at least Y feet above sea level with a velocity of X ft/sec
or greater.
We urge you to propose and ultimately adopt such procedures.
Very truly yours,
OT:mac
Orey Tanner, Jr., Administrator
Technical Assistance Unit
Air Qua Iity Section
La. State Division of Health
-------
Response to letter of June 4, 1976 from the Louisiana Air Control
Commission
1. The Department of Labor Standards of 8 hours per day exposure to
5 ppm HC1 will be recontnended for inclusion in the operating
procedures.
2. See the response to the comments from the Texas Air Control Board
regarding the limitations on the site usuage.
3. Estimates of HC1 concentrations at various distances downwind from
the source have been made for four stability classes. These classes
are categorized according to surface wind speed and incoming solar
radiation (for daytime) or cloud cover (for nighttime). For all
except the slightly unstable (E) end moderately stable (F) conditions
at a distance of 0.5 km from the source, the maximum concentration
anywhere in the plume occurred at the ocean surface. The E and F
categories only apply to surface wind speeds of less than 5m/sec
during the night. According to the table on page 30, these wind
speeds are relatively infrequent.
From these estimates, and from the frequently changing patterns
in the Gulf which affect the various stability classes, specific
restrictions at this tims would not appear to .be needed.
4. Stack emissions are controlled by special permit conditions (tempera-
ture and flow rate) and are dependent upon the specific design charac-
teristics of the vessel. For example, for existing incinerator vessels
the stack height is fixed, air feed rates are constant, feed rates are
variable and temperature is maintained by varying feed rate.
-------
UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Secretary for Science and Technology
Washington. D.C. 20230
June 15, 1976
Mr. Kenneth E. Biglane, Director
Oil and Special Materials Control Division
Environmental Protection Agency
401 M Street, S. ¥.
Washington, D. C. 20460
Dear Mr. Biglane:
The draft environmental impact statement entitled "Designation
of a Site in the Gulf of Mexico for Incineration of Chemical
Wastes, " has been received by the Department of Commerce for
review and comment. The statement has been reviewed and the
following comments are offered for your consideration.
General Comments
The proposed action described in the draft environmental impact
statement concerns the designation of a site in the Gulf of
Mexico where permissible incineration of chemical wastes can be
performed aboard specially designed or adapted incinerator
equipped chemical tank vessels. It is noted that initial test
studies concerning this proposed action began in the fall of 1974
using the National Oceanic and Atmospheric Administration (NOAA)
ship, Oregon II. The Department of Commerce's Maritime Adminis-
tration (MarAd) also has an interest in this proposed action since
it relates directly to the agency's Chemical Waste Incinerator
Ship Project. The final environmental impact statement for this
MarAd project is expected to be released by July 1976.
Specific Comments
Chapter 1, Ocean Dumping in the Proposed Site. It is noted on
pages 4 and 5 of the draft environmental impact statement that
'ocean incineration is subject to the pcean dumping regulations
pursuant to the Marine Protection, Research and Sanctuaries Act,
as amended in 1975- " This implies that ocean incineration is
considered by EPA as a special type of ocean dumping. The pro-
cedures for issuing an ocean disposal permit and for evaluating
an ocean disposal site, as defined in Chapter 1, are those for
ocean dumping in general and not for ocean incineration in par-
ticular. It is, therefore, suggested that the draft environmental
impact statement contain an emphatic statement which limits ocean
disposal of toxic chemical wastes within the site to incineration
only.
'^8-191*
-------
- 2 -
Page 31 - Most of the data from this section, as well as the pre-
vious section, were taken from SF-189II - Environmental and
Acoustics Atlas of the Caribbean and ^ull' or Mexico - volume II -
Marine Environment and from Environmental Uonditio'ns Within
Specified (geographical Regions. Although these two publicat ions
adequately describe the environment in general terms, there are
other sources of data, both published and otherwise, which could
be used to describe the base-line conditions in the area:
a. Key to Oceanographic Records Documentation No. 2 -
Temperature, Salinity, Oxygen and .Phosphate in fhe Waters
off United states - volume 11 UulT of Mexico"!
b. Summary of Synoptic Meteorological Observations for the
North Atlantic Coastal Marine Areas Volume "6"!
c. The National Data Buoy Office of NOAA has maintained an En-
vironmental Data Buoy, EB-12, at 26N and 9^W since September
1975- Data from this buoy are available as monthly summaries
in the "Mariners Weather Log, " or the individual observations
can be obtained from the National Oceanographic Data Center
(NODG). Data from this buoy could be used to provide statis-
tical summaries for air temperature, dew point, air pressure,
windspeed, and wind direction. Not only has this buoy pro-
vided extremely valuable data over the past few years but, as
a constant monitoring station in the region of the proposed
dump site, it could be used to obtain supportive data during
the operational phase.
d. The charts attached to these comments indicate the amounts
of data from the various NODC data bases available for the
area of interest. It does not appear that any of the data
have been incorporated into the draft environmental impact
statement, other than that in the various "Atlas" type publi-
cations, which tend to present the data as average conditions
and disregard the anomalies. These data are easily obtainable
and should be part of any environmental study in this area.
Additional Oceanographic data are available from the National
Oceanographic Data Center, National .Oceanic and Atmospheric
Administration, Washington, D. C. 20235-
Pages 49 and 50, Alternative Methods of Disposal - It is stated
l;hat '^conventional barging and dumping of petrochemical industry
wastes, especially organochlorines, into the ocean may no longer
be the most environmentally safe alternative." This statement
could be more strongly worded. Oxidation via high- temperature in-
cineration of 99-9 percent of the organochlorine wastes and venting
into the air is preferable to dumping into the ocean where oxidatioi
-------
- 3 -
and biodegradation rates are orders of magnitude slower, where
biological processes concentrate minute fractions of dissolved
toxic substances in the tissues of marine organisms, and where
persistence by many organochlorines is exhibited.
The development of alternatives to at-sea disposal of chemical
wastes has been urged by many interested parties, and it is be-
lieved that at-sea incineration offers one such potential alter-
native that seems to be environmentally acceptable for the class
of wastes involved. Consequently, it is believed that this is a
step forward. Furthermore, both national law and international
treaty are calling for the strict limitation of conventional ocean
dumping of such wastes. This comment is not meant to imply that
ocean incineration is the most viable alternative to conventional
ocean dumping. However, under strictly observed safety regulations
and monitoring procedures, ocean incineration is a major environ-
mental improvement relative to direct ocean dumping.
It is noted, however, that no specific plans or provisions for
continuous monitoring of possible adverse effects of incineration
action are reported. Informal contact with EPA officials indicates
that this will be levied as a condition of permit approval. But
this is nowhere stated.
Care should be exercised in the selection of calendar intervals
for voyages to the incineration site to avoid severe tropical
storms (hurricanes) and occasional strong north winds in winter.
It appears that the EPA is fully cognizant of these hazards, and
will regulate the planned activity accordingly.
Pages 55 and 56, Physical Factor Impacts - The assessment of the
impact of air quality resulting from the incinerator operation is
inadequate. A description of the basic behavioral pattern of the
incinerator plume should be provided here. In this way, the
reader can place the various physical factors in proper perspective,
The most likely scenario is as follows:
"The hot gases are emitted from the incinerator stack
in a plume, there is an initial atmospheric dispersion,
and the plume gases generally drift to and are absorbed
into the surface of the ocean.l
As written, this section could be misinterpreted. For example,
the paragraph entitled "Winds" seems to imply that substantial
amounts of plume gases are expected to reach land over 300 km
away, albeit in a thoroughly dispersed state. Furthermore, the
size of the incineration site and the operations within it should
-------
be such as to ensure that the plume generally touches down to the
ocean surface well within the confines of the site. It is recog-
nized that meteorological conditions may at times prevent such
an occurrence.
Although the incinerator plume was monitored at the sea surface and
by aircraft during October 2, 2, and 4, 197^, no accompanying
meteorological data was indicated and no attempt was made to relate
these concentration findings to other meteorological conditions of
stability, wind speed and wind direction.
Pages 63-66 and Pages 8-12, Long Term Effects and Permit Program -
If it is well established that the long-term, chronic effects or
incinerating a specific waste at sea are negligible, would research
or interim permits still be the primary means of federal certifica-
tion for disposing of this particular waste? Paragraph (f) on
page 12 seems to indicate the eventual development of a special
permit program for incineration at sea.
Page 68, land Use - The viable disposal alternatives to conventiona:
ocean dumping of chemical wastes are ocean incineration and various
land-based disposal methods, such as physical treatment, chemical
treatment, thermal treatment, biological treatment, and ultimate
disposal. Land-based disposal methods require substantial land
use; incineration at sea does not.
Pages 72-7^, Accidental Spillage - The potential threats of acci-
dental spillage due to vessel casualties have existed for years sin
toxic chemical wastes have been barged to sea for direct dumping
into the ocean. The U.S. Coast Guard enforces strict regulations
for protecting the marine environment from pollution-.due to chemica
tank vessel operations. These regulations include the following
categories: standards for design and construction of vessels,
cargo containment and fire protection requirements, navigating
equipment necessary for safe operation, cargo transfer regulations,
and procedures for notifying proper authorities if a spill occurs.
It is suggested that the final environmental impact statement con-
cerning the Maritime Administration's Chemical Waste Incinerator
Ship Project be referenced for information in this area.
Thank you for giving us the opportunity of providing these comments
which we hope will be of assistance to you. We would appreciate
receiving twelve (12) copies of the final statement.
Sincerely,
J~ > *~
Sidney^ K.XJ£aller
Deputy Assistant Secretary
for Environmental Affairs
Enclosure
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-------
Response to letter of June 15, 1976, from the Department of Commerce
1. This is the intention and the reason for the proposed action being
the designation of a site for the incineration of chemical wastes.
This is also reflected in the proposed rulemaking published in
the Federal Register on April 30, 1976, (40 CFR Part 227), which
proposed the designation of the site for the "high temperature
incineration of highly toxic chemical wastes."
2. Although the Atlas referred to was used in preparing Section II,
many other sources were referred to, especially those from
Texas A & M University (e.g., Ncwlin, McLennan, Cochrane,
Pequegnat). These authors have been the source of valuable
data to NODC. The various appendices, particularly Appendix F,
present rather specific data pertinent to the site (e.g., a 2°
square bounded by 26° - 28°N, 92° - 94°W for square 62 of Marsden
Square 82, as supplied by the National Climatic Center. The
additional suggestion to use data from the National Data Buoy
Office of NOAA is appreciated.
3. The appropriate wording changes have been made in the text
(see page 50).
4. The need for and type of continuous monitoring has not yet been
established. The monitoring and testing program described in
Section VI of the EIS will be used to determine if long-term
effects will result from incineration of the waste chemical at
the site. Since the results of the research burns indicated
-------
an absence of short-term effects, the need for other than periodic
monitoring has not yet been demonstrated. Based on the results
of further testing, a decision will be made on the need for
continuous monitoring.
5. The characteristics of the plume are discussed in considerable
detail in Appendix G of the EIS. Appropriate changes have been
made in the text in the paragraph entitled "Winds" on page 56.
6. The dates above should read December 2, 3, and 4, 1974.
Meteorological data on the latter dates are given on pages 61
and 62 of the Draft EIS and also in Appendix G.
7. Subparagraph (f) on page 12 has been revised to reflect the
wording of the Proposed Revisions to the Ocean Dumping Regula-
tions and Criteria.
8. Appropriate changes have been made in the text of the Final EIS.
9. The Maritime Administration EIS has been referenced in the text
of the Final EIS.
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United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, B.C. 20240
ER 76/428
JUN 2 3 1976
Dear Mr. Biglane:
We have reviewed the draft environmental impact statement
prepared by the Environmental Protection Agency on the
Designation of a Site in the Gulf of Mexico for Incinera-
tion of Chemical Wastes. Our comments are as follows.
The draft statement appears adequate in all but one respect.
No mention is made of the oil and gas production activities
in off-shore areas between the coast and the incinerator
site. The proposed incinerator site is located within
45 miles of the active OCS oil and gas leases and approxi-
mately 35 miles from tracts presently nominated for inclusion
in the proposed OCS oil and gas Sale #47 (tentatively scheduled
for March 1977).
According to Section 228.6, #8 of the Ocean Dumping Regulations
Criteria, the Environmental Protection Agency must consider
the proposal's "interference with shipping, fishing, recreation,
mineral extraction, desalinization, fish and shellfish culture,
areas of special scientific importance and other legitimate
uses of the ocean." This categorization is appropriately
listed on page 20 of the draft statement under the heading
(Specific Criteria for Site Selection (a)(8). However, on
page 53 under the heading Designation of the Proposed Site
C8), the explanation as to how this proposal will safely
coexist with all of the above mentioned categories omits any
reference to mineral extraction. The section simply states,
in part, that it is ". . .a safe distance, 90 kilometers or
more, from the 180 M bottom contour inshore of which numerous
submarine banks such as the East and West Flower Gardens
occur." Some active leases are well beyond the 200 meter
contour while some nominated tracts-' are beyond the 600 meter
contour.
We are concerned that the personnel working on existing
offshore platforms or on the construction of new platforms
will be adversely effected by the incinerator either by the
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emissions or accidents involving the ship itself. EPA should
assess these impacts in the final statement and determine if
moving the incinerator site further seaward is warranted to
protect these facilities from the emissions.
A map of the incinerator area in the Gulf of Mexico showing
potential oil and gas lease sites is enclosed.
Specific questions concerning the leased areas may be addressed
to the Bureau of Land Management (suggested contact: Lou Ganna,
202-3M-3-626H). Information concerning the level of human
activity on the active leases should be directed to the
U.S. Geological Survey, Conservation Division, Metaire,
Louisiana.
We hope these comments will be helpful to you.
Sincerely yours,
Deputy Assistant Secretar^of the interior
Mr. Kenneth E. Biglane
Director, Oil and Special Materials
Controls Division COSMCD) CWH-548)
Environmental Protection Agency
Washington, D. C. 20460
Enclosure
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Response to letter of June 23, 1976 from the Department of the Interior
As mentioned on page 57, downwind concentrations of HC1, measured
at 6 meters above sea level, were in the range of 1-2 ppm. This was
within the Department of Labor standard of 5 ppm exposure for eight hours.
Also, dispersion model calculations using different air stability conditions
show that under all but the most unusual wind conditions the plume will
touch the sea surface within 1 to 2 nautical miles of the incinerator
ship. Therefore, no hazard to platform personnel is anticipated.
Additional information can be found in the discussion on Air Quality
on page 71 of the text and in the response to the comments of the Louisiana
Air Control Commission.
The discussion on accidental spillage beginning on page 72 has been
strengthened by the restriction on site usage to one incinerator ship at
a time.
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MEMORANDUM
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
OFFICE OF THE SECRETARY
T0 : Geri Werdig
DATE:
: JUL 2 1376
FROM
Director
Office of Environmental Affairs
SUBJECT: Review DEIS _ Designation of a Site in the Gulf of Mexico
for Incineration of Chemical Wastes - EPA EIS-WA 76-054,
April 1976
Attached are this Department's comments on subject DEIS.
If there are any further questions regarding this material,
please do not hesitate to call this office (245-7243).
Charles Custard
Attachments
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ilEMORANDUM DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
OFFICE OF THE SECRETARY
O : Mr. Charles Custard, Director, OEA ' DATE- July 1> 1976
OM : Environmental Officer, OAES/OFEPM
JBJECT: Review DEIS - Designation of a Site in the Gulf of Mexico for Incineration
of Chemical Wastes - EPA EIS-WA 76-054, April 1976
Subject document has been reviewed. Comments following are forwarded for
your consideration.
A - General:
1. The document titled "Designation of a Site ..." actually addresses
two issues, site selection and the use of a proposed site. The site
designation is viewed as not having any direct environmental impact;
the potential impact(s) which may occur from permitted incineration
activities at the site are viewed as secondary.
2. If the document is viewed as a draft EIS relevant to future use of
the site for permitted incineration of chemical waster, it would seem
that permitting process becomes an integral part of a proposed action.
In this respect the difference between a research or interim permit for
incineration at sea, page 12 (f) , is unclear since either apparently
can be promulgated until specific criteria are promulgated. Further,
the question arises as to what extent variation in composition of
• material to be incinerated would be allowable if interim permits are
issued subsequently to research burns.
B - Site Designation
' 1. The proposed site is essentially the same as that used for the
1974-75 research and interim burns reorientated for navigational and
control purposes.
2. With respect to site designation, the area selected is appropriate
for a program intended to develop and evaluate sea incineration
techniques and equipment.
3. Data and observations supporting the site designation are contained
in the DEIS - Appendix G, EPA 430 of 9-75-014, Disposal of Organochlorine
Wastes.
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Page 2 . •
C - Support Data and Observations:
1. The support data and observations were developed during 1974-75
burns, under difficult experimental conditions. In this respect
recommendations are contained in the report to rectify identified
problems .
2. Considering the sampling and analysis difficulties detailed in
the report we must reserve judgment on the efficiencies claimed for
the incinerator performance. Destruction efficiencies in excess of
the 99.9% required by the permit are shown on the basis of empirical
calculations, assumptions with respect to feed stock composition,
sampling and combustion product identification.
-^
3. The immediate short-term effects of the incinerator emissions on
die marine environment and biota were not significant. With respect
to long-term biological effect on zoo plankton, etc., the qualification
of "very little life in the dump site" does not readily support "no
evidence of any long range impact from the incineration or organo-
chlorine wastes, "(15" page 72, Appendix G.
4. The report concludes that the "design and operation of the Vulcanus
incinerator were adequate for controlled oxidation or organochlorine wastes
of the type produced by Shell Chemical Company." This conclusion, how-
ever, may not be applicable to other types and classes or organochlorine
compounds, e.g. orange herbicide.
D - Recommendations:
It is recommended that:
*
1. Future use of the designated site be limited to incineration of
wastes of the "type produced by the Shell Chemical Company," until an
adequate monitoring and test program, as noted in Section VI of the
DEIS are developed.
2. The final EIS incorporate as much information as possible with respect
to the status of development of the monitoring and test programs above.
!
3. The recommendations, pages 5 to 8, of the Appendix 6 be incorporated
as permit requirements for future at sea incineration actions.
lond Goldberg (J
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MEMORANDUM DEPARTMENT OF HEALTH, EDUCATION, AND WELFAR
Public Health Service
TO : Director, Office of Environmental Affairs, DATE: June 30, 1976
DH£W
FROM : Principal Environmental Officer
SUBJECT: Comment on EPA DEIS - Designation of a Site in the Gulf of Mexico
for Incineration of Chemical Wastes
Attached are comments on the subject DEIS prepared by Dr. Klauder,
FDA.
These comments are submitted as the PHS comment.
George H. Deming
Acting Deputy
Environmental Officer
Attachment
-------
A/n?A/rrM;> Al\mTTA/T .DEPARTMENI OF HEALTH, EDUCATION, AND WELFARE
MEMJJKAJNDUM PUBLIC HEALTH SERVICE
FOOD AND DRUG ADMINISTRATION
« »
TO : Mr. Boris Osheroff • . DATE: June 28, 1976*
Principal Environmental Officer/H
Through: Director -^"f 0 s \ I
Environmental Impact Staff •)• /*
-------
Response to letter of July 2, 1976 from the Department of Health, Education
and Vfelf are
A. Response to Garments from OAES/OFEPM
General:
The designation of a site for the at-sea incineration of chemical
wastes is a prerequisite to the issuance of a permit. As such, the two
actions, site designation and permit issuance, are inter-related, but the
designation merely provides another alternative that can be considered for
the disposition of the waste. At-sea incineration will be evaluated with
all other viable alternatives prior to any permit action.
Paragraph (f) has been reworded in accordance with the Proposed
Revisions to the Ocean Dumping Regulations and Criteria. The conditions
for the various types of permits that can be issued are described on pages
10-12 of the text. Any waste other than that which was tested during
the research burns would be subject to the testing requirements of the
Permit Program. At this time, the only applicant for use of the site
is the Shell Chemical Company,
Support Data and Observations:
The monitoring and testing program described in Section VI will be
used to evaluate any possible adverse long-term impacts from the use of
the site. Further, the provisions of the Ocean Dumping Regulations and
Criteria, specifically the Impact Categories>and 'Modification of Disposal
Site Use on pages 21 and 22 of the EIS, will be used to assure that
continued use of the site will not be permitted should the monitoring
program reveal any adverse long-term impacts. Additionally, the designa-
tion of the site will be limited to a period of five years.
-------
Peconinendatioins:
The information to be accumulated during any use of the site will be
used to develop criteria for incineration of wastes at sea. This will
also provide further material for use in developing a monitoring and
testing program. The recommendations in Appendix G will be considered
for inclusion in any permit issued for use of the site.
A report has been prepared for EPA by TEW, dated June 1976, which
describes the test program which will be used to acquire emission data
from the at-sea incineration of Shell Chemical Company's chemical wastes.
The test program will evaluate the efficiency of combustion of the various
waste components and will determine the uncombusted or combustion modified
material remaining in the emissions.
The report discusses the following areas:
1. A brief description of the candidate ships, their incineration
operation, and the interface requirements necessary for
obtaining the test samples;
2. The design of the sampling probe and mount, and the sampling
procedure;
3. The approach for on-line monitoring of combustion gases;
4. The acquisition of combustion products;
5. The testing of the work areas to ensure safety during tests;
6. The results of the survey sample furnished by Shell and the
general analytical plan for all the samples taken during waste
destruction tests; and
7. Theoretically expected equilibrium products of wastes chemical
combustion and the theoretical behavior of the combustion
plume emitted from shipboard incineration.
-------
For further information regarding this report, please contact the
preparing office of this EIS.
B. Response to comments from the Public Health Service
The abundance of shrimping and fishing grounds in the Gulf area, as
described in the appendices, precludes the possibility of total avoidance.
Precautions will be taken, however, so as not to interfere with commercial
fishing and shrimping operations while in transit to the site.
Accidental spillage is addressed on pages 73 and 74 of the text.
In addition, reference has been made to the Maritime Administrations
final EIS on the Chemical Waste Incinerator Ship Project. Chapter IV of
that EIS describes the safety and control measures that apply, including
those for cargo transfer operations. Attention is particularly directed
to the section of Chapter IV that discusses the U.S. Coast Guard require-
ments and regulations.
-------
Al
APPENDIX A
PHYSICAL GEOLOGY AND SEDIMENTOLOGY
OF THE GULF OF MEXICO
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A2
PHYSICAL GEOLOGY RELATING TO GULF OF MEXICO
STRUCTURAL SUBDIVISIONS
The Gulf of Mexico is divided basically into two major provinces: a
carbonate province to the east and a terrigenous one to the west (Uchupi,
1967). Further topographic division of the Gulf of Mexico follows Ewing
et al. (1958) and Uchupi (1967), including the following physiographic
provinces: the continental shelf (sub-divided into West Florida Shelf,
Texas-Louisiana Shelf, East Mexico Shelf and Campeche Shelf), the continental
slope (including the Sigsbee, Florida and Campeche escarpments), the
Mississippi Fan (Cone), the continental rise and the Sigsbee Abyssal Plain
(floor of the main basin) (see Fig. A-l).
Antoine (1972) divides the Gulf of Mexico into seven geologic provinces
(Fig. A-2) that he considers to be geologically distinct. Shallow seismic
reflection methods were utilized to demonstrate unique characteristics of
each province, then viewed from a background of other studies to outline the
specific geologic areas - 1) Gulf of Mexico Basin, 2) Northeast Gulf of
Mexico, 3) South Florida Continental Shelf and Slope, 4) Campeche Bank,
5) Bay of Campeche, 6) Eastern Mexico Continental Shelf and Slope, and
7) Northern Gulf of Mexico. Insight into the origin and evolution of the
Gulf led Antoine to describe the basin as geologically old and representing
a subsided oceanic area that has been partially filled with sediments.
PROVINCE ENCOMPASSING PROPOSED INCINERATION SITE (NORTHERN GULF OF MEXICO-//?)
The northwestern Gulf, at least from a structural point of view, is consti-
tuted of the continental shelf and slope of Texas, Louisiana, Mississippi,
and Alabama. According to Ewing et al. (1968), it is bordered on the east
by De Soto Canyon, on the south and southwest by the bottom of Sigsbee Scarp,
and at the United States-Mexico border by the beginnings of the anticlinal
folds that more or less parallel the shoreline. (These folds mark the
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A3
-------
A4
30'
25*
20*
95*
90*
85*
80*
Fig. A-2. Geologic provinces in the Gulf of Mexico (from Antoine, 1972).
1. Gulf of Mexico Basin
2. Northeastern Gulf of Mexico
3. South Florida Continental Shelf and Slope
4. Campeche Bank
5. Bay of Campeche
6. East Mexico Continental Shelf and Slope
7. Northern Gulf of Mexico
-------
A5
northern extension of the Eastern Mexico Province, #6.)
The major structural element of the continental margin of the northwest
Gulf of Mexico is the Gulf Coast Geosyncline. This extends southwestward
from Alabama toward northeastern Mexico and contains upward of 20,000 m of
sediment. The geosyncline is underlain by varying thicknesses of salt,
probably of latest Triassic-Jurassic age (Jux, 1961). The offshore area of
the northwest Gulf, which includes the major portion of the geosyncline,
is characterized by diapiric structures from the coastline to the Sigsbee
Scarp. On the continental shelf most of these features are covered by
sediments, whereas on the slope they are evident in the topography and form
Gealy's "hummocky" zone (Gealy, 1955). It is emphasized by Antoine (1972)
that the widespread salt deposit provides a dynamic structural agent acting
throughout the entire northern Gulf region.
TERRACE MORPHOLOGY
The origin of the continental terrace (shelf and slope) of the northwest
Gulf of Mexico has been a topic for speculation since study of this basin
began. Early investigators suggested that the Gulf basin resulted from
massive Cretaceous or Pleistocene subsidence and faulting of continental
type crust, resulting in the steep Florida, Campeche, and Sigsbee Escarp-
ments (Suess, 1904; Schuchert, 1935; Dietz, 1952; Gealy, 1955; Greenman
and LeBlanc, 1956). This line of thought led to the belief that the
irregular nature of the bathymetry of the upper continental slope off Texas
and Louisiana was caused by subaqueous erosion following subsidence (Dietz,
1952; Gealy, 1955). Pursuing another line of evidence, Shepard (1937) pointed
out the existence of salt diapirs in the Mississippi Trough and Carsey (1950)
speculated that the upper slope topography was a direct result of diapiric
intrusion.
Ewing et al. (1960) and Antoine (1972) through geophysical studies of the Gulf
Basin, have revealed the true oceanic nature of the crust under the deep
-------
A6
Gulf, negating the fault postulate of Gulf origin. Continuous seismic pro-
filing has also corroborated the existence and importance of salt diapirs in
the formation of slope topography (Moore & Curray, 1963; Ewing & Antoine,
1966; Lehner, 1969). Ballard and Uchupi (1970), while achnowledging the im-
portance of diapirs in producing the hummocky zone of the upper continental
slope, point out that events related to Quaternary sea level fluctuations
have left relict features, which also add to shelf and slope topography
(see Fig. A-3).
SLOPE MORPHOLOGY
The continental slope of the northern Gulf of Mexico represents the seaward
part, or the growing margin, of the Gulf Coast geosyncline, where geologic
processes that helped to shape the basin are active today (Lehner, 1969).
Beds that are buried deeply in the Gulf basin are at shallow depths on broad
salt swells and uplifts of the continental slope. Sparker records (Moore &
Curray, 1963; Ewing & Antoine, 1966; Lehner, 1969) show that salt pillows
and swells with diameters of 28-37 km are typical structures on the upper
slope forming seaknolls or seamounts with elevations of as much as 1524 m.
The flat tops of the salt pillows on the lower slope reach a common elevation
and tend to create a terrace-like topography of broad sedimentary troughs.
These synclinal basins are filled with slump deposits and turbidites, most
of which are mud and clay, whose origin was related to the overloading of
the shelf edge by prograding foreset beds, giving rise to extensive submarine
slides on the upper slope. The lower slope terrace breaks off abruptly
along the Sigsbee Scarp, which has the appearance of being the south edge
of a large salt mass. Toward the Mississippi Delta, the upper slope, lower
slope, and Sigsbee Scarp merge into a relatively smooth incline known as
the Mississippi Cone.
TOPOGRAPHY OF NORTHERN GULF SLOPE
The slope is broken in many places by ridges, knobs, canyons, troughs and
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A8
basins. In the northeastern section of the Gulf of Mexico it is interrupted
by De Soto Canyon, a trough which heads near the 440 m contour and terminates
near the 950 m isobath, with a maximum relief ranging from 185 meters (Jordan,
1951) to 250 m (Harbison, 1968). The continental slope off Texas and Louisi-
ana consists of at least two segments, a relatively steep lower slope known
as the Sigsbee Escarpment and an irregular upper segment identified by its
hummocky topography (Uchupi, 1967) (see Fig A-4). The hummocky zone con-
stitutes a major portion of the slope off the Texas-Louisiana shelf. Antoine
(1972) associates the roughness and irregularity of the upper slope to
underlying diapiric structures of Triassic-Jurassic salt and suggests that
the Sigsbee Escarpment represents the present frontal edge of the
salt migration. Other investigators, notably Shepard (1937), Carsey (1950),
Moore and Curray (1963) , Ewing and Antoine (1966), Wilhelm and Ewing (1972),
have also interpreted the hilly topography of seaknolls and seamounts as
developing from growth of salt domes. Others (Gealy, 1955 and Ewing et al.,
1958) considered submarine slides, turbidity currents, and submarine creep
to be very important in shaping the slope topography. To be sure, Gulf-floor
relief was probably altered by erosion and deposition associated with lower
stands of Pleistocene sea level (Watkins et al., 1975) and by the continuing
process of submarine slumping but, as Ewing et al. (1958) suggest, the
dominant source of sediments filling depressions on the upper slope enter
the Gulf with Mississippi River flow.
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A10
DETAILED DESCRIPTION OF GULF OF MEXICO BOTTOM SEDIMENTS
The Recent and near-Recent sediments of the Gulf of Mexico have been ex-
tensively studied by Stetson (1953), Greenman and LeBlanc (1956), Ewing
et al. (1958), Shepard et al. (1960) and other investigators. As a result
of these studies Phleger (1967) implies that the distribution of surface
sediments in this region is better known than for any comparable marine
area in the world. This is essentially true for the embayments, nearshore
waters, and shallow shelf waters of the Gulf. In reality, however, the geology
of the offshore area of Texas and Louisiana is perhaps better known at the
subsurface level than at the surface due to the enormous amount of work with
precision echo sounding and in refraction seismic, gravity, and magnetic
surveying by such investigators as Antoine, Ewing, Bryant, Uchupi, Moore and
Lehner (previously cited). Appelbaum (1972) found that comprehensive sedi-
mentological studies in the northwestern Gulf has been restricted to the con-
tinental shelf and abyssal plain, with limited study on the upper continental
slope.
One of the deeper-water studies was that of Curray's investigations of
Holocene sediments of the northwest Gulf as a part of American Petroleum
Institute Project 51 (Curray, 1960). While utilizing samples from" depths
shallower than 190 meters, he compiled most of what was known of the sur-
ficial sediments and history of Holocene deposition. Bouma (1972) has up-
dated the subject of sediment distribution in the Gulf; however, his data
were obtained from average content within the upper 7 m of the sediment column.
He describes the sediments from the outer shelf and deeper environments as
primarily clay with variable amounts of silt (i.e., pelite - a combination of
all size fractions in the clay and silt range). To show variation in sediment
types, a clayey pelite is defined as a pelite containing 75% or more clay and
a silty pelite as one with 25% or more silt. In Fig. A-5, the 75% clay iso-
pleth indicates clayey and silty pelites while the numbers represent average
clay percentage for the various stations.
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There is essentially no deposition of detrital sediment from the continent
in the relict areas at the present time. This can be shown on the basis of
foraminifera ratios (Phleger, 1960) and by the presence of shallow water
sediments at the surface. The fact that detrital sediments are being de-
posited on the inner continental shelf can be substantiated by the nature of
the material, the presence of pure, indigenous faunas and foraminifera popu-
lation ratios. This suggests that sediment being supplied to the Gulf does
not reach the outer shelf (all sediment may be deposited on the inner shelf),
or if it does, it is being deposited seaward from there. Off the Mississippi
Delta, material coarser than fine silt is transported in small amounts across
the entire width of the shelf but the sites of active deposition are almost
impossible to distinguish. Phleger (1967) speculates that detrital sediments
from the land are being deposited at the present time on the continental slope
and in the basin (see Fig. A-6) but has no certainty of such activity or the
mechanics and amount of this supply. In general, it is felt that the major
source of sediment for the western Gulf is Mississippi River discharge, which
Drennan (1968) found to have an approximate average between 5000nrVsec. (late
fall) and 23,OOOm-Vsec. in the spring. The sedimentary products of weathering
are also supplied by the Rio Grande and many medium and small streams in
conjunction with some material being contributed by marine erosion, of the
coastal zone. During transport to and within the basin the materials are
mixed and sorted by a variety of agents before final deposition.
Appelbaum (1972) concluded that the Brazos, Colorado and Mississippi Rivers
were the main suppliers of sand size sediment to his study area on the upper
continental slope. This area is very proximate to the incineration site,
being bounded on the east and west by 94° and 94°30'W longitude, and on the
north and south by 28° and 27°30'N latitude. His evidence for a mixing of
varied sources stemmed from heavy mineral grain counts when compared to
previous patterns of northern Gulf assemblages (van Andel and Poole, 1960)
with corroboration being afforded through clay mineral analyses.
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A13
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A14
HEAVY MINERAL STUDIES
Work on the heavy minerals of the northwest Gulf began with Bullard's ex-
amination of the heavy mineral suites of Texas river and beach sands in order
to determine their source areas (Bullard, 1942). He concluded that each of
the principal Texas rivers carries a distinct suite of heavy minerals de-
pendent upon the nature of the source rock of the various drainage basins.
Goldstein (1942) divided the northern Gulf of Mexico into four distinct
sedimentary provinces on the basis of heavy mineral suites. These divisions
are the East Gulf province, the Mississippi province, the Western province
and the Rio Grande province. In the northwest Gulf, the Mississippi and
Western provinces are differentiated by a lower percentage of pyroxene and
a higher percentage of leucoxene in the Western province. The Rio Grande
province is distinguished from the Western by a higher percentage of pyroxene
and the presence of basaltic hornblende.
van Andel (1960) pointed out that with the exception of the Colorado River
sedimentary suite, the sediments of rivers emptying into the northwest Gulf
are orthoquartzitic and are derived mainly from the Cretaceous and Tertiary
margins of the Gulf Coast basin. He found modification of the sand in the
basin only slight except for the removal of pyroxenes from Rio Grande and
Mississippi sands exposed during the Pleistocene, van Andel and Poole (1960)
examined the heavy minerals shoreward of the 110-meter contour in order to
determine sand sources. In addition to Goldstein's provinces, these authors
added a Texas coast province characterized by abundant tourmaline with ".ircon
and some epidote. They attributed the Western province assemblage to mixing
during the early Holocene transgression. In their study of the continental
rise, slope, and abyssal plain, Davies and Facundus (1971) found no signifi-
cant alteration of their heavy mineral assemblages taking place during basin-
ward transport of the sediments. As a result, each assemblage enables in-
vestigators to trace the mineral province. The proposed site region receives
heavy minerals from both the Central Texas Province and the Mississippi Province,
the latter providing the greater quantity (see Fig. A-7).
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A15
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A16
SEDIMENT CHARACTER AND DISTRIBUTION
Analyses of the sediment from recent core stations in the general slope region
yielded data concerning grain size and percentage composition for the upper
5-7 cm of core section (TerEco, 1976). These determinations were obtained
by means of wet sieve and settling velocity procedures. Sand was considered
to be any material greater than 0.062 mm in size, regardless of being ter-
restrial or biogenous (i.e. foraminifera tests, mollusk shells or coral debris)
in origin. Later microscopic examination revealed the presence of carbonate
sand and almost complete absence of quartz sand in the coarse fraction obtained
from the core samples. Only the material cored from one station yielded any
quartz sand (very fine in size); however, approximately 99% of its sand-sized
material was biogenically related, mainly coral debris. Figure A-8 shows the
thickness of Globigerina ooze at the site and Figure A-9 is a carbonate percent-
age map. No authigenic grains, glauconite, were noted in any of the samples.
Sixteen core stations were occupied within or near the depth range of the
proposed site area. Those samples revealed almost equal distribution of the
finer sediments - 38% of the cores were predominantly clay and 38% were pre-
dominantly silt. Sand, silt and clay undifferentiated accounted for 18% of
the samples. These findings are consistent and agree with van Andel and
Curray (1960) who described the recent facies of the Gulf continental slope as
homogeneous clays and silty clays, some having a high percentage of planktonic
fo raminifera.
A map of sediment distribution in the northern Gulf was constructed by
Grady (1970) for the National Marine Fisheries Service. In general, his
chart shows sediment types from the shoreline to depths ranging between 100
and 1000 meters for that area north of the 24th parallel. It is notable that
several of the above core stations are located within the limits of his map
and that comparisons reveal almost total agreement with his general sediment
type for that locale. With this in mind and using Grady's work as a base,
-------
A17
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-------
A19
a map of predominant sediment types has been constructed by means of inter-
polation from his control area seaward to the cited core stations. This
compilation is designated as Fig. A-10. One should be aware that some extra-
polation of data was required between 89° and 92° W longitudes; however,
literature related to the Mississippi Cone (Huang and Goodell, 1970;
Wilhelm and Ewing, 1972) indicate the predominant sediment of that area to
>
be foraminiferal clay.
-------
A20
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APPENDIX B
GULF OF MEXICO PHYTOPLANKTON
SPECIES "DISTRIBUTIONS, STANDING CROP DISTRIBUTIONS,
PRIMARY PRODUCTION, AND SEASONAL CYCLES
-------
B2
DISTRIBUTION OF PHYTOPLANKTON SPECIES
GENERAL DISTRIBUTION IN THE GULF OF MEXICO
Phytoplankton sampling in the northern Gulf of Mexico has been sparse, inter-
mittent, and mostly unquantitative. Much of the information on the species
distribution in the central Gulf comes from the reports of Balech (1967),
Saunders and Fryxell (1972), and Steidinger (1972b).
Since phytoplankters are at the mercy of water movement, their distributions
vary with space and time. Thus, considerable overlap of species distributions
would be expected between continental slope waters and the adjacent oceanic
and neritic regions. Temporal variation in the composition of phytoplankton
populations was evident after shipboard analyses of net samples collected
from various stations during successive summer cruises in the northern Gulf
of Mexico (El-Sayed and Turner, in press). During the 1973 cruise diatoms
(Ceratulina pelagica, Rhizosolenia alata, and Thalassionema nitzschoides)
were the most abundant phytoplankters collected; dinoflagellates were rare
in all of the samples. During the 1972 cruise, diatoms were conspicuous only
in Louisiana coastal waters, whereas Trichodesmium sp. (bluegreen alga) and
various dinoflagellate species of the genus Ceratium predominated at other
stations.
Undoubtedly, there are more phytoplankton species present over the continental
slope region than have been recorded. However, it is possible to generalize
on the geographic distributions of some diatom, dinoflagellate, cyanophyte
(bluegreen alga), and coccolithophorid species'. In the following discussion,
several species are listed as being "abundant", "frequently recorded", or
"widespread". It should be noted that these designations reflect a bias of
the samples being discussed since these samples are not actually comparable,
because of different station locations, seasons, and sampling techniques.
-------
B3
Diatoms. Conger et al. (1972) listed 939 diatom species which have
been reported from the Gulf of Mexico. Of all the species in their list,
Rhizosolenia alata is the one most frequently recorded from Gulf waters
throughout the year (Balech, 1967; Saunders and Fryxell, 1972). This species
is also cited as the most important diatom in Apalachee Bay and in the north-
eastern Gulf of Mexico (Curl, 1959). Ceratulina pelagica is present in most
estuarine waters of the Gulf but is occasionally found in continental shelf
waters. Asterionella japonica and Skeletonema costatum occur over the entire
continental shelf, but occasionally are found in oceanic regions (Steidinger,
1973). Although abundant in the northern and northeastern Gulf of Mexico,
Biddulphia chinensis is replaced by 15. regia in coastal waters south of
Cedar Key, Florida. Other diatom species found throughout the Gulf of
Mexico in most months include: Guinardia flaccida, Chaetoceros compressum,
C^. peruvianum, Hemiaulus membranaceus, Jl. hauckii, and Rhizosolenia
stolterfothii (Saunders and Fryxell, 1972).
Over 200 phytoplankton species were recorded from an extensive seasonal sur-
vey in neritic waters of the eastern Mississippi Delta region immediately
north of the continental slope (Thomas and Simmons, 1960). Two diatom
assemblages were noted: a river population consisting of Cyclotella comta,
C^. meneghiniana, Melosira distans, M. granulata, Navicula gracilis, and N_.
rhynococephala; and a Gulf population comprised of Asterionella japonica,
Chaetoceros a^ffinis, Q. decipiens, £. diversus, Nitzschia seriata, Skeletonema
costatum, Thalassionema nitzschoides, and Thalassiothrix frauenfeldii.
Elements of both populations were found in area of convergence between the
river and oceanic waters. Chaetoceros, Melosira, and Rhizosolenia have also
been reported to be the predominant diatom genera in the same region during
a later study (Khromov, 1965).
Fifty miles west of the Southwest Pass of the Mississippi River, Skeletonema
costatum was the most abundant phytoplankton species (Fucik, 1974). Other
predominant diatoms included Cyclotella sp., Melosira sp., Nitzschia pungens,
N_. gubfraudulenta, and Rhizosolenia fragilissima. In both the studies of
-------
B4
Thomas and Simmons (1960) and Fucik (1974), a Melosira-Cyclotella complex
was indicative of river waters while a Asterionella-Chaetoceros-Nitzschia-
Skeletonema-Thalassionema-Thalassiothrix association was indicative of Gulf
water.
The geographic ranges of the predominant species recorded from net samples
by Balech (1967) were plotted by Saunders and Fryxell (1972). Species they
plotted in the region of the proposed site include: Biddulphia chinensis
J5. regia, Ceratulina pelagica, Chaetoceros coarchtatum, £. compressum, Guinardia
flaccida, Hemiaulus membranaceus, _H. sinensis, Rhizosolenia alata, II.
stolterfothii, and Thalassionema nitzschoides.
In oceanic waters within the proposed incineration site between 26°26'N-
26°52'N and 93°38'W - 93°55'W, 29 diatom species were recorded in October 1974
(TerEco, 1974). The most abundant diatom species included Bacteriastrum
delicatulum, Chaetoceros affinis, jC. atlanticum, Navicula sp., Nitzschia seriata,
Rhizosolenia calcar-avis, R.. hebetata, R_. styliformis, and Synedra sp.
Dinoflagellates. Steidinger (1972a) listed 405 dinoflagellate species
which have been recorded for the Gulf of Mexico. In addition she found that
Ceratium furca, C^. fusus;, £. massiliense, and £. trichoceros are widespread
species in both coastal and oceanic waters, while Ceratium teres, Ceratocorys^
horrida, and Pyrocystis pseudonoctiluca are generally present in oceanic
waters (Steidinger, 1972b).
The geographic ranges of the predominant dinoflagellate species recorded from
net samples by Balech (1967) were plotted by Steidinger (1972b). All of the
predominant species were found in the vicinity of the site. They include:
Blepharocysta splendormaris, Ceratium furca, C^. fusus, £. massiliense, C_.
teres, £. trichoceros, £. tripos, Ceratocorys horrida, Dinophysis caudata,
Diplopelta asymmetrica, Gonyaulax polygramma, Heteraulacus polyedricus,
Peridinium brochii, Pyrocystis pseudonoctiluca, and Pyrophacus horologium.
-------
B5
Other Phytoplankters. The cyanophyte, Trichodesmium sp. (=0scillatoria.
probably T_. erythraeum) has been reported to be the most abundant phytoplankter
during certain periods at various locations throughout the Gulf of Mexico
(Ivanov, 1966; TerEco, 1974; Fucik, 1974; El-Sayed and Turner, in press).
Thirty-two coccolithophorid species were collected in qualitative samples
from the Gulf of Mexico (Gaarder and Hasle, 1971), of which Coccolithus
huxleyi and Gephyrocapsa oceanica were the most frequently recorded. In
addition, quantitative samples revealed that JC. huxleyi may become the most
numerous phytoplankton species in offshore waters of the Gulf of Mexico in
late autumn (Hulburt and Corwin, 1972).
PHYTOPLANKTON STANDING CROP DISTRIBUTIONS
Abundance of Phytoplankton Cells;. Mean phytoplankton cell numbers in
2
oceanic regions of the Gulf of Mexico approximate 10 cells/liter (Fukase,
1967; Steidinger, 1973). Similar results were found in oceanic waters im-
mediately south of the northern Gulf slope where cell numbers ranged from
1.30 - 4.88 x 102 cells/liter (excluding Oscillatoria sp.) with Q^cillatoria
sp. values of 0.35 - 48.8 x 102 cells/liter (TerEco, 1974). At stations
close to the 200 m contour along the continental shelf break in the northern
Gulf of Mexico, phytoplankton cell numbers of 0.15 - 1.27 x 103 cells/liter
were found while values of 3.9 x 10^ cells/liter were recorded near the mouth
of the Mississippi River (Hulburt and Corwin, 1972). In continental shelf
waters near the Mississippi Delta, values ranging 'from 0.237 to 3.056 x 10
cells/liter and as high as 6.0 - 9.0 x 106 cells/liter were recorded by
Thomas and Simmons (1960) and Fucik (1974), respectively.
Chlorophyll-a and Total Plankton: Geographical Distribution. Numerous
phytoplankton standing crop values (measured as chlorophyll-a_ concentration)
-------
B6
have been collected over a period of nine years, covering virtually the
entire Gulf of Mexico (El-Sayed, 1972). Averages in the Gulf of Mexico
for chlorophyll-a_ concentrations at the surface and integrated to the
*3 9
bottom of the euphotic zone are 0.20 mg/m and 12.42 mg/m , respectively
(El-Sayed, 1972). Additional measurements obtained during four summer and
Q
autumn cruises revealed similar surface and integrated averages of 0.23 mg/m
o
and 11.50 mg/m (El-Sayed and Turner, in press).
Chlorophyll-^ averages from intermittent sampling without respect to season
for 2° squares of latitude and longitude for the areas which cover the northern
Gulf continental slope are presented in Figure B-l. When compared with the
whole Gulf, northern Gulf averages were low to moderate with surface and
integrated values ranging from 0.009 - 0.20 mg/m and 5.40 - 15.35 mg/m2,
respectively, with highest values east of the Mississippi Delta (El-Sayed, 1972)
A possible reason for surface values in the proposed site being generally
lower than the average for the Gulf of Mexico as a whole, is that the Gulf
average includes data from the productive areas of upwelling near the Yucatan
peninsula.
The low standing crop of the continental slope and oceanic regions is
apparent upon comparison with Fucik's (1974) data from the adjacent con-
tinental shelf region. He reported annual mean surface and integrated
3 9
chlorophyll-^ values of 1.69 mg/m and 23.55 mg/m , respectively.
Soviet investigations in the Gulf of Mexico of total plankton biomass
o
(measured as mg/m wet weight) reveal geographical patterns similar to
those of chlorophyll-a. with the most productive regions being found along
the northeastern continental shelf between the Mississippi Delta and the
northwestern coast of Florida (Khromov, 1965). Plankton biomass in the open
n O
Gulf was low, with values of 100-150 mg/m , compared to 200-1000 mg/mj
in the region near the Mississippi Delta (Khromov, 1965; Bodganov et al.,
1968). Upwelling in the northern Gulf along the bottom of the continental
slope and over the outer edge of the continental shelf was suggested as the
reason for the high productivity (Bogdanov et al., 1968).
-------
B7
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-------
B8
Chlorophyll-a: Vertical Distribution. Typical profiles of vertical
chlorophyll-^ distributions in the Gulf of Mexico reveal low values near
the surface with maximum concentrations to depths of 50-110 m, which in many
cases, coincide with the bottom of the euphotic zone (El-Sayed, 1972; El-Sayed
and Turner, in press), pycnoclines (Hobson and Lorenzen, 1972), or nitrate
nutriclines (El-Sayed and Turner, in press). This pattern appears to be a
regular feature in other oceanic areas (Anderson, 1969; Goering et al., 1970;
Venrick et al., 1973). The subsurface chlorophyll-a_ maximum may be due to
an increase in the chlorophyll-a_ content of shade-adapted phytoplankton cells
(Steele, 1964), increased supply of nutrients (diffusing from deeper layers
into nutrient-poor surface waters) to the phytoplankton of the chlorophyll-^
maximum layer (Anderson, 1969), accumulation of sinking cells at pycnoclines,
or a combination of these factors.
PRIMARY PRODUCTION
Geographic Distribution. Primary production averages for 2° squares of
latitude and longitude for the area over the northern Gulf continental-slope
were low (Fig. B-2) with surface and integrated values ranging from 0.08-
Q 9
0.26 mgC/m /hr and 2.02-4.00 mgC/nr/hr, respectively. Maximum values over
the continental slope were off Panama City, Florida, with surface and integrated
•
averages of 0.43 mgC/m3/hr and 5.0 mgC/m2/hr, respectively (El-Sayed, 1972).
A comparison of oceanic values with Fucik's (1974) data from the adjacent
continental shelf waters reveals the low primary production values of the
continental slope and oceanic waters, i.e., in areas similar to the proposed
site. His annual mean surface and integrated primary production values for
Louisiana coastal waters were 26.53 mgC/m3/hr and 98.56 mgC/m2/hr, respectively.
-------
B9
-------
BIO
Vertical Distribution. In a pattern similar to the vertical chlorophyll-a.
distributions previously discussed, maximum primary production values in the
Gulf of Mexico occur at depths of 20-60 m (El-Sayed, 1972; El-Sayed and Turner,
in press). A probable explanation for the reduced primary production near the
surface is photoinhibition where intense sunlight may bleach photosynthetic
pigments.
SEASONAL CYCLES
Fhytoplankton Species Distributions and Numbers. The only available data
for the northern Gulf of Mexico come from the studies of Thomas and Simmons
(1960) and Fucik (1974), east and west of the Mississippi Delta, respectively.
In both studies, phytoplankton numbers were highest in spring and lowest in
fall in inshore waters, but Thomas and Simmons (1960) found no significant
differences at their most seaward stations. In addition, Fucik found that
diatoms comprised 72-90% of the cell numbers while dinoflagellates accounted
for only 10-28% of the phytoplankters present.
Seasonal Cycles of Standing Crop and Primary Production. Maximum
surface chlorophyll-a_ values for the Gulf of Mexico as a whole were found
in winter, with decreases in the spring followed by gradual increases during
summer and fall. The mean integrated chlorophyll-a_ values for summer and
winter were identical, and only slightly higher than those for spring and
autumn (El-Sayed, 1972).
Seasonal primary production patterns for the Gulf of Mexico as a whole,
generally parallel those of chlorophyll-^ with maximum values in winter
(El-Sayed, 1972). The amplitude of seasonal changes in primary production
and chlorophyll-a_ concentrations in the oceanic regions of the Gulf is small
(El-Sayed, 1972).
-------
Bll
Seasonal differences are much more apparent in inshore waters along the
northern Gulf of Mexico. In waters near the Mississippi Delta, there were
increases in primary production in spring, coinciding with increased river
discharge (Thomas and Simmons, 1960; Fucik, 1974). Primary production
values during the spring of 1973 were six times higher than those of the
previous fall due to the spring flood of the Mississippi River. The flood
drove low-salinity, high-nutrient river water out into the Gulf, forming a
low density layer where high levels of nutrients were maintained near the
surface by stratification (Fucik, 1974). The influence of the Mississippi
River flood may be reflected in high chlorophyll-^ and nutrient levels ex-
tending 30-40 miles seaward into the Gulf and 80 miles west of the river
mouth (Riley, 1937). By contrast, total plankton biomass east of the Mis-
sissippi Delta decreased to 130 mg/nr from mean values of 200-1000 mg/m^
during a period of reduced river discharge (Bogdanov et al., 1968).
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B12
(This page intentionally left blank)
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Cl
APPENDIX C
ZOOPLANKTON SPECIES ENUMERATION, GEOGRAPHIC DISTRIBUTION,
AND STANDING CROP BIOMASS
-------
C2
ZOOPLANKTON OF THE PROPOSED INCINERATION SITE
Zooplankton of the proposed incineration site almost wholly consist of
oceanic forms. The site's distance from shore in conjunction with it's
water depth precludes most larval forms of commercially valuable continental
sh.elf organisms such as the shrimps and crabs. The most abundant zooplankton
groups occurring within the proposed site are copepods, chaetognaths,
euphausiids, and pteropods. Species enumeration and geographical distri-
bution of these latter groups are discussed under their appropriate section.
Although the number of zooplankton species and individuals listed from the
open Gulf waters in the vicinity of the proposed site may seem large, the
site's fauna in comparison to nearshore regions is considered depauperate
(see section on Zooplankton Standing Crop).
DISTRIBUTION OF PREDOMINANT SPECIES
Practically every major animal phylum makes some contribution to the
zooplankton. Although most zooplankters remain planktonic throughout their
existence, a large array of animals occurs in the plankton during only part
of their lives. Those organisms which spend only part of their lives as
plankton are known as meroplankton in contrast to the holoplankton which
remain in the plankton throughout their life cycle. Meroplankton includes
the larvae of benthonic invertebrates (viz., trochophores and veligers of
mollusks, nauplii of barnacles, various larval stages of crabs and shrimps,
larvae of echinoderms, and etc.) as well as eggs and larval stages of many
fish species. Included in the holoplankton are siphonophores, ctenophores,
pteropods, euphausiids, and most copepods and chaetognaths. Of course,
members of most other larger animal groups are also represented in the
holoplankton but do not conform to generalities.
In neritic waters of the Gulf of Mexico (i.e., extending seaward to a depth
of about 200 m) the meroplankton reach their greatest abundance and often
exceed the holoplankton. In the oceanic zone (seaward of the neritic zone)
-------
C3
holoplanktonic species predominateo The only adult shrimp of commercial
importance occurring near the present study area is the royal red shrimp,
Hymenopenaeus robustus. The waters of this study area, however, do contain
small numbers of the meroplanktonic shrimp larvae of various commercially
important species. Temple (1965) reported on 385 plankton tows taken on
the northwestern Gulf continental shelf. The total catch of planktonic
penaeid larvae was 27,800; of this total, the larvae of commercially
important shrimp (Penaeus spp.) made up 207. of the catch with non-commercial
forms, namely Trachypenaeus spp. (47%), Sicyonia spp. (247o) , Solenocera spp.
(77»), and Parapenaeus spp. (27o) making up the remainder. Fig. C-l shows the
yearly distribution of Penaeus spp. larvae in the northwestern Gulf in rela-
tion to the location of the proposed incineration site. Note the decrease
in larval numbers as one approaches deeper water.
By and large the most abundant holoplanktonic zooplankton groups of the
Incineration Site are copepods, chaetognaths, euphausiids, and pteropods.
These four groups will be discussed in detail within the following text.
STANDING CROP
The principal standing crop research within the vicinity of the proposed
site has come from U. S. Fish & Wildlife Service and Soviet-Cuba expeditions.
Arnold (1958) reported on the plankton volumes of about 350 samples collected
Gulf-wide with his west central region encompassing the area of the proposed
3
site (Fig. C-2). He gave the plankton standing crop (ml/m ) collected from
three depth ranges in this locale during springtime sampling as follows:
0-100 fm - .065; 100-1000 fm - .029; over 1000 fm - .008. It is noteworthy
that the standing crop biomass data are lower than that of the adjacent
subregion (Table C-l).
Khromov (1965) and Bogdanov et al. (1969) reported on the distribution of
plankton standing crop collected in conjunction with the Soviet-Cuban
-------
C4
94°
92°
90°
30°
28° •
26°-
PROPOSED
INCINERATION
SITE
JULY-SEPTEMBER 1962
92°
90°
OCTOBER-DECEMBER 1962
26°-
92°
90°
III
JANUARY-MARCH 1963
26° -
Fig. C-l. Distributions of numbers of planktonic-stage
Penaeus spp. per standard plankton tow in the
northwestern Gulf during the period July 1962
to March 1963 (after Temple, 1965).
-------
C5
95'
90'
30'
25'
_PROPOSED
^INCINERATION SITE
Fig. C-2. Arnold's (1958) subregions which relate to the proposed site.
Table C-l .
Gulf of Mexico seasonal plankton standing crop (ml/m3) for the
three bottom depth ranges. Proposed incineration site is within
Area WC as shown on the Figure above. The number of samples is
given in parentheses (from Arnold, 1958).
Area
NW
NC
WC
c
0-100 fms
winter spring fall
. 055 . 104
(10) (14)
.094 .142 .152
(6) (17) (3)
.065
(5)
100-1000 fms over 1000 fms
winter spring fall winter spring
.009
<2>
.113 .061 .074 .091 .054
(4) (ID (1) (2) (4)
.029 .008
(A) (1)
.038 .050
(9) (8)
fall
.096
(6)
.063
(1)
-------
C6
expeditions of 1962-1966. These Soviet researchers' data cannot be directly
compared with Arnold's (1958) since different field and laboratory techniques
were used. However, as will be shown later, the overall picture is about
the same. Figures C-3 and C-4 give the food plankton (net plankton less
the detritus) standing crop as reported by Khromov (1965).
From the studies mentioned above two trends become clear. First, the western
half of the Gulf of Mexico has a lower plankton standing crop than does the
eastern half, and second, the standing crop in the upper layers generally
decreases with increasing distances from shore or increasing depth.
-------
C7
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-------
C9
MAJOR HOLOPLANKTONIC ZOOPLANKTON GROUPS
COPEPODS
Copepods are very small crustaceans, most ranging from less than one
millimeter to several millimeters in length. Marine copepods exist in
enormous numbers; they may be the most abundant metazoans on the earth. It
is their enormous numbers that delegates their importance in the marine food
web. As was shown by Fleminger (1957, 1959), certain copepod species or
groups of species are excellent water mass indicators. Fleminger (1957)
established the value of the pontellid copepods as indicators of Gulf waters.
Labidocera acutifrons and Pontella spiniceps are tropical-oceanic, L. aestiva
and P. meadi are temperate-neritic, and L. scotti is tropical-neritic.
Fleminger (1959) also studied the geographic distribution of calanoid copepods
from Gulf waters based on approximately 500 samples. The majority of the Gulf
species are tropical forms inhabiting equatorial waters around the world.
Some neritic species with temperate North Atlantic affinities vary in their
adaptation to tropical conditions such as Centropages hamatus, Acartia tonsa,
Pseudodiaptomus coronatus, and Labidocera aestiva. These species are numerous
in coastal and estuarine waters with winter minima of 10°C and summer maxima
temperatures of 28°C. When the lowest temperature in winter is 8°C, they
diminish in quantity.
In relation to onshore-offshore gradients Fleminger (1959) found 5 modes of
spatial distribution of copepod species, in successive bands parallel to
the shoreline with overlapping boundaries. Of these modes the following
pertain to and are directly related with the proposed site area:
1. Shelf-Oceanic facies - the outermost shelf and slope: Clausocalanus
furcatus and Undinula vulgaris.
2. Oceanic facies - oceanic waters: Centropages violaceus and
Pontellina plumata.
Park (1970) reported on the calanoid copepods collected with a modified
-------
cio
Nansen net used during R/V CHAIN Cruise 60 in the Gulf and Caribbean.
His study was principally systematic but a check list of species and their
vertical distribution within the oceanic Gulf were gleaned from his data
and are presented in Table C-2. Park's (1970) Gulf samples were chiefly
taken from below 200 m which probably accounts for the large number of
species listed as bathypelagic.
CHAETOGNATHS
The phylum Chaetognatha is a group of exclusively marine invertebrates.
With the exception of the benthonic genus Spadella, all chaetognaths are
holoplanktonic. These organisms are voracious carnivores, feeding heavily
on crustaceans and larval fishes. This, coupled with their being among
the most common plankters, classifies them as being very important in the
marine food web.
Studies by Pierce (1951, 1954, 1962), Adelmann (1967) and Every (1968) have
delineated the Gulf's chaetognath fauna. Pierce's (1951, 1962) and Adel-
mann's (1967) studies were confined to the neritic Gulf while Every's
(1968) study concentrated on the oceanic waters of the Gulf. No obvious
east-west geographical affinities have been found. However, definite neritic-
oceanic distributions are present. In Table C-3 .the .common chaetognatha
found in the Gulf are listed along with their neritic or oceanic affinities.
Sagitta enflata, a cosmopolitan species has been reported to be the most
abundant chaetognath species in neritic as well as oceanic waters. The
remaining species listed in Table C-3 should be considered expatriates when
found outside their designated zones.
-------
Cll
Table C-2. Vertical zonation of calanoid copepods in the Gulf of Mexico
as reported by Park (1970).
Epipelagic
Calocalanus pavoninus
£.' styliremis
Paracalanus parvus
Clausocalanus furcatus
C. paulultis
Heterohabdus spinifera
Ctenocalanus vanus
Euaetideus acutus
E_. giesbrechti
j^colecithricella vlttata
Xucicutia paraclausi
L. favicornis
Mesopelagic
Spinocalanus parabyssalis
j>. brevicaudatus
J5. oligospinosus
Chiridius gracilis
Chirundina streetsii
Gaetanus minor
£. pileatus
Scaphocalanus subcurtus
j[. amplius
^. brevirostris
S^. ma gnus
Scrolecithricella abyssalis
^. dentata
Scolecithrix brady
Temoropia mayumbaensis
Lucicutia clausi
fieterohabdus papilliger
il. vipera
H^. median us
Haloptilus paralongicirrus
Pseudodaugaptilus longiremis
Eucalanus attenuatus
E_. elongatus
Rhincalanus cornutus
Farrania frigidus
Microcalanus pygmaeus
Mimocalanus crassus
M.
M.
cultrifer
_ nudus
Monacilla tenera
Spinocalanus abyssalis
jS. spinosus
j^. pteronus
j^. usitatus
S. horridus
—• ma gnus
Teneriforma naso
Chiridiella bispinosa
—• poppei
Undinella brevipes
Metridia brevicauda
M.
curticauda
Lucicutia curta
L.
ovalis
Bathypelagic
Euchirella pulchra
E_. splendens
Undeuchaeta major
JU. plumosa
Xanthocalanus paululus
Racovitzanus porrecta
Scaphocalanus curtus
^. echinatus
A- major
A- longif urea
§.- acuminatus
Scolecithricella emarginata
S. • • maritima
•
ovata
valens
Heterorhabdus abyssalis
S^. j>seudoarcuata
§.' lobophora
Scollocalanus helenae
S^. persecans
Euaugaptilus nodifrons
E_. palumboi
Haloptilus longicirrus
Bathypontia minor
B. similus
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C12
Table C-3. List of common neritic and oceanic chaetognaths reported
from the Gulf of Mexico.
Species Designation
Sagitta enflata Cosmopolitan
Sagitta hexaptera Oceanic
Sagitta serratodentata Oceanic
Sagitta bipunctata Oceanic
Sagitta decipiens Oceanic
Sagitta helenae Neritic
Sagitta hispida Neritic
Sagitta tenuis Neritic
Krohnitta pacifica Neritic
Pterosagitta draco Oceanic
The majority of Every's (1969) samples were taken with open nets thus
specific vertical distribution data were not obtained. However, upon
examination of data from his opening-closing nets combined with data of
depth of tow vs species collected from open nets, certain distributional
trends appear. From these data Table C-4 was derived denoting those
chaetognaths found in the Gulf and designating their probable vertical
distribution as epipelagic, mesopelagic, or bathypelagic.
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C13
Table C-4. Vertical distribution of Gulf chaetognaths (from
Every (1968).
Pterosagitta draco
Sagitta enflata
Sagitta hexaptera
Sagitta helenae
Krohnitta subtilis
Sagitta decipiens
Epipelagic
Mesopelagic
Sagitta hispida
Sagitta bipunctata
Sagitta serratodentata
Sagitta tenuis
Krohnitta pacifica
Sagitta minima
Sagitta lyra
Eukrohnia fowleri
Eukrohnia hamata
Bathypelagic
Sagitta macrocephala
EUPHAUSIACEA
The euphausiacean fauna of the Gulf is typical of that of the tropical
western Atlantic (James, 1971). Investigations by James (1970) and
Schroeder (1971) showed that 33 species occur in the Gulf. These latter
investigators' samples were concentrated mainly in oceanic waters, but
several of their stations were taken in or very near the present study
area. Dividing the northern Gulf into east and,west: sectors by 90 W
longitude, Schroeder (1971) listed the species by abundance for the north-
west and northeast Gulf. Table C-5 gives the 10 most abundant species
found by Schroeder (1971) in each of the areas. Distributional data pre-
sented by James (1971) documents the presence of Schroeder's most abundant
species in the present study area. Cognizance of sampling technique limi-
tations and lack of seasonal data prompted James (1970, 1971) and Schroeder
(1971) not to speculate on euphausiacean geographical affinities which may
exist for the Gulf of Mexico.
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CIA
Table C-5. The ten most abundant euphausiids, arranged in
decreasing order of abundance, found in the north-
west and northeast Gulf (from Schroeder, 1971).
Northwest
Stylocheiron schumii
Euphausia tenera
Stylocheiron carinatum
Euphausia mutica
Euphausia americana
Stylocheiron affine
Stylocheiron abbreviatum
Nematoscelis microps-atlantica
Stylocheiron longicorne
Euphausia hemigibba
Northeast
Nematoscelis microps-atlantica
Stylocheiron carinatum
Euphausia tenera
Stylocheiron abbreviatum
Stylocheiron schumii
Euphausia americana
Euphausia pseudogibba
Stylocheiron longicorne
Euphausia hemigibba
Stylocheiron affine
James (1971) generalized the vertical distribution of Gulf euphausiids
as (1) Epipelagic - adults common above 100 m, (2) Mesopelagic - adults
from 100-7700m, (3) Bathypelagic - adults below 700 m. Species belonging
to these categories are given in Table C-6.
Table C-6. Vertical distribution of Gulf euphausiaceans. Asterisk
(*) denotes those species reported by Schroeder (1971)
as diurnal vertical migrators.
Epipelagic
Euphausia americana*
IE. brevis*
E.
E.
E.
E.
E.
gibboides*
hemigibba*
mutica*
pseudogibba*
tenera*
Nematoscelis atlantica
Nematoscelis microps
Stylocheiron'abbreviatum
_S. affine
S^. carinatum
.S_.' suhmii
Thysanopoda monacantha
T\ subequalis*
T. tricuspidata*
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C15
Table C-6. Continued
Mesopelagic
Nematobranchion boopis
N^. flexipes
II. sexspinosmn
Nematoscelis tenella
Stylocheiron elongatum
S. longicorne
Stylocheiron maximum
J5. robustum
Thysanopoda cristata
T\ obtusifrons
_T. orientalis
T. pectinata
Bentheuphausia amblyops
Thysanopoda cornuta
Bathypelagic
Thysanopoda egregia
PTEROPOD MOLLUSKS
Pteropods, which are holoplanktonic mollusks, are important contributors
to the plankton of oceanic waters, but are of little importance to the in-
shore or coastal plankton. As emphasized by Bjornberg (1971) an abundance
of pteropod species usually indicates offshore waters. Their direct importance
to man as indicator organisms may soon be more fully exploited. Austin (1971)
has shown that water masses of the eastern Gulf can be recognized and dif-
ferentiated by occurrence of certain pteropods. He concluded that biological
characteristics of water permit a- finer definition of water masses than do
physical or chemical parameters. In particular, Austin found that the velocity
core of the Loop Current and regions of upwelling could be recognized by the
presence of particular species of pteropods and foraminiferans.
The inshore area of the Gulf is depauperate in pteropod species. A compre-
hensive study of the plankton of St. Andrew Bay, Florida was reported by
Hopkins (1966) who found only one species of pteropod, Creseis acicula, which
is also very abundant in offshore waters.
On the northern Gulf shelf, the most abundant pteropod species reported by
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C16
Snyder (1975) were juveniles of Limacina inflata, _L. trachiformis, Creseis
acicula acicula, and _C. virgula conica. From samples taken at the Flower
Gardens (27°54'N, 93°50.5'W) during March 1973 and March 1974, she reported
pteropod abundances of 1003 - 3017/1000 m3 and 9598 - 10,070/1000 m3, respec-
tively for the two years. She believed the fluctuations in abundance to be
typical of pteropod populations in shallow water. For her few stations on the
slope, abundances were up to 12,000 - 14,000/1000 m3. In Gulf oceanic waters
she reported the average concentration of pteropods to range between 10,000 -
20,000/1000 m3.
Of the pteropod species reported by Snyder (1975) , from the slope and oceanic
waters of the Gulf, Limacina inflata was the most common species occurring
in 90% of the samples, and frequently was the most abundant. She reported
abundance for L_. inflata up to 12,400/1000 m for samples taken in the
central Gulf. Listed below are pteropod species which occurred in at least
of Snyderfs samples from Gulf slope and oceanic waters.
Limacina inflata Styliola subula
Creseis acicula acicula Hyalocylis striata
Q. virgula conica Diacria quadridentata
Cavolina inflexa
The vertical distributions of pteropods are somewhat obscured by their
diurnal vertical migrations, but considering only daytime collections,
Snyder separated the Gulf species in to the following two groups:
Group I 0-100 m Group II ^100 m
Limacina trochiformis Limacina inflata
Creseis acicula acicula L_. lesueurii
—• virgula virgula L_. ' ' bulimoides
—• virgula conica Hyalocylis striata
Cavolina inflexa Styliola subula
Diacria quadridentata Clio pyramidata
Peraclis reticulata _C_. cuspidata
Peraclis bispinosa
Cavolina uncinata
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Dl
APPENDIX D
NEKTON OF THE GULF OF MEXICO
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D2
MAJOR NEKTON GROUPS
CEPHALOPODS
Lipka (1975) reported 66 species of pelagic cephalopods from the Gulf.
Most species were represented by very few adult specimens, and collections
of abundant adults occurred at only a few locations. On the basis of such
limited data Lipka was unable to establish any clearcut faunal distributional
patterns within the open Gulf.
Cephalopods of the neritic zone include Doryteuthis plei, Loligo pealei,
and Lolliguncula b re vis. L_. b_revis_ is ubiquitous in nearshore regions where
it generally inhabits estuaries and bays with salinities as low as 17 ppt.
1). plei and L_. pealei tend to be found in more saline waters of the shelf.
The majority of Lipka's pelagic cephalopod samples were collected during
descent or ascent of bottom dredges and trawls. Thus, precise bathymetric
distributional limits were impossible to determine. However, Lipka determined
the probable vertical distributions of certain species based upon morphological
indicators described by Voss (1967). The probable bathymetric distribution
patterns of Lipka's pelagic cephalopods of the Gulf of Mexico are given in
Table D-l.
CRUSTACEANS
Decapod and mysidacean shrimps are conspicuous components of the mid-water
fauna. L. Pequegnat (1972) noted that of the 23 species of penaeid shrimps
known to occur from depths below 200 m, only six are pelagic, and only two of
these (Gennadas valens and Bentheogennema intermedia) can be considered
"common". Of the 63 species of caridean shrimps occurring below 200 m, 22
species are pelagic, and only three of these (Acanthephyra purpurea, Acanthephyra
stylorostrata, and Systellaspis debilis) may be called "common". Ten species
of deep-sea mysidacean shrimps are known from the open Gulf, and only three of
these (Gnathophausia ingens, Eucopia australis, and Eucopia sculpticauda)
are considered "common".
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D3
Table D-l. Vertical distribution of Gulf cephalopoda (from Lipka, 1975)
Epipelagic (0-200 m)
Onykia carriboea
Onychoteuthis banksi
Onnnastrephes^ pteropus
Ommastrephes bartramij.
Thysanot euthis rhombus
Liocranchia reinhardti
Leachia cyclura
Cranchia scabra
Heteroteuthis hawaiiensis
Tremoctopus violaceous
Argonauta argo
Mesopelagic (200-700 m)
Enoploteuthis leptura
Enoploteuthis anapsis
Abralia veranyi
Abralia grimpei
Pyroteuthis margaritifera
Pterygioteuthis giardi
Pterygioteuthis gemmata
Lycoteuthis dladema
Oregoniateuthis spring^eri
Selenoteuthis scintillans^
Histioteuthis corona corona
Histioteuthis dofleini
Bathypelagic (700-2000 m)
Chiroteuthis lacertosa
Bathyteuthis abyssicola
Mastigoteuthis glaucopsis
Mastigoteuthis grimaldi
Joubiniteuthis portieri
Cycloteuthis sirventi
Japetella diaphana
Eledonella pygamaea
Grimalditeuthis bomplandii
Sandalops ecthambus
Corynomma speculator
Egea inermis
Phasmatopsis oceanica
Bathothauma j^yromma
Helicocranchia pfefferi
Helicocranchia papillata
Megalocranchia megalops
Vampyroteuthis infernalis
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D4
L. Pequegnat (based upon unpublished research still in progress) has provided
information concerning approximate depth ranges, areas of occurrence, and
relative abundance of the meso-and bathypelagic species of penaeid, caridean,
and mysidacean shrimps of the Gulf of Mexico (Table D-2).
Table D-2. Meso-and bathypelagic shrimps and their distribution and relative
abundance in the Gulf of Mexico listed in order of relative
abundance within each group.
MESOPELAGIC (200-700 m)
Area of Gulf
Relative in Order of
Abundance Abundance
PENAEIDAE
*Gennadas valens (Smith, 1884)
*Bentheogennema intermedia Bate, 1888
*Gennadas capensis Caiman, 1925
Gennadas scutatus Bouvier, 1906
*Gennadas bouvieri Kemp, 1909
Gennadas talismani Bouvier, 1906
CARIDEA
*Acanthephyra purpurea A. Milne-Edwards, 1881 Common
*Systellaspis debilis (A. Milne-Edwards, 1881) Common
*0plophorus gracilirostris A. Milne-Edwards, 1881 Sparse
*0plophorus spinicauda A. Milne-Edwards, 1881 Sparse
*Parapandalus richardi (Courtiere, 1905) Sparse
Psathyrocaris infirma Alcock & Anderson, 1894 Rare
Abundant
Common
Sparse
Sparse
Sparse
Rare
NE,NW,SE,SW
SW,NE,NW,SE
SE,NE,NW,SW
SE, NE
SE,NE,SW
NE,SE
MYSIDACEA
*Gnathophausia ingens (Dohrn, 1870)
*Gnathophausia zoea Willemoes-Suhm, 1875
Common
Common
SW,NW,NE,SE
SW,NW,NE,SE
SW,SE,NE,NW
SW,SE,NE,NW
SW,SE,NE
SW
NE,SE,NW,SW
SE,SW,NE,NW
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D5
Table D-2. Continued
BATHYPELAGIC (700-2000 m)
CARIDEA
Acanthephyra stylorostrata (Bate, 1888)
*Acanthephyra acanthitelsonis Bate, 1888
*Acanthephyra curtirostris Wood-Mason, 1891
*Acanthephyra acutifrons Bate, 1888
*Notostromus gibbosus A. Milne-Edwards, 1881
*Acanthephyra brevirostris Smith, 1885
Oplophorus spinosus (Brulle, 1835)
Ephyrina benedicti Smith, 1885
Meningodora mollis Smith, 1882
*Parapasiphai cristata Smith, 1884
*Ephyrina hoskynii Wood-Mason, 1891
Acanthephyra pelagica (Risso, 1816)
Notostomus longirostris Bate, 1888
Hymenodora sp.
Hymenodora glacialis (Buchholtz, 1874)
Parapasiphae sulcatifrons Smith, 1884)
MYSIDACEA
*Eucopia sculpticauda Faxon, 1893
*Eucopia australis Dana, 1852
*Gnathophausia gracilis Willemoes-Suhm, 1873
Gnathophausia gigas Willemoes-Suhm, 1873
Relative
Abundance
Common
Sparse
Sparse
Sparse
Sparse
Sparse
Rare
Rare
Rare
Rare
Rare
Rare
Rare
Rare
Rare
Rare
Common
Sparse
Rare
Rare
Area of Gulf
in Order of
Abundance
SW,NE,NW
NE,SW,NW
SW,NE,NW,SE
SW,NE,NW,SE
NE,NW,SW,SE
NW,SW,NE
SW,NE
SW,NW
SW,NE
SW,NE
SW,NE
SW
SW
SW.
SW
NW
SE,SW,NE,NW
NE,SE
NE,SE
SW
* Known to occur over the continental slope in the northern Gulf of Mexico.
FISHES
The fish groups which predominate in the mid-water areas of the Gulf of Mexico
include the hatchetfishes (Sternoptychidae), lanternfishes (Myctophidae),
lightfishes (Gonostomatidae), viperfishes (Chauliodontidae), and scaleless
dragonfishes (Melanostomiatidae). Very little is known of the distribution
of any of these groups in the northern Gulf of Mexico except the hatchetfishes.
Baird (1971) noted the general world-wide depth distribution patterns for the
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D6
following three sternoptychid genera:
Argyropelecus - high seas, pelagic; upper 600 m
Polyipnus - close to shore
Sternoptyx - high seas, pelagic; 500-1500 m
Bright and Pequegnat (1969) reported that of the 10 species of hatchetfishes
known from the Gulf of Mexico, 8 are distributed Gulf-wide and are probably
residents, and 2 species (Argyropelecus amabalis and Polyipnus laternatus)
appear to be transients which are transported into and out of the eastern
Gulf by the Loop Current. Within the Gulf, hatchetfishes occur chiefly between
the depths of 250 and 1500 m. They are apparently not associated with the
sound-scattering layers above 200 m in the Gulf (which are apparently caused
by invertebrates rather than by fishes). The data of Bright and Pequegnat
suggest ascent at night and descent during the day for Argyropelecus aculeatus
and most other members of the family. However, the reverse migration is
suggested for Sternoptyx diaphana and possibly Argyropelecus hemigymnus, both
of which tend to inhabit the deeper layers. Information concerning species
of hatchetfishes taken with opening-closing midwater trawls at three depth
levels in the Gulf of Mexico is given in Table D-3.
In order to obtain information on the other groups of midwater fishes not
previously reported upon in the literature, data were compiled on those mid-
water fishes fortuitously collected during descent and ascent of the benthic
trawls and dredges within the depth limits of this study. Generally the
fishes collected were small, since the larger, more mobile forms could more
easily avoid capture. Also, mesopelagic and bathypelagic fishes, as a
whole, tend to be smaller than epipelagic or benthonic representatives. The
most commonly collected species (Table D-4 ) are from families Sternoptychidae
(hatchetfish), Chauliodontidae (viperfishes), Gonostomatidae (lightfishes) and
Myctophidae (lanternfishes).
Most of the midwater pelagic fishes collected are well adapted to deep-sea
pelagic life. Besides luminescent organs along the body which are possessed
-------
D7
Table D-3. Numbers of hatchetfish caught per hour using opening-closing
device (from Bright and Pequegnat, 1969).
Depth
range (meters)
Hours
trawling time
Argyropelecus
af finis
Argyropelecus
gigas
Argyropelecus
hemigymnus
Argyropelecus
aculeatus
Argyropelecus
olf ersi
Argyropelecus lynchus
lynchus
Stemoptyx
diaphana
Polyipnus
asteroides
All
species
D
N
D
N
D
N
D
N
D
N
D
N
D
N
D
N
D
N
D
N
0- 175-
175 500
4.8 3.0
1.9 4.4
0.2
1.0
1.1
3.3
0.5 1.8
0.5
1.0 1.8
2.0
0.2
0.3
0.2
5.7
1.6 6.0
500-
900
0.8
2.4
1.2
-
2.4
8.4
6.8
12.0
6.8
D-Day
N -Night
-------
D8
by many of these fishes, some have luminescent organs on their barbels which
may act as lures for attracting prey. Since food is relatively scarce in the
nesopelagic and bathypelagic zones, the principle of large predator-small prey
breaks down. A good example of this is Chauliodus sloanei which can engulf
prey larger than it is by the means of opening its mouth and extending its
stomach. Various other degrees of specialization are encompassed among the
pelagic fishes collected during this investigation. Table D-5 lists the most
commonly collected Gulf pelagic fish species, along with their respective
families, collected within the depth limits of this study.
Table D-4. Most commonly collected pelagic fishes in descending
rank of occurrence.
Species Family
Sternoptyx diaphana Sternoptychidae
Chauliodus sloanei Chauliodontidae
Gonostoma elongatum Gonostomatidae
Yarella blackfordi Gonostomatidae
Cyclothone sp. Gonostomatidae
Neoscopelus macrolepidotus Myctophidae
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D9
Table D-5.
Alphabetized list of Gulf pelagic fish collected within those
depth limits of the proposed incineration site.
SPECIES
FAMILY
COMMON NAMES
Antennarius radiosus Carman, 1896
Apogon sp.
Argyropelecus gigas Norman, 1930
Argyropelecus lynchus Carman, 1899
Argyropelecus sp.
Aristostomias grimaldii Zugmayer, 1913
Avocettina infans (Gunther, 1878)
Balistes capriscus Gmelin, 1788
Bathophilus pawneei Parr, 1927
Bathyclupea argentea Goode & Bean, 1895
Bregmaceros atlanticus Goode & Bean, 1886
Bregmaceros cayorum Nichols, 1952
Chauliodus sloanei Bloch & Schneider, 1801
Chloroscombrus chrysurus (Linnaeus, 1766)
Cyclothone sp.
Diaphus metopoclampus Cocco, 1829
Diplophos taenia Gunther, 1878
Epigonus pccidentalis Goode & Bean, 1895
Epigonus pandionis (Goode & Bean, 1881)
Epinnula magistralis Poey, 1851
Equetus acuminatus
(Bloch & Schneider, 1801)
Evermannella sp.
Gonostoma elongatum Gunther, 1878
Hygophum macrochir (Gunther, 1864)
Lagocephalus laevigatus (L., 1766)
Macdonaldia sp.
Macrorhamphosus scolopax (Linnaeus, 1758)
Malacosteus niger Ayres, 1848
Melamphaes beanii Gunther, 1887
Melamphaes sp.
Melanostomias biseratus
Regan & Trewavas, 1930
Mullus auratus Jordan & Gilbert, 1882
Neoscopelus macrolepidotus Johnson, 1863
Notacanthus analis Gill, 1883
Oxyodon sp.
Peprilus burti Fowler
Photostomias sp.
Polymixia lowei Gunther, 1859
Selar crumenophthalmus (Bloch, 1793)
Sphoeroides parvus Shipp & Yerger
Sphoeroides splengeri (Bloch, 1782)
ANTENNARIIDAE
APOGONIDAE
STERNOPTYCHLDAE
STERNOPTYCHLDAE
STERNOPTYCHIDAE
MALACOSTELDAE
NEMICHTHYIDAE
BALISTLDAE
MEIANOSTOMIATIDAE
BATHYCLUPEIDAE
BREGMACEROTLDAE
BREGMACEROTLDAE
CHAULIODONTIDAE
CARANGIDAE
GONOSTOMATIDAE
MYCTOPHIDAE
GONOSTOMATIDAE
APOGONIDAE
APOGONIDAE
GEMPYLIDAE
SCIAENIDAE
EVERMANNELLIDAE
GONOSTOMATIDAE
MYCTOPHIDAE
TETRAODONTIDAE
NOTACANTHIDAE
CENTRISCIDAE
MALACOSTEIDAE
MELAMPHAEIDAE
MELAMPHAEIDAE
MELANOSTOMIATIDAE
MULLIDAE
MYCTOPHIDAE
NOTACANTHIDAE
APOGONIDAE
STROMATEIDAE
MALACOSTEIDAE
POLYMIXIIDAE
CARANGIDAE
TETRAODONTIDAE
TETRAODONTIDAE
Frogfishes
Cardinalfishes
Hatchetfishes
Hatchetfishes
Hatchetfishes
Snipe eels
Triggerfishes
Scaleless dragonfishes
Codlets
Codlets
Viperfishes
Jacks & Pompanos
Lightfishes
Lanternfishes
Lightfishes
Cardinalfishes
Cardinalfishes
Snake mackerals
Drums
Lightfishes
Lanternfishes
Puffers
Spiny eels
Snipefishes
Scaleless dragonfishes
Goatfishes
Lanternfishes
Spiny eels
Cardinalfishes
Butterflyfishes
Beardfishes
Jacks & Pompanos
Puffers
Puffers
-------
DIG
Table D-5. (Continued)
SPECIES FAMILY COMMON NAMES
Stenotomus caprinus Bean, 1882 SPARIDAE Porgies
Sternoptyx diaphana Hermann, 1781 STERNOPTYCHIDAE Hatchetfishes
Stomias ferox Reinhardt, 1842 STOMIATIDAE
Stomias sp. STOMIATIDAE
Synagrops bella (Goode & Bean, 1895) APOGONIDAE Cardinalfishes
Synagrops spinosa Schultz APOGONIDAE Cardinalfishes
Trachurus lathami Nichols CARANGIDAE Jacks & Pompanos
Trichiurus lepturus L., 1758 TRICHIUR3DAE Cutlassfishes
(Atlantic)
Upeneus parvus Poey, 1851 MULLIDAE Goatfishes
Yarella blackfordi Goode & Bean, 1895 GONOSTOMATIDAE Lightfishes
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El
APPENDIX E
ZOOBENTHOS OF THE
GULF OF MEXICO
-------
E2
THE ZOOBENTHOS
The aggregate of animals living on (and in) the bottom and those sub-
stantially dependent upon bottom organisms as food constitute the zoobenthos
(in the photic zone there may be a well-developed phytobenthos). The
composition and structure of the substratum is the key to the fundamental
nature of the benthic faunal assemblages found in a local area of the marine
environment. Hard bottoms support groupings of organisms that are almost
wholly categorized as epifaunal species; those species on the other hand that
inhabit soft bottoms and live within the unconsolidated sediments are called
infaunal species. These broad definitions leave decisions as to how the
following kinds of organisms should be fitted into these major categories:
1) Species, generally quite mobile, that live on the surface of soft
bottoms (often called level bottoms) and do not burrow into them
(so far as is known), e.g., the giant red crab, Geryon quinquedens,
are relegated to the epifauna (soft-bottom type).
2) Species that are quite mobile and move over soft bottoms but that
burrow in largely for refuge and possibly for protection of newly
hatched individuals and emerge to feed on the sediment surface,
e.g., the caridean Glyphocrangon nobilis and possibly the giant isopod
Bathynomus ffiganteus, even though they burrow into the sediments,
should be treated as epifaunal species.
3) Species that burrow into hard substrata, siltstone for example,
and remain there for life, e.g., the date mussel, Lithophaga
plumula, are considered to be epifaunal species - since this habit
is essentially a special extension of the sessile life that is so
typical of hard substrata.
Demersal fishes might seem to present a special problem, but it seems best
to let them remain in this category. Some prefer to set apart those species
that have a very intimate physical relationship with the bottom, even
burrowing into sediments, such as benthic fishes. In any case if one should
-------
E3
assign these demersal fishes to one or another of the above categories,
it is apparent that they bear greater functional relationships with the
epifauna than with the infauna.
This leaves, then as infaunal those species that are intimately bound with
the soft bottom substratum, usually burrowing into it, having limited
mobility, if any, as adults, except perhaps within burrows, and that feed
wholly within the sediments by either drawing water into their burrows or
moving through the sediments. Typical infaunal species dealt with here
are most (but not all) of the bivalve mollusks, some holothurians, some
echinoids, some polychaete annelids, etc. Excellent examples, although
not under consideration in this report, are much of the meiofauna, e.g.,
tiny nematodes, megaciliates, and tardigrades, inter alia.
The numbers of species of organisms living on hard substrata have been
estimated by Thorson (1957) to far exceed those living on level bottoms.
This is probably true in deep water, and it certainly applies if the macro-
fauna only is considered. One wonders, however, just how the comparison
would change if the meiofaunal component were included.
In the depth range of this report (<600 to >1000 fm) major areas of hard
bottoms are scarce. Secondary hard bottoms (Remane, 1940) such as mollusk
shells and small rocks are about the only developments that are observed.
These serve as the substratum for small brachiopods (e.g. Pelagodiscus
atlanticus), such bivalves as Bentharca, some barnacles (Verruca and
Scalpellum), a few ecotoprocts, and an occasional gorgonian, horny coral
(Chrysogorgia).
Numerous benthic stations have been sampled in the near vicinity of the
proposed incineration site by personnel of TerEco Corporation, however,
none were within its perimeter. Those samples have been worked, i.e.,
species identified and enumerated, but these data have not been presented
in published form. These collections, obtained by means of either dredging
of trawling, are presented in Table E-l.
-------
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E10
BENTHIC FAUNAL ASSEMBLAGES
The concept of benthic animal communities seems to have been formulated
first in the late 19th century by Karl MHbius as an outgrowth of his
observation of oyster reefs. Presumably he intended the word "biocoenosis"
to apply to those groupings of animals that were near equilibrium with
the totality of their environment. If true, this implies an integration of
species actions, involving interdependencies, that marine ecologists tend
to assume do occur even though they may not be able to demonstrate their
nature. The difficulty of obtaining these critical data is recognized in
the definition of a community presented by Mills (1969) as follows. "
a group of organisms occurring in a particular environment, presumably
interacting with each other and with the environment, and separable by
means of ecological survey from other groups." This definition is quite
acceptable to many ecologists, but others find Krebs1 (1972) operational
definition better fits the state of our knowledge of marine benthic communi-
ties, especially those in deep water, when he says that a community may be
thought of as "any assemblage of populations of living organisms in a
prescribed area or habitat." This is similar to Pager's (1963) wholly
operational definition: "a community is any group of species which are
often found living together." No matter which definition seems preferable,
one should be willing to agree that in a community one is dealing with
(1) populations of organisms that together make up (2) assemblages of co-
incidental species that (3) exhibit sufficient degrees of recurrence in
prescribed areas as to (4) repudiate the notion that they are simply ran-
domly assembled collections of species.
The acceptability of the above definitions is heightened by the fact that
none of them puts any limit on the size of communities nor does any one
require that attempts be made to include every species that lives in the
habitat. This is especially important to marine benthic studies where
species diversity can be high and the availability of species-level
taxonomic expertise may be low. Moreover, the shift from pelagic to
benthic environments, the large range of size and motilily of the consti-
tuent species, and changes in substratum type demand that several sampling
-------
Ell
techniques be employed if any reasonable approximation of a "complete" repre-
sentation of the constituents of a marine community is to be achieved. For
these reasons, the discussion and description of communities in the follow-
ing pages is limited to large benthic organisms that can be captured by means
of dredges and/or trawls. Even here sampling problems in deep water could
easily dissuade one from attempting to discuss deep-benthic communities
except for one thing, viz., that after gaining a backlog of experience one
cannot but be impressed by the observation that when the catch of a trawl or
dredge from a particular isobath of habitat is laid out on the deck it is
similar to but not identical with recurrent groups of species taken pre-
viously by the same gear. This is not new. Petersen (1918) was motivated
to write about "recurrent organized systems of organisms" that were revealed
in his grab samples. At that time he was impressed by similarities among
samples, as expressed in terms of species presence and abundance. Acceptance
of this concept of recurrent groups has been advanced by Fager and others,
but in so doing neither he nor others have necessarily felt constrained to
accept more tenuous portions of the concept of "parallel communities",
which was championed in recent years by the late Gunnar Thorson.
Benthic communities are somewhat easier to define than pelagic communities,
due to the fact that the bottom represents a barrier to many organisms,
a surface of action (feeding, reproduction) for others, and a haven of
protection for the burrowing forms. Communities still range over broad
areas, however, due to extensive areas of similar environmental conditions.
Collard and D' Asaro (1973), quoting several other authors, state that,
while abiotic factors such as temperature, salinity, turbidity, sediment
depositional rates, currents, physico-chemical and geographic barriers are
important modifiers of community structure and distribution, substrate
remains as the single key abiotic factor influencing communities. Biotic
modifiers and determinants of community structure include predation, competi-
tion, physiological tolerances, and population characters (fecundity,
longevity, mortality, etc.).
In the present study of the faunal assemblages residing on the continental
-------
E12
slope of the northern Gulf between depths of 550 and 1000 fm, one is con-
cerned with benthic organisms ranging in size from small (1 cm or so)
palaeotaxodont bivalves to fishes of considerable size. The meiofauna are
excluded by design and some of the larger and more mobile invertebrates
and vertebrates may have been missed by sampling shortcomings. Then too,
only those species that seem to predominate by frequency of occurrence and
population size are included in the assemblages.
Probably one should not attempt here to take a firm position as to whether
or not the communities on the shelf and slope are more nearly discrete
functioning units easily separable one from the other or whether they form
a continuum of assemblages wherein the components are responding to complex
and usually poorly understood environmental gradients. Nevertheless, the
idea of a continuum is attractive if one remains aware of the fact that some
of the component species have rather definite depth limits along a given
vertical transect. When many species tend to attain a lower or upper depth
limit on the same isobath (or near to it), their clusters within the continuum
tend to be impressive. But when, on the other hand, groups of species have
wide bathymetric ranges starting and stopping depthwise without obvious
reason, one may focus more on the continuum than on the smaller and more
discrete clusters. Clearly then there are groups within groups, as will be
demonstrated on both the shelf and the slope. So far as can be told, however,
there is no hierarchical arrangement, the "within" groups simply being made
up of species that for one reason or other have smaller ranges of distribution
than others. The truly interesting point is related to the limiting
factors rather that to whether or not they form discrete functioning units.
The approach to describing the faunal assemblages will be to list under the
proper assemblage name those species that are essentially limited to the
bathymetric limits stipulated for the assemblage as a whole. However, a study
of the two proposed assemblages revealed that several species occupied the
entire depth range of the proposed site area. These components of the zoobenthos
include: Glyphocrangon nobilis (Caridean shrimp), Geryon quinquedens (Brachyuran
crab), Stereomastis sculpta (Macruran decapod), Nymphaster arenatus (Starfish),
-------
E13
Bathypterois quadrlfilis (Demersal fish), and Venefica procera (Demersal
fish).
The constituent species of what one can consider as a true lower slope
assemblage are broken down into the following two zones.
Lower Slope Assemblage
Upper Zone (550 to > 800 fm)
Nematocarcinus rotundus
Glyphocrangon aculeata
Heterocarpus oryx
Glyphocrangon alispina
Benthesicymus faartletti
Bathyplax typhla
Homolodromia paradoxa
Munidopsis sigsbei
Munidopsis spinosa
Munida valida
Uroptychus nitidus
Parapagurus pilosimanus
Nephropsis agassizi
Bathynomus giganteus
Benthodytes sanguinolenta
Mesothuria lactea
Goniopecten demonstrans
Astropecten americanus
Doraster constellatus
Tindaria amabilis
Dicrolene intronigra
Monomitopus agassizi
Stephanoberyx monae
Dibranchus atlanticus
Synaphobranchus oregoni
Caridean shrimp
Caridean shrimp
Caridean shrimp
Caridean shrimp
Penaeid shrimp
Brachyuran crab
Brachyuran crab
Galatheid crab
Galatheid crab
Galatheid crab
Galatheid crab
Pagurid crab
Macruran decapod
Giant isopod
Holothuroid
Holothuroid
Starfish
Starfish
Starfish
Bivalve mo Husk
Demersal fish
Demersal fish
Demersal fish
Demersal fish
Demersal fish
-------
E14
Upper Zone (Continued)
Nezumia hildebrandi
Cariburus zaniophorus
Cariburus mexicanus
Demersal fish
Demersal fish
Demersal fish
Middle Zone « 950 to 1350 fm)
Nematocarcinus ensifer
Glyphocrangon longirostris
Benthesicymus cereus
Munidopsis nitida
Polycheles validus
Benthodytes lingua
Litonotaster intennedius
Dytaster insignis
Hemipterois sp.
Cataetyx sp.
Caridean shrimp
Caridean shrimp
Penaeid shrimp
Galatheid crab
Macruran decapod
Holothuroid
Starfish
Starfish
Demersal fish
Demersal fish
DENDROGRAM SHOWING FAUNAL RELATIONSHIPS
The diagram in Fig. E-l is based upon unpublished data obtained from
numerous dredge and trawl stations within the deep aspects of the Gulf of
Mexico. Instead of pooling the results of sampling around each isobath,
in constructing the dendrogram, station data have been used and then re-
flected on the isobath in an attempt to delineate faunal assemblages.
The dendrogram seems to point to important faunal breaks around 550 fm,
between 800 and 950 fm, and near 1350 fm.
This dendrogram is based upon the index of similarity I, which is calculated
by using the value
2j
2ab-(a-fb)j
-------
E15
where a and b are the respective number of species in two samples and j is
the number of species common to both samples. Mountford (1962) derived the
index, based on logarithmic-series distribution, and showed it to be less
dependent on sample size than earlier ones. This method tends to classify
stations into groups of similar stations on the basis of the fauna collected
at each and makes use not only of the index of similarity between a pair of
single stations, but also of an index of similarity between two groups of
stations. The index between a station B and a group composed of A., and A_
is defined as
I (A B) + I (A B)
; B) = ___:
where I(A B) is the index of similarity between the pair of stations A
and B; and, in general, the index of similarity between a station B and a
group composed of m stations is defined as
I(A B) + I(A2B)... + I(A B)
I(A1,A2...Am; B) =
m
The index between a group composed of stations A and A and a second group
composed of stations B.. and B2 is
In general the index between groups A-, A0, ... A and B,, B0, ... B .
1 2. m 1 2. m
is defined as
m n
1
ran i«=l j=l
-------
E16
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-------
Fl
APPENDIX F
METEOROLOGICAL AND PHYSICO-CHEMICAL DATA
PERTAINING TO THE PROPOSED SITE
-------
F2
Table F-l. Percent frequency of observations noting visibilities of
<0.5, <1, and<5 miles for the 2° square bounded by 26°-28°N,
92°-94°W (from data furnished by NCC for square 62 of Marsden
Square 82).
MONTH VISIBILITY (7» FREQUENCY)
•CO. 5 MILE
Jan. 0.5
Feb. *
March 0. 2
April *
May 0. 2
June *
July *
Aug. *
Sept. *
Oct. 0.6
Nov. 0.4
Dec. *
ANN 0. 16
< 1 MILE
0.5
0.2
0.2
*
0.4
0.2
*
*
*
0.6
0.6
*
0.23
< 5 MILE
4.5
3.4
5.9
4.9
1.6
1.4
1.5
1.3
1.5
1.8
1.7
1.6
2.6
OBS
441
411
505
452
556
583
600
688
608
622
522
561
* Less than 0.05%
-------
F3
Table F-2. Percent frequency of relative humidity in the area of the
site (from data furnished by the National Climatic Center,
Asheville, N.C. for 5° square number 50 of Marsden Square
82).
MONTH Hr,GMT RELATIVE HUMIDITY CLASSES DBS
31-40 41-50 51-60 61-70 71-80 81-90 91-100
JAN
FEB
MAR
APR
MAY
00
06
12
18
.3
.1
.2
1.2
1.8
2.2
2.9
7.8
8.1
8.1
12.0
17.9
19.5
16.8
16.0
23.3
20.0
21.5
20.0
32.5
30.0
35.2
34.6
16.9
20.4
16.3
14.1
720
827
731
865
00
06
12
18
.4
.1
.5
2.2
1.7
.7
1.7
6.9
6.2
6.7
9.1
15.3
13.0
14.4
14.9
20.2
21.9
18.3
25.4
37.0
37.4
38.8
37.8
18.0
19.6
20.9
10.4
668
754
688
767
00
06
12
18
.1
.5
.4
.5
3.9
3.1
4.4
4.1
10.0
7.9
8.4
13.2
15.0
13.7
13.8
15.7
17.3
15.2
18.2
22.5
35.8
34.4
33.3
34.3
17.7
25.2
21.3
9.4
693
834
726
848
00
06
12
18
00
06
12
18
.3
.3
.1
.2
.1
1.6
1.0
1.2
2.6
1.4
.5
.5
1.8
7.9
6.6
6.2
11.3
7.2
3.0
3.5
7.1
14.5
11.6
13.2
15.1
12.9
9.0
7.1
18.6
19.9
13.1
15.1
25.8
33.1
21.9
26.3
35.9
43.1
42.7
42.4
35.3
32.8
45.0
44.6
28.1
12.7
24.5
21.8
9.7
12.5
20.5
17.7
8.4
692
773
682
846
650
796
733
835
JUN 00
06 .1
12
18 .2
JUL 00
06
12
18
AUG 00
06
12
18
1.5
.7
.9
2.8
19.7
4.8
5.0
26.7
49.3
39.4
45.0
SO'. 5
23.6
41.0
38.4
' 13.1
5.9
13.9
10.7
6.6
785
862
782
895
.2
.4
.1
.1
.6
2.0
.3
.3
3.8
3.2
.5
.9
4.4
35.9
10.0
11.4
47.8
30.7
10.5
11.2
38.2
46.6
61.4
62.5
36.6
45.9
58.1
57.3
37.7
12.6
21.2
20.1
7.7
15.3
23.2
24.1
11.9
2.7
7.1
5.4
3.8
4.9
7.6
6.2
7.3
889
901
902
1036
874
947
872
1019
-------
F4
Table F-2 continued-
MONTH Hr,GMT RELATIVE HUMIDITY CLASSES OBS
31-40 41-50 51-60 61-70 71-80 81-90 91-100
SEP 00
06
12
18
OCT
NOV 00
06
12
18
DEC
.5
.1
.4
.2
2.8
2.2
1.7
5.3
20.5
10.0
10.2
33.2
47.2
46.5
49.1
41.4
21.5
29.6
27.8
13.3
7.4
11.4
10.7
6.7
811
909
807
943
00
06
12
18
.1
.1
.4
.4
1.2
.5
.8
2.7
9.0
8.6
8.6
13.9
20.1
15.7
16.7
25.3
38.2
39.4
36.1
32.4
24.2
27.3
28.0
18.3
7.2
8.4
9.3
6.9
752
865
830
925
.6
1.8
1.3
3.5
11.8
11.0
8.8
12.0
17.5
18.5
17.7
22.3
26.3
26.5
24.4
27.3
33.5
32.7
35.2
26.3
10.3
9.3
12.5
8.1
680
789
753
849
00
06
12
18
.1
.3
.6
2.8
2.5
2.3
4.0
12.1
11.0
9.8
15.2
20.5
19.7
21.9
20.0
23.2
22.5
22.4
22.2
30.8
31.7
28.8
28.1
10.6
12.3
14.5
9.8
708
836
'732
877
-------
F5
95°
90°
30°
h I ' I ' I ' I
TEXAS
25C
PROPOSED
INCINERATION
SITE
JAN.
FEB.
MAR.
APRIL
MAY
JUNE
6) 47-
JULY
AUG.
SEPT.
OCT.
NOV.
DEC.
20
40
60
80
100
Scale of Wind Percentages
Fig. F-l. Wind roses illustrating wind speed and direction for the designated
region. The arrows fly with the wind. Length of arrow represents
the percentage of observations during the month that wind was from
that direction. When arrow is too long to be shown, the percentage
is indicated by numerals. The number of feathers shows the average
Beaufort wind force. Number within circle represents percentage of
calm and variable winds (U.S. Navy Hydrographic-Office, 1972).
-------
F6
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-------
F7
Table F-4. Surface current speed and direction for the region of the
proposed site (from U.S. Naval Oceanographic Office, 1972)
JAN - MAR
No. of Obs.-1896
Direction Frequency Ave. Speed
(%) (kt)
APR - JUNE
No. of Obs.-5151
Direction Frequency Ave. Speed
(%) (kt)
N
NE
E
SE
S
sw
w
NW
Calm
12
12
16
9
7
5
20
14
5
0.6
0.6
0.7
0.6
0.6
0.7
0.7
0.7
N
NE
E
SE
S
SW
W
NW
Calm
6
6
7
5
4
5
33
28
9
0.6
0.6
0.6
0.6
0.5
0.6
0.9
0.9
JULY - SEPT
No. of Obs.-4447
Direction Frequency Ave. Speed
(%) (kt)
N
NE
E
SE
S
SW
W
NW
Calm
10
7
11
8
4
7
27
17
9
0.6
0.6
0.6
0.6
0.6
0.6
0.8
0.8
OCT - DEC
No. of Obs.-8554
Direction Frequency Ave. Speed
(%) (kt)
N
NE
E
SE
S
SW
W
NW
Calm
7
6
8
7
5
6
31
20
10
0.6
0.6
0.6
0.6
0.5
0.6
0.8
0.8
Current Speed Summary-All Directions
No. of Obs.- 20048
Current Speed
(kt)
Percent
Calm
0.1-0.9
1.0-1.9
2.0-2.9
8
65
23
4
-------
F8
WATER MASSES
The principal inflow of water into the Gulf of Mexico is from the Caribbean
Sea through the Yucatan Strait. These waters are a mixture of South Atlantic
water (transported northwestward by the Guiana and Equatorial current systems)
with North Atlantic water (from the west Sargasso Sea). The ratio of South
Atlantic to North Atlantic water has been estiamted to be between 1:4 and 1:2
(Harding and Nowlin, 1966). Most of the outflowing water passes through the
Florida Straits into the North Atlantic.
Five water masses are recognized in the Gulf and all occur within the State's
water column. These water masses are vertically layered as follows: (1) Sur-
face Mixed Layer, (2) Subtropical Underwater, (3) Oxygen Minimum Layer,
(4) Subantarctic Intermediate Water, and (5) Gulf Basin Water. Each of these
water masses can be distinguished in the Gulf by distinct values, gradients,
or relative maxima or minima in specific parameters. In Fig. F-2 are plotted
temperature, salinity, and oxygen as functions of depth for a March hydro-
graphic station taken just south of the proposed site. Approximate water
mass depth ranges for the five water masses are also shown in Fig. F-2. The
distinguishing characteristics given below for each water mass were taken
from various sources - Harding and Nowlin, 1966; Nowlin, 1971, 1972; Wlist, 1964.
1. Surface Mixed Layer (SML) - generally characterized as the upper isothermal
layer with temperature depending on the heat budget and by a salinity distri-
bution depending on evaporation minus precipitation, runoff, and the horizon-
tal advection of currents. Depth of SML, shown in Fig. F-2 is approximately
75 meters.
2. Subtropical Underwater (SU)- characterized by an intermediate maximum of
salinity in depths between 50-200 meters. Fig. F-3 gives the depth distribu-
tion of the core of the SU. The source of the SU in the Caribbean and Gulf
is probably from the tropical North Atlantic at 20° - 25°N, 30° - 50°W.
-------
F9
3. Oxygen Minimum Layer (OML) - characterized by minimum oxygen values within
depths of approximately 300-600 meters. The OML is not associated with salinity
or temperature extremes. The Gulf OML is clearly continuous with that of the
Caribbean. Fig. F-2 shows dissolved oxygen that is typical for the site.
4. Subantarctic Intermediate Water (SIW) - characterized in the Gulf by a
salinity minimum of 34.86-34.89 ppt at depths between 550-900 meters. This
water mass has its origin at the Antarctic Convergence where cold, low salinity
water sinks and spreads to the north. By the time it reaches the proposed site
in the northwestern Gulf its salinity has increased to 34.88-34.89 ppt due to
mixing that accompanies horizontal spreading. Calculations show the percentage
composition of Subantarctic water in the core to be less than 5% at the Yuca-
tan Strait and only some 1-2% in the western Gulf. A suggestion has been made
to label this portion of the Gulf water mass "Remnant of the Subantarctic
Intermediate Water."
5. Gulf Basin Water (GBW) - defined as those Gulf waters below 1650-1900
meters (estimate of Yucatan sill depth). Since water depths of the proposed
site range from near 1100 m to approximately 1835 m, the bottom is bathed by
SIW-GBW transitional waters and GBW. Typical temperature, salinity, and
oxygen values for these waters are shown in Fig. F-4.
-------
5.0
36.0 362 36.4 36.6
3.0 3.4 3.8
35.0 35.2 35.4
8 10
35.6 35.8
RFACEMJXEOtAYER
SUBTROPICAL UNDERWATE
OXYGEN MINIMUM LAYER
SUBANTARCTIC
:GULF BASIN WATER
Fig. F-2 Physical characteristics and water mass designations from a
west-central Gulf hydrographic station taken just south of
the proposed site (25°09'N, 94°11'W; 15 March 1968).
-------
Fll
PROPOSED INCINERATION
95
Fig. F-3. Core depth in meters of salinity maximum of the Subtropical
under water (after Nowlin, 1972) .
PROPOSED INCINERATION SITE
STATIONS IIS lia 117 lie i 115 114 115 112 III HO 109 KX IOT I0« 105 ICX 105
NORTH LATITUDE
Fig. F-4. Temperature (°C) along the line shown in Fig. F-5. Note
position of site next to station 115 (after Nowlin, 1972).
-------
F12
30"
PROPOSED INCINERATION
scr
Fig. F-5. West Gulf stations occupied in February-March, 1962 by R.V. Hidalgo.
Line indicates vertical section discussed in text (after Nowlin,
1972).
-------
F13
I PROPOSED INCINERATION SITE
STATIONS 119 lid 117 lie J us | ll« US IIJ III MO 109 lOB 107 IO6 105 ICM IO5
O—H—i^^yi _•_——• ' -c—•—r- • 'x—• •—.— px—•*—— •-=
29' 28' 27- 26
25' ?<• 23' 22'
NORTH LATITUDE
Fig. F-6. Salinity (ppt) along line shown in Fig. F-5. Note position
of site next to station 115 (after Nowlin, 1972).
-------
F14
r^^^-rf^-^
fc /
F * f
' I /
PROPOSED INCINERATION
SITE
»•-
j; L
Fig. F-7. Dissolved oxygen content (ml/1) of waters contiguous with the
bottom (after Richards, 1957).
PROPOSED INCINERATION SITE
STATIONS 119 118 117 116 115 114 113 112 III IIO 109 108 107 106 105 104 103
29* 28* 27- 26' 25' 24' 23' 22* 21
NORTH LATITUDE
19*
Fig. F-8. Dissolved oxygen concentration along the line shown in Fig. F-5.
Note position of site next to station 115 (after Nowlin, 1972).
-------
APPENDIX G
U.S. ENVIRONMENTAL PROTECTION AGENCY, DISPOSAL OF
ORGANOCHLORINE WASTES BY INCINERATION AT SEA
(Under Separate Cover)
------- |