EPA-EIS-WA 76X-054
                 FINAL
ENVIRONMENTAL  IMPACT STATEMENT
   DESIGNATION OF A SITE IN THE GULF OF MEXICO

      FOR INCINERATION OF CHEMICAL WASTES
            ENVIRONMENTAL PR
             WASHINGTON, D.C.


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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 & M UNIVERSITY (EPA-EIS-WA 76X-054)
APPROVED BY
                                   ;  U  {**
                               DATE:/   ML *   B76

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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.
                                     iii

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    B.   Alternative  site  -  rejected because the proposed site meets or exceeds

        all of the criteria for  site selection, which include economic, health,

        and recreational  factors.  Thus, no additional safeguards to the

        environment  could be gained etc.

5.  Comments on the  draft impact statement were 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,  S.W.
       Washington,  B.C. 20460

       Dr.  William  Aron,  Director
       Office of the Ecology &
         Environmental Concerns
       National Oceanic Atmospheric
         Administration
       Department of Commerce
       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
                                   IV

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    Federal Agencies (CONT'Dl

    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 Barden, 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
                                  v

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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
Attorney General's Office of Texas
Austin, 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
New Orleans, LA  70128

Area Supervisor
National Marine Fisheries
Service Water Reservoir Division
4700 Avenue U
Calveston, TX  77550

Mr. James Coerver, Director
Bureau of Environmental Health
Louisiana State Department of Health
P.O. Box 60630
New Orleans, LA 70160
                                       Mr. Donald D. Carruth, President
                                       The American Eagle Foundation
                                       3306 Winneth Road
                                       Chevy Chase, MD  20015
    C.   Citizens  Groups

        Mr.  Brock Evans,  Director
        Sierra  Club
        324  C Street,  S.E.
        Washington,  D.C.  20003

        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 made

available to the Council on Environmental Quality and the Public on jyj_ ^ 4
                            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, B.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 Health, Education & Welfare
Room 524 F2, S. Portal Building
200 Independence Avenue, S.W.
Washington, D.C.  20201
                                    viib

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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 for 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
              Site Designation Procedures	18
              General Criteria for the Selection of Sites	13
              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 GULF 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)
                                        x

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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	51

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.--—„-„_„_„-,—___,	,	,	,	,	  9
 1-2.    Location of 1974-75 incineration site.———•	15
 1-3.    Location of the proposed site in relation to the 1974-75
             incineration site.—	•	——•	16

II-l.    Bathymetric map of northwestern Gulf of Mexico.	27
II-2.    Possible patterns of flow of surface waters in the western
             part of the northern Gulf.	33
                                    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 Marine 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 held that 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 EPA's environmental regulatory activities,
the Agency has been urged to prepare EIS's.  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, the Corps was given the authority to establish disposal sites.  However,
because of the lack of jurisdiction, they could only suggest disposal sites
beyond the three mile limit.  In the area of this proposed site the Galveston
Corps 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
on 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 organochlorine 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 VULCANUS in the United States,  DCS 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;
 TIAS 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 the Interior, the Secretary of  Commerce,
 the Secretary of State, and the Secretary of  Defense, the Secretary (of
 Transportation) shall  designate a zone of appropriate size around  and in-
 cluding any deepwater  port for the purpose of navigational safety.  In
 such zone, no installations, structures,  or uses will be permitted that
 are incompatible with  the operation of the deepwater port.  The Secretary
 shall by regulation define permitted activities within such zone.   The
 Secretary shall, not later than 30 days 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 establish a safety zone to be  effective
 during the period of construction of a 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 conservation 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                     '
  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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                                    10
(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 Marine  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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                                  11
(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

      (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.

   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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                               12
    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



    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 specify  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 Administrator, 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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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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                                    13
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, 26°32'24"N-93°15f30"W, 26°19'00"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 £he 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'
940Q01
  I
93040'
  I
93°20'
  I
93°00'W
   •27°20'N
                         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 (th'e 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-
sary with the original geographical grid system.  The four time delay numbers
will represent the boundaries of the site, thus giving greater assurance that
the ship will remain within the boundaries and facilitating more accurate sur-
veillance 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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                                    18
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 reaching any beach, shoreline,
marine sanctuary, or known geographically limited fishery or shellfishery.

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                                    19
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 forth 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

(a)  In the selection of disposal sites, in addition to other necessary or
     appropriate factors determined by the Administrator, the following fac-
     tors will be considered:

       (1)  Geographical position, depth of water, bottom topography and
            distance from coast;

       (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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                                   20
       (5)  Feasibility of surveillance and monitoring;

       (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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                                    21
     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:
   Ca)   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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                              22
          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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                                    23
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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                                    24
(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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                                    25
               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. II-1> 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 & Curray, 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
explained them on the basis of biohermal structures which have kept pace with
changing sea levels (Stetson, 1953; Mathews, 1963).  One of the more interest-
ing and intensively studied of the banks is the West Flower Garden, a possible
element of a discontinuous arc of reefal structures occupying the Gulf's
southern and western continental shelves (Bright & Pequegnat, 1974; .Edwards,
1971).  It and the similar East Flower Garden Bank are capped by what are
considered to be the northernmost thriving tropical shallow water coral reefs
on the eastern coast of North America; however, they are located 133 km north
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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27
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                                                               u


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                                                               4J
                                                               CO
                                                               J-l
                                                               o
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                                                               o

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                                                               M
                                                              JS
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                                    28
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).  "Within 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 suite 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 during July-August.  On a daily basis the site's
relative humidity is lowest in the afternoon (Appendix F).

WINDS AND STORMS

Historically, winds at the proposed site are the calmest during July and
August with average wind speeds of 7-10 knots (U.S. Navy Hydrographic Office,
1972).  Wind speeds increase somewhat 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

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                                    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
14
0
0
4
9
14
0
0
5
9
13
0
0
5
9
13
0
0
3
7
11
0
0
1
5
10
0
0
0
5
10
0
0
0
4
9
0
0
3
7
11
0
0
4
8
12
0
0
4
8
13
0
0
4
8
13
Min.
01
05
25
50
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 these studies it can be seen that the

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                                    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. H-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. II-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).

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                                    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

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:  Cl) 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

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                                    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-l.  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).

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                                    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 (Wtist, 1964).  This entering  layer, with a dis-
solved oxygen content of approximately 2.6 ml/1, spreads  northward and becomes
contiguous with the sediment along the slope (Appendix F).  According to
Nowlin (1972) the core of the oxygen minimum layer in the vicinity of the site
is at a depth of around 250 m and has a dissolved oxygen content of slightly
less than 2.4 ml/1 (See Appendix F).
                    «

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"*" 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.

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                                    37
Since the H"1" 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 (X>2>
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 8.05) 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 (IT1")/!.
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% of the time and those > 8 ft. occur 8-13% of the time.   In
June-July the occurrance of > 5 ft. waves is 12-17% of the time and those
> 8 ft. occur 0-0.5% of the time (for 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-

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                                    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     % Freq.     % Freq.     % Freq.      No. of
                 Height       > 5 ft.     > 8 ft.     > 12 ft.     Obs


JAN               4.9          53.4        13.1        1.9         206
FEB               3.3          49.5        11.2        2.1         180
MAR               3.3          43.8         9.4        1.0         203
APR               3.3          41.1         6.8         .0         192
MAY               3.3          36.7         6.3         .5         207
JUNE              3.3          16.5          .5         .0         212
JULY              1.6          12.2          .0         .0         180
AUG               3.3          17.5         2.1        1.3         234
SEPT              3.3          37.2         7.0        2.8         215
OCT               3.3          37.7         7.9        3.9         228
NOV               3.3          41.7         7.0        1.5         199
DEC               3.3          45.1         8.3        1.0         193
                         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 phytoplankton and zooplankton components of the pelagic

realm (Appendices B & C).  Data from TerEco (1974) show the relative abundance

of phytoplankton cells collected 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; Hulburt and Corwin, 1972; and Fucik, 1974).  Zaitsev (1970) re-

corded a maximum biomass for zooplankton 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-ji concen-
tration at this station was low (0.11 mg/m^).  Chlorophyll-j. values (mg/m^
                          t\
for discrete samples; mg/m^ for integration of all discrete samples over the
euphotic zone) represent the amount, or biomass, of phytoplankton present
in the water.  At several stations peripheral to the proposed site, surface
                                                            o
chlorophyll-a values were also low in August (0.11-0.18 mg/m ), but slightly
higher in February (0.18-0.32 mg/nr').  Chlorophyll-a concentrations integrated
over the euphotic zone are absent for the site, but at four stations west of
                                                               o
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,
                                                                        o
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 (mgC/m /hr for dis-
crete samples; mgC/m /hr for integration of all discrete samples over the
euphotic zone) represent the photosynthetic activity of the phytoplankton.

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                                     40
At one station east of the site,  primary productivity integrated through the
                                          2
euphotic zone was also low (1.0-3.16 mgC/m /hr)  during August.

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 ^ig-at/1, 0.17 ji'g-at/1, and 1.7-6.4 ug-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 26026'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)
                   2
with 0.35-48.8 x 10  cells/1.  Relative abundance of other combined species
                          fy
ranged from 1.30-4.88 x 10  cells/1.  The most abundant diatom species in-
cluded Bacteriastrum delicatulum, Chaetoceros a.ffine, (3. atlanticum,
Navicula sp., Nitzschia seriata,  Rhizosolenia calcar-avis, R.. hebetata,
B.. gtyliformis, 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,

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                                    41
and pteropods.  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                                  Station
                          1234567

Cnidaria
  Hydroid  (parts)        x     x     x      x                 x
  Medusa                                          x     xxx
  Siphonophore  (parts)                                  x     x
    Porpita sp.                                   x           x

Chaetognatha             x           x                        x

Polychaeta               xxx                  x     x

Gastropod Mollusca
.rrosoorancnia
Atlanta sp.
Opisthobranchia
Pteropods
Crustacea
Amphipoda
Copepoda
Decapoda (larvae)
Brachyuran
Natantian shrimp
Sergestid shrimp
Lucifer sp.
Euphau s iac ea
Isopoda
Mysidacea
Stomatopoda
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
X X
X

X X

X X
XX X
X XXX XXX
X


XX X
X X
X X
XX
XX ' X




X
X
xxx






XX
X
Echinodermata (larvae)

Insecta                              x     x     x     x     x      x      x

Chordata
  Thalliacea                                           x
  Pisces
    Eggs                                               x     xx
    Juvenile             x                 x           x     x      xx     x
    Adult                x     xx    x     x     x     xx    xxx    xxx    xx

Sargassum                xxxxxxxxxx
  Actinaria                          x           xxx            x
  Serpulidae             xxx                                    x
x = present
xx « abundant
xxx - very abundant

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                                     44
            Table
                          Enumeration of organisms collected In neuston net tow*
                          froa northwest Gulf of Mexico.
  Cnldarla
   Medusa
   Slphonophore  (part*)
         forplta  ap.

  Chaetognatha

  Polychaeta

  Mollusc*
   Caatropoda
     Proaobranchla
        Heteropods
     Oplsthobrachla
        Pteropods
   Cephalopoda
         Argonauta *p.
         larvae
 17
      14

4     68      42

1              6
  5     11
 24

 59     30
 C      B

  1
XX     XX
        3

 21    51
7122
             247            1

5     33     456     15    41

                      1
 Arthropod*
   Crustacea
    Anphipoda
    Cope pod*
         Pontella ap.
         Candacea ep.
         Copilia ap.
    Decapoda
     Brachyuran  (larvae)
     Natantlan  shrimp
     Carldean  shrimp
         Latreutes fucorum
         Leander tenulcomls
         Falaenonld  (larvae)
         Other  Caridea  (larvae)
     Sergestld shrimp
         Lucifer sp.
     Palinuridae
        Larvae
        Juvenile
    Euphauslacea
    Isopoda
    Mysidacea
        Siriella thompsonil
    Stomatopoda (larvae)

   Insect*
        Halobates sp.
        Terrestrial forms

 Echlnodermata  (larvae)

 Chordata
   Pisces
    Antennarlidae (Sargassum fish)
        Hlstro sp.
    Balistidae (Trigger fish)
    Coryphanldae (Dolphin)
        Coryphana sp.
    Exocetidae (Flying  fish)
        Cypselurus sp.
        Parexocoetus sp.
    Gonostomatldae  (Viper fish)
    Hugilidae (Mullet)
        Mugll  sp.
    Myctophidae (Lantern  fish)
        Conlchthys sp.
        Hygophym sp.
        Myctophua sp.
    Pleuronectlforoes (Flatfish)
    Stemoptychidae  (Hatchet fish)
        Stemoptyx diaphana
    Others  (Juvenile)

 Sargassua
   Actlnara
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

1
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
11
                                              24
              11
                                                 16
                                                 18
        x
       10
• present
 • abundant

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                                    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 data show
agreement with Thorson (1971) who observed an obvious decrease in the number
of individuals with increasing depth.

ZOOBENTHOS

Numerous benthic stations have been sampled in the near vicinity of the
proposed incineration site by TerEco personnel, 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.  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
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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.
REJECTION OF "NO ACTION" ALTERNATIVE

Under Section 102(c) of the MPRS 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 MPRS Act.  Exercise of this authority will occur only after need for a
site is evident and it has been demonstrated that the disposal method is en-
vironmentally sound.

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 research
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, phytoplankton 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
     organochlorines  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 safe distance, 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 th,e 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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                                    35
                        IV.  ENVIRONMENTAL IMPACTS

                      DESIGNATION OF THE PROPOSED SITE
           *
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 nautical
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 very 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 metals 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 stems  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
                                      l
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:  66% (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 [H*l /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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62










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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 per unit volume of sea
water might be the same in plume and control samples, the amounts of ATP

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                                     64
 and/or chlorophyll-a 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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                                 65
     jPossible 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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                                 66
     Stratospheric Ozone.  At-sea incineratioq of the total world-wide
                                                                          .%
production or organochlorine wastes would not produce sufficient strato-
spheric chlorine (HC1/C12) 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 HCl/Cl2» 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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                              67
     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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                              68
Coast state.  The ports in which the ships would be fueled and 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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                               69
     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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                  70
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                                     71
    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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                               72
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^j 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 spectographic 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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                               73
Oceanographic 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
of these effects in the field are employed.

FROM ACCIDENTAL SPILLAGE

Even though incineration at sea has been found to have no demonstrable
deleterious effects upon the upper portion of the water column and its
biota (TerEco, 1974;1975), the possibility of environmental damage resulting
from 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 are at
their highest in November - February, averaging 13-15 knots, but pose no

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                                 74
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-tewn 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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                                74a
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 the
Chemical Waste Incinerator Ship Project.

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                              74b
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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                                     75
COMMERCIAL PISHING

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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                                     77
          VI.  RELATIONSHIP BETWEEN LOCAL SHORT-TEBM USES OF THE
          ENVIRONMENT AND ENHANCEMENT OF LONG-TEBM 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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                                     78
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 monofilament 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 site 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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                                     79
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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                                     81
      VII.  IRREVERSIBLE AND 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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                                  83
        VIII.  LITERATURE CITED IN TEXT AND IN APPENDICES A-F
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ANDERSON, G. C. 1969. Subsurface chlorophyll maximum in the northeast Pacific.
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ANTOINE, J. W. 1972. Structure of the Gulf of Mexico, p. 1-34. In R. Rezak
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ANTOINE, J. W. and W. R. BRYANT. 1968. Major transition zones of the Gulf of
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ANTOINE, J. W. and W. R. BRYANT. 1969. Distribution of salt and salt struc-
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BAGG, A. M. 1948. Barometric pressure-patterns and spring migration. Auk,
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                                  84
BALLARD, R. D. and E. UCHUPI. 1970. Morphology and Quaternary history of the
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BOUMA, A. H., 0.  CHANCEY,  and G. MERKEL. 1972. Alaminos Canyon area, p. 153-
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BRIGHT, T.  J.  and L. H. PEQUEGNAT. 1974. Biota of the West Flower Garden
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                                  85
COCHRANE, J. D. 1972. Separation of an anticyclone and subsequent developments
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COL1ARD, S. B. and C. N. D'ASARO. 1973. The biological environment  - benthic
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EL-SAYED, S. Z. 1972. Primary productivity and standing crop of phytoplankton,
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EL-SAYED, S. Z. and J. T. TURNER. Productivity of the Antarctic and tropical/
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EWING, J., N. EDGAR, and J. W. ANTOINE. 1968. Structure of  the Gulf of
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GAUL, R. D. and R. E. BOYKIN. 1964. Northeast Gulf of Mexico hydrographic
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                                  90
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                                   97
IX.   COMMENTS AND RESPONSES

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   Ci!EP«fEI«A3u
May 4, 1976
Mr. Kenneth E. Biglane, Director
Oil and Special Materials 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.  We have reviewed the document  and we feel
that the proposed procedure with regard to  issuing  permits
is reasonable.

      We, at the 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 organochlorine wastes by incineration  at
sea.

      Please keep us informed on any developments on any
offshore incineration matters in the Gulf of  Mexico.   Thank
you for your cooperation.

                             Sincerely yours,
                                    ^
                                            /t
                                  Malouf, Ph.D., P/E.
                             Special Environmental^Assistant
                             to the Texas Attorney  General
JM/lf
                    An  Equal Opportunity Employer

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Response to letter 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
412 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-548)
   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.'i 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 Blglane
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 acceptabilit
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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J
    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,
  1971* Report of  the Presiding Officer (Taylor 0. Miller) on the EPA
  Public Hearing  held on October  4, 197^ 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
  "[f]urther  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.
n
-/         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 significant 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
  to 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

          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. 73-OD008E 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/i&erely,
KSK:jb                                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 CPR § 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 bioassay 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 not
 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 been
 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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   titional Wildlife Federation-
Mr. John C. White
August 22, 1975
Pape 2
          2.  Given EPA's tentative determination to prepare an
Environmental Impact Statement, on the proposed ocean Incineration
site before 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 the public
notice.  If public comment on the Shell application is to be mean-
ingful and 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 chlorination 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 Operatioi
division at EPA headquarters.

          In conclusion, while the National Wildlife Federation support'
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
    John C.  /.'hUe
   .-t  22, 1975
   e 3
          Although the Shell public notice was somehow never sent
*co us by Region VI (someone else called it to our attention), we
nevertheless appreciate the opportunity to express our views on
this matter.
                                   Very truly yours
                                   Kenneth S. Kamlet
                                   Counsel
cc:  iVr.  Kenneth Biglane
     F.r.  T.A. Wastler
     Oames Rogers, Esq.
     Iiark Chandler, ESQ.
     Mr.  Robert E. Apple
     Mr.  P.H. Farrar
         Cecil Reid
         Richard Stat.ek
KSK/o

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    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                  WASHINGTON, D.C. 20460
                                7 FEB 1976
                                                     OFFICr OK TH£
                                                     ADMINISTRATOR
Captain George Steinman
Chief of the Environmental Group
Maritime Administration
U.S. Department of Commerce
Washington, O.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  (EIS) does not present adequate information to
evaluate the impacts of projects other than the incinera-
tion of organochlorides on the VULCAKUS.  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 measures 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.                        j

     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,

                                     c-c*^ 10 .
                               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
1.  The draft Environmental Impact Statement (EIS) provides information
    that has been developed  from the incineration test burn of organo-
    chlorine waste from the Shell Chemical Company conducted in the Gulf
  . of Mexico during October 1?74 through January 1975.  While these tests
   ] generally support the conclusion that thermal oxidation of the organo-
    chlorincs can achieve efficiencies greater than 99. 9%, they do not
    adequately reflect the kinds of conversion ratios that can be expected
   I 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 will 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 VTJLCANUS 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 adequately 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 mitigativc measures that are relevant to chemical
    incinerator ships.  Other regulations and international conventions
    which  will  become applicable.- for nev/ shins upon  ratification or coming
    into force at some future date  should bo  discussed under a separate
    heading, if so desired.

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       Jf
    /    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 IMCO 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
         j temperatures.

          According to the EIS the proposed incineration ship will not
          need a scrubber because the incineration achieves 99. 9% com-
          bustion and  I1C1 emissions 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
          high 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 some 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-
             i tion  chamber. Cold air can even have a quenching effect xvhon
              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 CC>2, 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.

Pg. 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 Fi.rure 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.

Pg. IH-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.

Pg. 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.

Pg. 111-13 Change "inconclusive" to  "inclusive".

Pg. HI-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..

 3g. 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.

 3g. 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.

 3g. 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 Tnder the typical approaches for minimizing risks for
          sinking, or hull rupture,  several provisions are 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 standai-ds discussed in this  section
          have not yet been ratified, as mentioned on page IV-27.  The
          applicability of those 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 IMA RAD  intends to
          make these a part of their requirements, a point not  stated
          in the EIS,  we suggest they be excluded or discussed under
          a separate heading if so desired.  See General Comment 4.

Pg. IV-41.  See the comment on Page 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,
          1975 apply to oil tankers only.  They are not applicable to
          chemical carriers. See comment on Page 1V-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 MA RAD.

 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-l5 The statement that a national disposal site will "undoubtedly
           be required in the future"  must be thoroughly explained.

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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.

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       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 VT will be used to



    evaluate any long-term impacts from incineration.  Hypothetical

-------
    levels of ocean incineration,  and resultant hypothetical emissions,
    would lead to no more 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.

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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).  Additions 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 industry, 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.

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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, Pequegnat (1966)  reports in the
    chief scientist's log of Texas A & M University's R/V Alaminps
    that during a March-April oceanographic 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), Pequegnat 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 ppn.  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.

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                   DEPARTMENT OF TRANSPORTATION
                  UNITED STATES COAST GUARD
MAILING ADDRESS:
U.S. COAST GUARD (G—WEP-7/73)
WASHINGTON. D.C. 20590
PHONE: 202-426-9573
                                                          592279.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,
                                                   —,ia

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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.

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                   TEXAS * WATER QUALITY  BOARD


J. DOUGLASS TOOLE                                                  CLAYTON T. GARRISON
    CHAIRMAN
                                    X:iO?"-.                     BEN RAMSEY
FRANK H. LEWIS                         /«£p^A
    VICE CHAIRMAN                      /. Orb ife                    JAMES M. ROSE
M.F. FROST                           '•'TO W Ml i                    HUGH C- YANTIS, JR.
                                  . \m.if~*\*i .                       EXECUTIVE DIRECTOR

FRATIS L. DUFF, MD                       V"~3>"'                     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«-*
 eluded 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.

 Vacy truly yours,      ~
•   rA.W^.  -O       <
v£mory G. /Long, Director
 Administrative Operations

 cc:   Mr. Charles T. Travis,  Governor's Budget and Planning Office

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Response to letter of June 2,  1976,  from the Texas Water Quality Board










     Garments on the Draft EIS by the Texas Water Quality  Board are



hereby noted.

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                  PHONE 512/451-5711                    CHARLES R. 8ARDEN, P. E.
                  8520 SHOAL CREEK BOULEVARD            EXECUTIVE DIRECTOR


JOHN L BLAIR, Chairman                    AUSTIN, TEXAS - 78758         CHARLES R. JAYNES
WILLIAM 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
     Deputy Director
     Control and Prevention

     cc:   Mr.  Lloyd Stewart, Regional  Supervisor, Bellaire
          Mr.  Ray Lozano, Environmental  Protection Agency, Region  VI,  Dallas

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Response to letter of June 3, 1976, fron 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.



     Rscommendations 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.

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                    DEPARTMENT  OF 7«E ARMY
                GALVESTON DISTRICT.CORPS OP W6INEERS
                         P.O.BOX 1229
                      GALVESTON,  TEXAS .77553
    REPUY TO
    ATTENTION OFt

    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 statement> "Designation of a
Site in the Gulf of  Mexico for Incineration of Chemical Wastes,"
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, D.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,
                                            fc:
                                     R. E.  Van Ingen
                                     Manager - Manufacturing
                                     Environmental Conservation
Attachments

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                     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

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                                                                 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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                 SHELL   DEVELOPMENT   COMPANY
10   . CHEMICAL ENGINEERING
     DEPARTMENT - MANAGER
                                           AUGUST 26,  1975

                                    fKOM    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 waste chloride incineration to these phenomena.

Sources of Atmospheric Chlorine and Transport to Stratosphere
          Atmospheric chlorine (HC1,  Cl£)  is predominantly released from natural
        1'5  The best estimates of atmospheric loading indicate the following
sources of
sources.
                                  TABLE 1
            RELATIVE STRENGTHS OF ATMOSPHERIC CHLORINE SOURCES
  Mass Loading  ' Percent Ground
At Ground Level  Level Emissions
   (tons/yr)	(% 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
(* 121)
'relative total1
17
82
1
100.0
These sources give rise to a ground level atmospheric chlorine concentration of
*v» 1 ppb  (also termed by atmospheric scientists as a mixing ratio of 1 x 10~9).
These ground level sources are the origin of the approximate £ 0.2 ppb atmospheric

-------
•EFFECT OF HC1/C12
 chlorine  level existing in  the stratosphere between 20 and 40 km.  Hox^ever, since
 the volcanic  sources often  inject I1C1 and C12 via an extremely hot eruption,  they
 are 10  to 200 times more effective as sources of stratospheric chlorine. **  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 NH^Cl aerosols6'7 and absorption by soil and
 vegetation.1'8  The consideration of these 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 x 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 x 107 tons/i
 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.'
 Therefore, the U. S. ocean  dumping figure of 1.65 x 107 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 IQ7 tons/yr becomes j^ 2 Y 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  1Q5  tons/yr as opposed t
 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 107  tons
 was approximately the  total amount of material  (sewage and all industrial wastes)
 dumped  into the ocean  under EPA permits during 1973. 14  This estimate  is  arrived
 at by assuming  that  the Region II total of 9.4 x 1Q5 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 IIC1 and reaction OH +  HC1  -*• Cl + H20, which
 produce the Cl  free  radical.  Then  the  catalytic cycle;

-------
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
                               03  •*• 02 + 0   ,


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 (CFCls 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. 2~4

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.1*'5  Thus, (with reference to data in Attachment 1),  incinera-
tion of 1.5 x 1010 kg per' year or 1.65 x 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 x 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 ah order of magnitude below an observable effect.

          Some idea of the magnitude of the task of incinerating 1.65 x 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 incineration of organic chlorides
(^ 2 x 107 tons per year) should have an unobservable effect on the stratospheric
ozone concentration.

-------
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. 74,, 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
     Pollution CuuLrol - By-Product Recovery  through  ExhausLive-Chloriiiation of
     Halogenated Hydrocarbon Wastes",  presented at Joint  AIChE-Gesellschaft
     Verfahrenstechnik and Cheraeingemerwesen Meeting,  Munchen, Deutschland.

10.  Chemistry and Industry, .16  (June  1973), pp. 567-569.

11.  Chemical Week, 26,  (July 1973), p. 61.

12.  Chemical Week, J5,  (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

-------
    ittefs
   ilymer chemistry

   : I would like to "second" the forthright
   lorial  by  Dr.  Paul  H.  Linda nmcyer
   iEN. Nov. 13) of tho National  Science
   jndation. about the deficiencies  of poiy-
   r  chemistry  support by acaiemia and
   ustry.  As  chapman of the  education
   nmiltee of the ACS Division of  Polymer
   emistry Inc..  I  would like  to offer  tho
   vices of our committee to  those institu-
   tes and/or individuals who  wish  to con.
   er the development of appropriate  un-
   rgraduais and/or graduate courses and
   jgrams. We !iava currently supported the
   sparation  of   a  new  ACS  Interaction
   lurse—"Polymer Science  and Tcchnol-
   y—An  Interdisciplinary Aporoach";  are
  cparing a laboratory manual wi;n experi-
  enls suitable lor incorporation into under-
  aduate  organic and  physical chemistry;
  e developing a reference bibliography on
  >lymers:  and  have recently  published a
  irvey  of polymer education in various In-
  itutions.
   Mention  should also ba  made  at this
  •ne of the fact that in addition to  Dr. Flo-
  •'s receiving the Nobel Prize, another sig-
  licanl occasion is on the horizon for poly-
  ier  science  and education—tha calebra-
 Of! c!  Pro!. He'Tian F Mark's 80lh  birth-
 ay on May 3.  1975.  Among  Mark's  many
 ccomplishments was the establishment of
 19 world's first acsdemic program grant-
 ig graduate degrees  in polymer' chemistry
 .1 Polytechnic Institute of New York (nee
  rooklyn). Signiiicantly. Flory will chair an
 iternationai symposium In  honor of this
 iccasion on May Z and 3. It  is planned to
 innounce the  Professor Herman P.  Mark
 ihair in  .Polymer Science  at that  time.
 :rionds of Mark, the  Polytechnic Institute.
 md  polyrr.er chemistry can  contribute to
 he success of  this event, important to '.he
 growth and recognition of polymer  chemis-
 ry. by contacting me.
                           Ell M. Pearco
 Chairman. Education  Comm/ffe«,  Polymor
   Division,  ACS. Dcpt. ol Chemistry. Poly-
   technic Institute ol New York, New York,
   N.Y.TI201
            %
Drinking water study

SIR: Your report of the Environmental Pro-
tection   Agency   drinking  water  study
(C&EN. Nov. 18. page 44) lllustrate-i that
significant prooiems stiil exist  in this  coun-
try with respect to trace contaminants in
our natural waters. Particular  concern  still
centers around  the  nature of. tho various
organic compounds tnnt hnv»» i:?en
cd. especially tno potential lor tox
Of carcinogenic beh.ivior.
   However, care must b* exercised as to
tho^ mechanisms for the production of vari-
ous  halogenoted  orgamcs In  wntor  sys-
lomj. It is likely that chloroform is indeed
 prcsont In Now Ode.inV drinking w.itcr. r.s
 EPA has found  But is it possible thai chio-
 rotorni is furmod by chionr-ntion process-is
 In w.Mor or w.ib'.e-water tto.itniont plants?
 Most  organic cho-nivtry text:.  discuss \\\?
 chlorlnnlion ol rr.eihano (3 likoiy  constitu-
 ent  of  waMo-w.iti-r  treatment  plnnt  cl-
 lluents)  In terms of a free radical mecha-
 nism under conditions ol ultraviolet lir.ht or
 high  tempsralura  (250 to  >rn>»s for
 organic  chlorides have boon su"",i}--!«;d in
 Ci EN. Sept. 1C. p.iqo  U'. Also.  --:I.I!M-S of
 converting  organic  chlorides io:a  ii'.u'ul
 products are m progress  (r-d~.rv.ood Arsa-
 nnl). On«> mignt think ono coulO always ru-
 plonish  the ozone layer should t^n deple-
 tion become dangerous. Hcwcvr. ;it lejr.t
 for  processes  on tho  r.irth's su'tncc-'. in-"
 creasing tne ozono concer::r.i:ion also  has
 severe  problems (C&EN.  Oct.  ?8, paqs
 22).  Since we know of (his darker ahead
 of  time, lot us  thus  avoid  depi?t;ng  the
 ozone layer in tho first place.
                          Joel F. Liebman
 Assistant Professor ol Chemistry. University
   ol Maryland. Baltimore


 ion transport

 SIR: I  should like to 'comment on your re-
 cent  article (CiEN.  Nov.  18.  psrjs  35)
 concerning the potential  practical uses of
 carrier-mediated ion transport.
   The examples given represent exciting
 new applications ol  perrr.seiect.vs liquid
 membranes. However,  there is at least ona
 precedent [M.  Pinkerton, L. K. Stcmrauf.
 and  P.  Dawkins. fijoc.'iem.  fi/op'ivs.  fJ?s.
 Cornmun.. 35.  512 (1959)J to the use of a
' membrane-active  antibiotic   to  produce
 transport of an ion against its concentration
 gradient. In t.-.is paper, experirr.jnts were
 presented which led  the authors to  con-
 clude: "Using valinomycin as a carrier, we
 havo rnnsiructsd a  device lor couoled ion
 transport  which will concentrcto onu ion
 across  a  barrier using  the  concentration
 gradient of  a  second  ion as  ;no  driving
 source." Thus, tne principle of "uphill" ion;
 transport in vitro is not really a novelty.
                         Balthaser F. Gisin
 Associate Professor, Rockefeller University,
   New York. N.Y.  •


 Commercial prostaglandin

 SIR: I would like to correct an error In your
 issue o( Nov. 18 (Concentrates, page 30).
 The  firs!  commercial  prostnglar.cm to  be
 approved  lor use in animals  was not pros-
 taglandin  F7o  but a synthetic analog. 16-
 (3-trifluoromethylpher.oxy)-17.18.19.20-
 tctranor-prostaglandm  F?0.   which  was
 launched  in the  U.K. in March 1974 under
 tho tradename Ec.uimnto.
                            N. S. Crossley
 Pharmaceuticals Division. Imperial  Chemi-
   cal Industries. U.K.
 Cyclamates

 SIR: Three cheers lor Mike Svoda!  He has
 tho courage to stand up and tell it like i! l3
 (CAEN. Nov. 25. PJ3-5 14) co.-.cerninn CY-
 clnmatos. f3iq Brother in W.-iTi'.'.'.-.on (> co^
 & Drug Aom.nistintion)  sunjjly  .'.;:••* vi 10
 ag.nn. is  dead wrong, and  hnint  50! tl'.o
 guts to admit it.
                             A. R. Morgan
 President. Thorma Technology. Tulsa.
                                                                                                        DoC.23. 1074CM-.N if

                                                                                                              ut**** **•** *"***'

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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.

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                  Louisiana   Air Control  Commission
          State Office  Building                  RO. Box 6O63O

          Phone (504) 527-BUS       x^x      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,
                                              C
                                                  - > <  ^ j /   ' V U ' u- ' \. v^ u * ' -'
                                                   "" ~s*+s
                                            Orey Tanner, Jr.,  Administrator
                                            Technical Assistance Unit
                                            Air Qua Iity Section
                                            La. State Division of Health
OT:mac

-------
Response to letter of June 4, 1976 from the Louisiana Mr Control
Conmission
1.  The Department of Labor Standards of 8 hours per day exposure to

    5 ppm HC1 will be recommended 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 HCl 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 time 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 Ifetional 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 I, 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 ocean dumping  regulations
pursuant to the Marine Protection, Research and Sanctuaries Act,
as amended in 1973-"  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.

-------
                              - 2 -

Page 51 - Most of the data from this section, as well as the pre-
vious section, vere taken from SP-189II - Environmental and
Acoustics Atlas of the Caribbean and Uulf pi' Mexico - volume II -
Marine Environment and from Knvlronmental Conditions Within
Specified Geographical Regions.Although these two publications
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, Uxygen and Phosphate in £he Waters
     off United States - Volume ii Ciulf of Mexico.

b.   Summary of Synoptic Meteorological Observations for the
     iMorth Atlantic Uoastal Marine Areas Volume 6.

c.   The National Data Buoy Office of NOAA has maintained an En-
     vironmental Data Buoy, EB-12, at 26N and 94W  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
     (NODC).  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 obtainabl
     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. 202^5.

Pages 49 and 50* Alternative Methods of Disposal - It is stated
that  "conventional barging and dumping or 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 ventin
into the air  is preferable to dumping into the  ocean where oxidati

-------
                              - 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> Pfeysical Factor Impacts - The assessment of the
impact or 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."

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

-------
                             - 4 -

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 an<
by aircraft during October 2, 3, and 4, 1974, no accompanying
meteorological data was indicated and no attempt was made to relat<
these concentration findings to other meteorological conditions of
stability, wind speed and wind direction.

Pages 63-66 and Pages 8-12, ^-°n&, Term Effects and Permit Program -
If it is well established that the long-term, chronic effects of
incinerating a specific waste at sea are negligible, would researcl
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 convention?
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 72-74, Accidental Spillage - The potential threats of acci-
dental spillage due to vessel casualties have existed for years si
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 chemic
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 comment
which we hope will be of assistance to you.  We would appreciate
receiving twelve (12) copies of the final statement.

Sincerely,
 Sidn
Deputy Assistant Secretary
for Environmental Affairs

Enclosure

-------
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-------
Response to letter of June 15, 1976, fron 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., Nowlin, 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 NQAA 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.

-------
          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,
202-343-626M-).   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^Jof the interior
Mr. Kenneth E. Biglane
Director, Oil and Special Materials
  Controls Division COSMCD) (WH-548)
Environmental Protection Agency
Washington, D. C.  20460
Enclosure

-------
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 coitments 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  1976
FROM
        Director
        Office of Environmental Affairs
SUBJECT:  Revj_ew 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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 MEMORANDUM        DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
                                                   OFFICE OF THE SECRETARY
                                                                          »
TO    :  Mr. Charles Custard, Director,  OEA             DATE-  ^^y ^»  1976
FROM  :  Environmental Officer, OAES/OFEPM


SUBJECT:  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.
                                                           -«v
    3.  The immediate short-term effects  of the incinerator emissions  on
    the 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 waste
    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 G be incorporated
    as permit requirements for future at sea incineration actions.
                                               md Goldberg         (J

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M-F1\/FO"R ANTiT TTVT       DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
xviAjivj. w JX-TV.L ^ u u ivx                         p^jk Health Service
TO    : Director,  Office of Environmental Affairs,       DATE:  June 30,  1976
         DHEW
FROM  :  Principal Environmental Officer


SUBJECT:  Comment  on EPA DEIS - Designation of a Site in the Golf 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 conment.
                                                         je H.  Denting
                                                      Acting Deputy
                                                  Environmental Officer
        Attachment

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MEMORANDUM
.DEPARTMEN1  OF HEALTH, EDUCATION, AND WELFARE
                PUBLIC HEALTH SERVICE
            IOOD AND DRUG ADMINISTRATION
TO    : Mr. Boris Osheroff
        Principal Environmental Officer/H
        Through:  Director
                  Environmental Impact Staff
                     DATE:   June 28.  1976*
FROM  :  Environmental Health Scientist
         Environmental Impact Staff (HFS-30)                   '      .

SUBJECT:  EPA—Designation of a Site in the Gulf of Mexico for Incineration
         of Chemical Wastes
         We have commented on the EIS for the overall chemical waste incinerator
         ship  project and thus we will limit our discussion to the selection of
         a site for  this project.

         Our major concern is not with normal incinerating operations on board
         the sea vessel, but rather with the possibility of(accidental discharges
         of raw waste chemicals from-the ship en route to and within the designated
         operation site.  The subject EIS addresses accidental discharges on
         pages 67 and 72 of the document, stating that:  "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 requirements for carrying hazardous cargo thereby minimizing
         the probability of the discharge of the cargo even if the ship is involved
         in accident at sea."  We recommend that, in addition to keeping the vessel
         out of recreational areas, the route taken by the ship from its point of
         loading to  the site, of incineration should also avoid major fishing and
         shrimping grounds.  Will loading and sailing of the incinerator ship be
         prohibited  under severe weather conditions or warnings of such conditions?
         What  precautions will be taken during the loading operation to avoid spills
         of toxic chemical wastes in the harbor?
                                          David S. Klauder, Ph.D.

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Response to letter of July 2, 1976 from the Department of Health, Education
and Vfelf are


A.  Response to comments from QAES/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.

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Recotmendaticjns:



    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 THfl, 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.

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        For further information regarding this report, please contact the



    preparing office of this EIS.



B.  Besponse to Garments from the Public Health Service



        The abundance of shrinping 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.

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               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

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                                   A4
30'
25*
20*
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         /INCINERATION
            SITE->
              93*
                                 90*
                                                                        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

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                                    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

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                                    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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                                  A12
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 SOOOnrVsec. (late
fall) and 23,000m^/sec. 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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                                  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 zircon
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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                                   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
foraminifera.

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,

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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.

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                        Bl
                   APPENDIX B






          GULF OF MEXICO PHYTOPLANKTON




SPECIES DISTRIBUTIONS, STANDING CROP DISTRIBUTIONS,




      PRIMARY PRODUCTION, AND SEASONAL CYCLES

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                                   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.

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                                    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 JB. 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,
 £.  peruvianum,  Hemiaulus  membranaceus, H.  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,
£.  meneghiniana, Melosira distans, M. granulata, Navicula gracilis,' and N_.
 rhynococephala; and a Gulf  population comprised of Asterionella japonica,
 Chaetoceros affinis, £. 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., Melosj.ra sp., Nitzschia pungens,
IS. sub fraudulent g_, and  Rhizosolenia fragilissima.  In both the studies of

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                                    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
IJ. regia, Ceratulina pelagica, Chaetoceros coarchtatum, £. compressum, Guinardia
flaccida, Hemiaulus membranaceus, II. 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, £. atlanticum, Navicula sp., Nitzschia seriata,
Rhizosolenia calcar-avis, _R. hebetata, 11. styliformis, and Synedra sp.
     Pinoflagellates.  Steidinger (1972a) listed 405 dinoflagellate species
which have been recorded for the Gulf of Mexico.  In addition she found that
Ceratium furca. J3. 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, (\  fusus, £.  massiliense, £.
teres,  £.  trichoceros, C^.  tripos, Ceratocorys horrida, Dinophysis caudata,
Diplopelta asymmetrica,  Gonyaulax polygramma, Heteraulacus polyedricus,
Peridinium brochii, Pyrocystis pseudonoctiluca,  and Pyrophacus horologium.

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                                   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 £. 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 Oscillatoria
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)

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                                    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-^ concentrations  at the surface and integrated to the
                                          o               2
 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
 autumn cruises  revealed  similar surface and integrated averages  of  0.23 mg/m
               2
 and 11.50 mg/m  (El-Sayed  and Turner, in  press).

 Chlorophyll-a^ 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
                                                3                       7
 integrated  values ranging from 0.009 - 0.20 mg/m  and 5.40 -  15.35 mg/m ,
 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-a values of 1.69 mg/m  and 23.55 mg/m , respectively.

Soviet investigations in the Gulf  of Mexico of  total plankton biomass
(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
Gulf was low,  with  values of 100-150 mg/m3,  compared to 200-1000 mg/m3
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-^ 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-
          O                       «}
0.26 mgC/m /hr and 2.02-4.00 mgC/mz/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
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                                   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
     Phytoplankton 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).

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                                   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
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

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                                    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
st\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)

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                                     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 207o of the catch with non-commercial
forms, namely Trachypenaeus spp.  (47%), Sicyonia spp.  (24%), Solenocera spp.
(7%),.and Parapenaeus spp.  (2%) 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

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                                 C4
         98°
               96°
94°
90°
      30°
     28°-
     26°-
                                       PROPOSED
                                       INCINERATION
                                       SITE
                               JULY-SEPTEMBER 1962
                                         92°
                                               90°
                       5-24 E=^ >I24

                              OCTOBER-DECEMBER 1962
26°-
        98°
    3O°
    28° •
    26° -
                              JANUARY-MARCH 1963
Fig. C-l.    Distributions of numbers of planktonic-stage
            Penaeus  spp.  per standard plankton  tov  in the
            northwestern  Gulf during the period July 1962
            to March 1963   (after Temple, 1965).

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                                      C5
                            95'
                                      90'
           30"
           25'
                          WEST CENTRAL
                           T
                         „_. PROPOSED
                         ^INCINERATION  SITE

                                CENTRAL
Fig. C-2.   Arnold's (1958) subregions which relate to the proposed site.
Table C-l .
Gulf of Mexico seasonal plankton  standing crop (ml/nP) 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 0-100 fms 100-1000 fms

NW

NC

WC

c

winter spring fall winter spring fall
. 055 . 104 . 009
(10) (14) (2)
.094 .142 .152 .113 .061 .074
(6) (17) (3) (4) (11) (1)
.065 .029
(5) (4)


over 1000 fms
winter spring


.091 .054
(2) (4)
.008
(1)
.038 .050
(9) (8)
fall


.096
(6)


.063
(1)

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                                    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.

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C7
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                                    C9
                 MAJOR HOLOFLANKTONIC 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

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                                   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.

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                                    Cll


 Table C-2.  Vertical zonation of calanoid copepods in the Gulf of Mexico
             as reported by Park v-^70).
                            Epipelagic
 Calocalanus pavoninus
 £.          styliremis
 ParacaIanus parvus
 Clausocalanus furcatus
 £.            paululus
 Heterohabdus spinifera
                                  Ctenocalanus vanus
                                 'Euaetideus acutus
                                  —•         giesbrechti
                                  Scolecithricella vlttata
                                 ILucicutia paraclaus^
                                  L.       favicornis
                            Mesopelagic
 Spinocalanus parabyssalis
 j>.           brevicaudatus
 j>.           c>ligospinosus
 Chiridius gracilis
 Chirundina streetsii
 Gaetanus minor
 (*. pileatus
 Scaphocalanus subcurtus
 ^.            amplius
 A'            brevirostris
 S.            magnus
                                  Scrolecithricella abyssalis
                                  ^.                 dentata
                                  Scolecithrix brady
                                  Temoropia mayumbaensis
                                  Lucicutia clausi
                                  Heterohabdus papilliger
                                  n.            vipera
                                  H^.            medianus
                                  Haloptilus paralongicirrus
                                  Pseudodaugaptilus longiremis
                           Bathypelagic
 Eucalanus attenuates
 —•         elongatus
 Rhincalanus  cornutus
 jarrania  frigidus
 Microcalanus  pygmaeus
 Mimocalanus  crassus
 M.           cultrifer
 M.          nudus
 Monacilla tenera
 Spinocalanus  abyssalis
 j^.            spinosus
 —•            pteronus
^.            usitatus
^.            horridus
§.•            ma gnus
 Teneriforma naso
 Chiridiella bispinosa
£.•          poppei
 Undinella brevipes
2-letridia  brevicauda
M.
curticauda
Lucicutia curta
L.
 ovalis
                                 Euchirella pulchra
                                 .§.•         splendens
                                 Undeuchaeta major
                                 _U.          plumosa
                                 Xanthocalanus paululus
                                 Racovitzanus porrecta
                                 Scaphocalanus curtus
                                 .§.•            echinatus
                                 JL-            major
                                 JL'            longifurca
                                 j^.            acuminatus
                                 Scolecithricella emarginata
                                 S.               maritima
                                  •
                                                  ovata
                                                  valens
Heterorhabdus abyssalis
S^.                pseudoarcuata
£[.                lobophora
Scollocalanus helenae
J.'            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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                                     C14
    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
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.
Euphausia americana*
IS.        brevis*
E.«        gibboides*
          hemigibba*
          mutica*
E.
E.'
E.
E.
                           Epipelagic
          pseudogibba*
          tenera*
Nematoscelis atlantica
Nematoscelis microps
Stylocheiron abbreviatum
A-           affine
_S_.           carinatum
j>.           suhmii
Thysanopoda monacantha
T_.          subequalis*
T.          tricuspidata*

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                                   CIS
      Table C-6.   Continued
                           Mesopelagic
Nematobranchion boopis
N^.              flexipes
1J.              sexspinosum
Nematoscells tenella
Stylocheiron elongatum
j[.           longicorne
Stylocheiron maximum
JS.           robustum
Thysanopoda cristata
—•          obtusifrons
Z-          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_. trachiformls, Creseis
acicula acicula, and £. 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
80% of Snyder's 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
.C.      virgula virgula                    L_.       bulimoides
(^.      virgula conica                     Hyalocylis striata
Cavolina inflexa                           Styliola subula
Diacria quadridentata                      Clio pyramidata
Peraclis reticulata                        £.   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 cephalopoda 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 brevis.  L_. brevis is ubiquitous in nearshore regions where
it generally inhabits estuaries and bays with salinities as low as 17 ppt.
I), 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 jystellaspis 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)
 Onykla carriboea
 Onychoteuthis banksi
 Ommastrephes pteropus
 Qmmastrephes bartramli
 Thys ano t euthis rhombus
 Liocranchia reinhardti
 Leachla cyclura
 Cranchia scabra
 Heteroteuthis hawaiiensis
 Tremoctopus violaceous
 Argonauta argo
                      Mesopelagic  (200-700 m)
 Enoploteuthis leptura
 Enoploteuthis anapsis
 Abralia veranyi
 Abralla grimpel
 Pyroteuthis  margarltifera
 Pterygioteuthis giardi
 Pterygioteuthis gemmata
 Lycoteuthls dladema
 Or egonlat euthis^ springer!
 j>elenoteuthis sclntlllans
 Histloteuthis corona corona
 Histioteuthis dofleini
                    Bathypelagic (700-2000 m)
Chlroteuthis lacertosa
Bathyteuthis abyssicola
Mastlgoteuthis glaucopsls
Mastlgoteuthis grimaldi
Joubiniteuthis portierl
Cycloteuthis slrventl
Japetella_diaphana
Eledonella pygamaea
Grimalditeuthis bomplandll
Sandalops ecthambus
Corynomma speculator
Egea inermls
Fhasmatopsls ocean!ca
Bathothauma lyronnna
Helicocranchla pfeffer!
HelicocranchJa paplllata
Megalocranchla 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)
PENAEIDAE
  *Gennadas valens  (Smith, 1884)
  *Bentheogennema intermedia Bate, 1888
  *Gennadas capensis Caiman, 1925
   Gennadas scutatus Bouvier, 1906
  *Gennadas bouvieri Kemp, 1909
   Gennadas talisman! Bouvier, 1906
          Area of Gulf
Relative  in Order of
Abundance  Abundance


Abundant  NE,NW,SE,SW
Common
Sparse
Sparse
Sparse
Rare
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
MYSIDACEA
  *Gnathophausia ingens (Dohrn, 1870)                Common
  *Gnathophausia zoea Willemoes-Suhm, 1875           Common
SW,NE,NW,SE
SE,NE,NW,SW
SE, NE
SE.NE.SW
NE,SE


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

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                                    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
affinis
Argyropelecus
gigas

Argyropelecus
hemigymnus
Argyropelecus
aculeatus
Argyropelecus
olfersi
Argyropelecus lynchus
lynchus
Sternoptyx
diaphana
Polyipnus
asteroides
All
species
D-Day
N-Night
0-
175
I> 4.8
N 1.9
D
N
D
N
r
D
N
D
N 0.5
D
N
D
N 1.0
D
N
D
N
D
N 1.6


175-
500
3.0
4.4
_
0.2
^
-

1.0
1.1
3.3
1.8
_
0.5

1.8
2.0
0.2
0.3
0.2
5.7
6.0


500-
900
0.8
2.4
_
-
1.2
-

-
-
2.4
-
.
-

.
8.4
6.8
—
-
12.0
6.8



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                                   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
mesopelagic 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 Gtnelin,  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 occidentalis  Goode & Bean, 1895
 Epigonus pandionis (Goode & Bean, 1881)
 Epinnula magistralis Poey, 1851
 Equetus acuminatus
    (Bloch & Schneider, 1801)
 Evennannella  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
Pnotostomias sp.
Polymixia lowei Gunther, 1859
Selar crumenophthalmus (Bloch,  1793)
Sphoeroides parvus Shipp & Yerger
Sphoeroides splengeri (Bloch,  1782)
                             ANTENNARILDAE
                             APOGONIDAE
                             STERNOPTYCHEDAE
                             STERNOPTYCHIDAE
                             STERNOPTYCHIDAE
                             MALACOSTELDAE
                             NEMICHTHYIDAE
                             BALISTIDAE
                             MELANOSTOMIATIDAE
                             BATHYCLUPE3DAE
                             BREGMACEROT H>AE
                             BREGMACEROTIDAE
                             CHAULIODONTIDAE
                             CARANGIDAE
                             GONOSTOMATLDAE
                             MYCTOPHIDAE
                             GONOSTOMATIDAE
                             APOGONIDAE
                             APOGONIDAE
                             GEMPYLIDAE

                             SCIAENIDAE
                             EVERMANNELLIDAE
                             GONOSTOMATIDAE
                             MYCTOPHIDAE
                             TETRAODONTIDAE
                             NOTACANTHIDAE
                             CENTRISCIDAE
                             MAIACOSTEIDAE
                             MELAMPHAEIDAE
                             MELAMPHAEIDAE

                             MELANOSTOMIATIDAE
                             MIJLLIDAE
                             MYCTOPHIDAE
                             NOTACANTHIDAE
                             APOGONIDAE
                             STROMATEIDAE
                             MALACOSTELDAE
                             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

-------
                                     D10
 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 lepturns L., 1758               TRICHIURIDAE         Cutlassfishes
                                                                    (Atlantic)
Upeneus parvus Poey, 1851                  MULLIDAE             Goatfishes
Yarella blackfordi Goode & Bean, 1895      GONOSTOMATIDAE       Lightfishes

-------
       x g





******
       or

-------
                             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 giganteus, 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 benthic1animal communities seems to have been formulated
first in the late 19th century by Karl MObius 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 interdependences, 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 Krebs' (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 Fager'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 D1 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 fin, 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 quadrifilis (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 trartletti
     Bathyplax typhla
     Homolodromia paradoxa
     Munidopsis sigsbei
     Munidopsis spinosa
     Munida valida
     Uroptychus nitidus
             •»
     Farapagurus pilosimanus
     Nephropsis agassizi
     Bathynonrus 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
Fenaeid 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 intermedius
     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+b)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(A2B)
                             ; 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(AmB)
                 ,A0...A ; B) = 	™	
                                           m
The index between a group composed of stations A  and A  and a second group
composed of stations BI and B« is
                                    -I- I(A1B2) + I(A2B1) + I(A2B2)
In general the index between groups A.., A_,  ...  A  and B. , B0, ... B .
                                     J.   z        m      l   /       m
is defined as
                           m    n
                                      KA.B )

-------
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                   Fl
              APPENDIX F




METEOROLOGICAL AND PHYSICO-CHEMICAL DATA




     PERTAINING TO THE PROPOSED SITE

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                                   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

Jan.
Feb.
March
April
May
June
July
Aug.
Sept.
Oct.
Nov.
Dec.
ANN
VISIBILITY (7« FREQUENCY)
<-0.5 MILE
0.5
*
0.2
*
0.2
*
*
*
*
0.6
0.4
*
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%

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                                      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  HUMIDIT.Y CLASSES                 OBS

                 31_40   41-50   51-60  61-70  71-80   81-90   91-100

 JAN
FEE
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
.3
.3
.1

1.6
1.0
1.2
2.6
7.9
6.6
6.2
11.3
14.5
11.6
13.2
15.1
19.9
13.1
15.1
25.8
43.1
42.7
42.4
35.3
12.7
24.5
21.8
9.7
692
773
682
846
00
06
12
18
.2
.1


1.4
.5
.5
1.8
7.2
3.0
3.5
7.1
12.9
9.0
7.1
18.6
33.1
21.9
26.3
35.9
32.8
45.0
44.6
28.1
12.5
20.5
17.7
8.4
650
796
733
835
JUN     00
        06               .1
        12
        18               .2
JUL     00               .2
        06
        12
        18               .4
 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
50.5
23.6
41.0
38.4
13.1
5.9
13.9
10.7
6.6
785
862
782
895
2.0
.3
.3
3.8
35.9
10.0
11.4
47.8
46.6
61.4
62.5
36.6
12.6
21.2
20.1
7.7
2.7
7.1
5.4
3.8
889
901
902
1036

.1
.1
.6
3.2
.5
.9
4.4
30.7
10.5
11.2
38.2
45.9
58.1
57.3
37.7
15.3
23.2
24.1
11.9
4.9
7.6
6.2
7.3
874
947
872
1019

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                                     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

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                       30° —
                      25°
                                 PROPOSED
                                INCINERATION
                                 SITE
                                 I  I   I  I  I   I  I   I  I  I   I  I   I
       JAN.
 FEB.
MAR.
            APRIL
      MAY
JUNE
JULY
            AUG.
                                1}	33	«
      SEPT.
OCT.
NOV.
            DEC.
                                   20
               40
 60
80
IOO
                               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).

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                                   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)
                 j*& - MAR
              No. of Obs.-1896

Direction  Frequency  Ave. Speed
              (%)        (kt)
Direction
     APR - JUFZ      '

   No. or Obs.-5151

.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

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                                   F8
WATER MASSES

The principal inflow cf 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; Wllst, 1964.

1.  jiurface 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.

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                                  F9
3.  Oxygen Minimum Layer (OML) - characterised 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 di^idrcd oxyg?" 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.

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                                     F10

    02       2.6    3.0    3.4   3.8    4.2   4.6    5.0

    S%o    34.8   35.0  352   35.4   35.6  35.8  36.0  362   36.4   36.6

    T°C      468    10
                        SUBTROPICAL UNDERWATE
                                     OXYGEN MINIMUM LAYER
                                SUBANTARCTIC INTERMEDIATE  WATER
                                 X\\\\N
     .200-o
  a  1600-
                   :GULF BASIN WATER:::::::::::'\:::::::.::::::::::::::::::::::::::i
    2000-:>"
    3600—T
              *
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).

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                                         Fll
                           PROPOSED INCINERATION
           20'
Fig. F-3.   Core depth in meters of salinity maximum  of the Subtropical
            under water  (after Nowlin, 1972) .
                                          PROPOSED INCINERATION SITE
                   STATIONS 119 l» 117  lit , 115  114  II] 112  III  HO  IO1 KM  IOT  lOt IO5 KX KM
                                       •4.J6
                                        2S-

                                       NORTH LATITUDE
                                                                    1


_ ' ! 1 ! 1 1 1 1 1

4 -4.20' •*7' •* .*7' -*''1 -4
^l
^ ' f ' i • ' t • : i i i • i 1 i i t 1
4.Z4. /
2t .4.24 /
,420
— ! i • i
 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
                                       i    I    i    i
                                   PROPOSED INCINERATION
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).

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                                             F13
                                            PROPOSED  INCINERATION SITE
                 STATIONS 119 IB  117  116, IIS i 114  115 112  III  no   IO9  IOB  IO7  IO6  IOS IO« 103
                          •?•"*• •*•*.&? ''   •    -\  '•,-£, •   •   -"V •    • )  • X "*""  •
                                          25-   24-   23'    22-
                                           NORTH  LATITUDE
Fig.  F-6.    Salinity (ppt)  along line  shovm  in  Fig. F-5.  Note position
              of site next  to station 115 (after Nowlin, 1972) .

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                                        F14
                   t   »
                      *
                                 PROPOSED INCINERATION

                                      SITE
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   110  109 IO8   107  106  105  104 103
             29'    28"    27-    26'    25'    24-    23*    22*    21*    20
                                   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 Nowlxn, 1972).

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                  APPENDIX G
U.S. ENVIRONMENTAL PROTECTION AGENCY, DISPOSAL OF
  ORGANOCHLORINE WASTES BY INCINERATION AT SEA
             (Under Separate Cover)

-------