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October, 1987
ERRATA
Page vii, Paragraph 3. First sentence should read:
With the passage of the Resource Conservation and Recovery
Act (RCRA) in 1976 and its 1984 amendments, the U.S.
approach to hazardous waste management is changing.
Page 1, Paragraph 1. Fourth sentence should read:
In addition, the U.S. now has more than 27,000 sites on the
Comprehensive Environmental Response, Compensation and
Liability Act information system, that may require remedial
action due to release of a hazardous substance.
Page 20, Figure 2. Additional footnote should read:
This schedule is presented here only to show the order by
which events are expected to occur. All dates are estimates,
made at the time of printing, and are subject to change.
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OCEAN INCINERATION: BACKGROUND AND STATUS
Contract No. 68-03-3319
Work Assignment 35
September 4, 1987
prepared by
Margarete S. Steinhauer
and
Christine E. Werme
BATTELLE
Ocean Sciences
397 Washington Street
Duxbury, MA 02332
for
David P. Redford
Work Assignment Manager
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Marine and Estuarine Protection
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TABLE OF CONTENTS
PAGE
EXECUTIVE SUMMARY ....... vi i
CHAPTER 1: INTRODUCTION 1
OVERVIEW OB1 HAZARDOUS WASTE DISPOSAL
BY OCEAN INCINERATION................ 2
BRIEF HISTORY OF OCEAN INCINERATION. ..„.,.. 3
DECISION TO DEVELOP REGULATIONS AND
CONDUCT RESEARCH 9
OVERVIEW OF THE STATUS DOCUMENT. 9
CHAPTER 2: OCEAN INCINERATION REGULATION................... 11
ISSUES FOR PUBLIC COMMENT 13
Determination of Need 13
Liability Limits and Financial Responsibility ..... 14
Concentration Limits for Trace Metals 14
Environmental Performance Standards 15
Waste Sampling and Analysis 16
Port Siting. 16
Applicant Integrity 17
Application Processing Fees 17
PROPOSED SCHEDULE FOR REGULATORY PROCESS AND
SITE DESIGNATION 17
CHAPTER 3: DEVELOPMENT OF AN OCEAN INCINERATION
OPERATING PROGRAM 21
SITE DESIGNATION 21
PERMITTING 26
PERMIT AND SITE MANAGEMENT 33
CHAPTER 4: EPA'S RESEARCH STRATEGY 37
BACKGROUND OF THE RESEARCH STRATEGY 37
RISK ASSESSMENT FOR OCEAN INCINERATION 37
ill
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TABLE OF CONTENTS
(Continued)
PAGE
RESEARCH"STRATEGY STUDY AREAS 39
STUDY AREA 1: DEVELOPMENT OF METHODS FOR
EMISSIONS SAMPLING AND TOXICITY TESTING 39
STUDY AREA 2: MONITORING OCEAN INCINERATION
( CONDUCT OF A RESEARCH BURN) . . . . . 44
Sampling Activities. 46
STUDY AREA 3 : ADDITIONAL RESEARCH. 52
CURRENT STATUS OF THE RESEARCH PROGRAM. . 56
GLOSSARY 57
LIST OF ABBREVIATIONS 63
BIBLIOGRAPHY 65
IV
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LIST OF TABLES
PAGE
TABLE 1. CHRONOLOGY OF EVENTS IN EPA'S OCEAN
INCINERATION PROGRAM 5
TABLE 2. SUMMARY OF OCEAN INCINERATION BURNS
MONITORED BY EPA 7
TABLE 3. ACTIVITIES CONDUCTED ON EPA'S BASELINE
SURVEY TO THE SOUTHEAST COAST SITING AREA 27
TABLE 4. APPLICATION REQUIREMENTS FOR AN OCEAN
INCINERATION PERMIT 30
TABLE 5. TOPICS TO BE INCLUDED IN AN OCEAN
INCINERATION CONTINGENCY PLAN 32
TABLE 6 . STUDY AREAS OF EPA'S RESEARCH STRATEGY 40
TABLE 7. DETAILED SAMPLING ACTIVITIES AND MEASUREMENTS
TO BE MADE DURING AT-SEA BURNS 47
TABLE 8. VARIATION IN SAMPLING ACTIVITIES FOR THREE
SCENARIOS OF EMISSIONS PLUME FATE AND
METEOROLOGICAL CONDITIONS 48
TABLE 9. STANDARD OPERATING PROCEDURES PREPARED
FOR EPA' S OCEAN INCINERATION PROGRAM 53
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LIST OF FIGURES
PAGE
FIGURE 1. REGULATORY PROCESS FOR THE OCEAN
INCINERATION REGULATIONS . . .... 18
FIGURE 2. PRELIMINARY SCHEDULE FOR OCEAN
INCINERATION SITE DESIGNATION 20
FIGURE 3. EPA'S OCEAN INCINERATION OPERATING PROGRAM
INCLUDES SITE DESIGNATION, PERMITTING,
AND MANAGEMENT. 22
FIGURE 4. PERCENT OF TOTAL OCEAN-INCINERABLE WASTE
GENERATED BY STATE, 1983 . 25
FIGURE 5. OVERVIEW OF THE PERMITTING PROCESS... 28
FIGURE 6. THE MIBAS SAMPLING TRAIN COLLECTS EMISSIONS
IN A SERIES OF SEAWATER-FILLED IMPINGERS..„ .. 42
FIGURE 7. THE 1000-LITER STAINLESS STEEL EXTRACTION TANK
ALLOWS ONBOARD PROCESSING OF
HIGH-VOLUME WATER SAMPLES „ 49
FIGURE 8. THE ROTATING-DRUM MICROLAYER SAMPLER IS
DRIVEN BY WATER TURBINES 51
VI
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EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA), under the
authority of the Marine Protection, Research, and Sanctuaries Act
(MPRSA) of 1972, is the federal agency charged with regulating the
disposal of waste materials in the ocean. The destruction of
wastes at sea through high temperature incineration is one of the
disposal activities regulated under MPRSA. This document presents
a brief history and background of ocean incineration, and the
status of EPA's ocean incineration program.
EPA's ocean incineration program has three major components: the
development of regulations; an operating program that includes
procedures for designation of incineration sites, permitting, and
site monitoring; and a research strategy to provide a sound,
technical basis for the operating program.
With the passage of the Resource Conservation and Recovery Act
(RCRA) in 1972 and recent amendments (1974, 1980) to it, the U.S.
approach to hazardous waste management is changing. In addition
to more actively encouraging reduction and recycling of wastes,
EPA has been exploring alternatives to the land-based waste
disposal option. Incineration of wastes at sea is a viable
option for the destruction of hazardous waste in the United
States .
Under the authority of the MPRSA, EPA issued a proposed ocean
incineration regulation in February 1985, and solicited public
comment on the proposed regulation through public hearings and
other mechanisms. Because several parts of the regulation
generated substantial public interest and concern, EPA is
reopening the public comment period on these sections to insure
that the public concerns are adequately addressed in the final
regulation.
Vll
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EPA is developing an ocean incineration operating program to
designate ocean incineration sites, to process permits, monitor
compliance with the permits, and to monitor the environment of the
sites. As gart of the operating program, EPA is also developing
technical guidance documents to support the regulation and the
procedures associated with designation of sites, permitting
guidance, preparation of an ocean incineration contingency plan,
and conduct of a trial burn. These guidance documents are
intended to serve the permit applicant as well as the interested
public.
To address a number of technical issues of the ocean incineration
program, EPA designed and began implementation of a comprehensive
research strategy in 1985. The research plan was divided into
three research areas: 1) development of methods for sampling and
analysis of incinerator emissions, and determining the toxicity of
the emissions to marine organisms; 2) development of methods for
monitoring ocean incineration operations; and 3) research to
determine potential impacts of ocean incineration activities.
The results of EPA's research program are being used to refine the
development of the regulations and the operating program, and to
further assess and enhance our understanding of the environmental
impact of incinerator emissions.
This document describes the status of EPA's ocean incineration
program, including research, and development of regulations and an
operating program. in addition to serving as a resource for
citizens, citizen groups, and educators, the status document is
also intended as a resource for participants within EPA's ocean
incineration program.
VI 1 1
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CHAPTER 1
INTRODUCTION
The United States is faced with a serious hazardous waste disposal
problem. In addition to disposing of the wastes we now generate,
we must find safe methods for disposing of stored wastes that have
been generated in the past and for new wastes that will be
generated in the future. According to a recent U.S. Environmental
Protection Agency (EPA) survey of hazardous waste generators, more
than one metric ton per year of hazardous waste is produced for
every citizen of the United States. In addition, as a result of
inadequate disposal practices in the past, the U.S. now has more
than 27,000 hazardous waste sites that may require remedial
action. We have, and will continue to have, large volumes of
hazardous wastes that must be disposed of safely.
EPA (the Agency) is actively pursuing ways to manage the volumes
of hazardous wastes that have been generated and those that we
will continue to produce. We are handling inherited wastes by
cleaning up acutely hazardous sites. We are addressing present
and future waste accumulations by encouraging reduction and
recycling of wastes, and development of safe waste disposal
practices.
Recent federal legislation has eliminated some of the traditional
ways in which we have disposed of wastes. The Resource
Conservation and Recovery Act of 1976 (RCRA) and its 1984
amendments could eventually close 30 to 50 percent of existing
storage, treatment, and land disposal facilities. The amendments
prohibit the disposal of noncontainerized liquids into landfills
and surface impoundments, and may eventually restrict the disposal
of certain liquid wastes into deep injection wells, the current
disposal methods for most liquid hazardous wastes. The Agency is
undertaking studies to determine the type of treatment necessary
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before certain hazardous compounds may be disposed of in landfill5
and surface impoundments in accordance with the schedule outlined
in the 1984 Amendments to RCRA. Depending on the outcome of these
studies and the availability of treatment technologies, certain
hazardous compounds may be banned from landfills and surface
impoundments. Thus, even with active efforts to reduce and
recycle wastes, an increasing volume of wastes will require
disposal by alternative methods.
EPA believes that the well-regulated destruction of certain
hazardous wastes by incineration, whether on land or at sea, is
preferable to their storage in landfills or deep disposal wells.
Land-based incineration alone will not fill this need. The 225
land-based incinerators operating under EPA-issued permits and
regulation are destroying only about 1 percent of all the
hazardous waste generated annually. Due to the large volumes of
wastes generated and the restrictions on certain land-based
disposal options (such as landfills), EPA is seeking to make -more
options available for destroying wastes. Therefore, in the last
decade this country has begun to explore alternative disposal
technologies including the concept of burning wastes at sea, a
process that was developed about 20 years ago in Europe. The
technology has been improved so that currently operating ocean
incinerators function under conditions similar to land-based
incinerators.
OVERVIEW OF HAZARDOUS WASTE DISPOSAL BY OCEAN INCINERATION
Ocean incineration involves loading wastes aboard ships equipped
with specially designed incinerators and transporting these wastes
to a designated site 100 miles or more from shore where the wastes
are burned. Burning time for a full load ranges from slightly
more than 6 days to a little over 10 days. The process uses high-
temperature incineration to destroy hazardous wastes, converting
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most of the hazardous chemicals to harmless compounds such as
carbon dioxide and water, and leaving very little residue. When
chlorinated organic compounds are burned, the emissions also
include hydrogen chloride, which, upon contact with the sea
surface, are quickly neutralized by the enormous buffering
capacity of the ocean. Products of incomplete combustion (PICs)
may also be formed in trace amounts. EPA is continuing research
on the formation of PICs and their effects on the environment.
U.S. regulations require that the incineration process (either on
land or at sea) destroy 99.99 percent of the wastes' hazardous
components and 99.9999 percent of the extremely hazardous
compounds, such as dioxins, polychlorinated biphenyls (PCBs), and
dibenzofurans, if these compounds are included in the waste
mixture. EPA studies indicate that incineration on land or at sea
poses low risks to human health and to the environment.
Incinerating hazardous wastes at sea, a greater distance from
populated areas, lowers the human risk factor significantly below
that of land-based incinerators. On the other hand, a spill
enroute to the port or while at sea could potentially cause
environmental damage. EPA estimates the probability for a spill
of any size to be 1 in 19,200 voyages and 1 in 384,000 voyages for
a large spill.
Studies to date indicate that ocean incineration does not have
measurable effects on the marine ecosystem. Incineration can be a
valuable, environmentally sound option for destroying liquid
hazardous waste, particularly when contrasted to methods
historically used for disposal or storage on land.
BRIEF HISTORY OF OCEAN INCINERATION
The technology for incinerating hazardous wastes at sea was
developed in Europe nearly 20 years ago and, since that time, many
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technological advances in ocean incineration have been made. The
feasibility of incinerating organochlorine wastes at sea was
initially demonstrated in the North Sea by a German company using
the M/T Matthias I_, a tanker ship equipped with a small
incinerator. Since 1969, other European vessels have been
modified or ^designed for incinerating wastes at sea. Several
European countries regularly use ocean incineration to destroy
liquid organic hazardous wastes. Australia and Japan also use
the technology of ocean incineration.
In the United States, ocean incineration is not currently a
commercially available option for disposal of hazardous wastes.
The U.S. has, however, been evaluating this technology for 13
years. Within EPA's Office of Water, the Office of Marine and
Estuarine Protection (OMEP) is responsible for regulating ocean
incineration. OMEP is developing final regulations and an
operating program before this technology can be used commercially
as a waste disposal option. A chronology of major events over
those 13 years is shown in Table 1.
Between 1974 and 1982, research permits for incineration were
granted by EPA for a series of four burns (Table 2). A
fundamental purpose of these research burns was to test the
efficiencies of the incinerators for destroying the hazardous
materials and to evaluate the operating conditions of the vessels.
Three of the four series of burns were carried out in the Gulf of
Mexico. The fourth was conducted in the South Pacific Ocean near
Johnston Atoll. All of the burns were conducted on the M/T
Vulcanus _!, and were accompanied by various research and
environmental monitoring activities. In addition to the four sets
of incineration operations, in 1982 EPA monitored a European burn
of organochlorine wastes on the newly constructed M/T Vulcanus II
in the North Sea.
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TABLE 1. CHRONOLOGY OF EVENTS IN EPA'S OCEAN INCINERATION PROGRAM
DATE EVENT
Prior Industrial wastes were dumped
to 1973 directly into the ocean.
July 1974 Shell Chemical Co. contracts with
the Netherlands company, Ocean
Combustion Services (OCS), to use
the M/V VULCANUS to conduct
at-sea incineration of
organochlorine wastes.
24 Sept EPA determined that ocean
1974 incineration of wastes is under
the purview of the MPRSA of 1972,
as amended.
Late 1974- The first U.S. research bum of
Early 1975 hazardous wastes. Organochlorines
incinerated in a series of bums
in the Gulf of Mexico on the M/T
VULCANUS.
8 July EPA issued Final ELS for
1976 Designation of the Gulf of Mexico
Incineration Site.
20-24 First Consultative Meeting of
Sept 1976 Contracting Parties under London
Dumping Convention (LDC) agreed
that procedures for controlling
incineration-at-sea should be
developed.
11 Jan Regulations implementing the
1977 MPRSA promulgated.
Early 1977 Second series of organochlorine
waste incinerations on the M/T
VULCANUS in the Gulf of Mexico.
April- EPA issued Research Permits to
Sept 1977 the U.S. Air Force to incinerate
a total of 16,520 metric tons of
Herbicide Orange during three
separate burns on the M/T
VULCANUS in the South Pacific.
9-13 Oct Third Consultative Meeting of
1978 LDC adopted regulations
concerning at-sea incineration.
DATE
25 Nov
1981
Late 1981-
Early 1982
26 April
1982
Aug 1982
17 Nov
1982
14-19 Feb
1983
Oct 1983
21 Oct
1983
EVENT
EPA released Final FJS for the
designation of the North Atlantic
Incineration Site (NAIS).
Under Research Permits issued by
EPA, Chemical Waste Management,
Inc. (CWM)/OCS incinerated 3,500
metric tons of PCS wastes on the
M/T VULCANUS I at the Gulf of
Mexico Incineration Site.
Redesignation of the Gulf of
Mexico Incineration Site
(47 FR 17817).
EPA issued a Research Permit to
CWM/OCS for a second incineration
of PCS wastes on the VULCANUS I
in the Gulf of Mexico.
EPA proposes designation of the
NAIS (47 FR 51769).
EPA monitored a successful North
Sea bum of organochlorine wastes
on the newly built M/T VULCANUS
n.
SeaBum, Inc. initiates
incineration-at-sea permit
application process.
EPA published Tentative
Determination to Issue Special
and Research Permits to CWM in
Federal Register (48 FR 48986).
The Special Permit would have
authorized incineration of
300,000 metric tons of mixed
chlorine wastes on the VULCANUS I
and n over a 3-year period at
the Gulf of Mexico Incineration
Site. The 6-month Research
Permit would have authorized the
VULCANUS II to incinerate DDT.
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TABLE 1
(CONTINUED). CHRONOLOGY OF EVENTS IN EPA'S OCEAN
INCINERATION PROGRAM
MTE
21, 22
Nov 1983
Dec 1983
Jan 1984
EVENT
18 Feb
1984
Brownsville, TX and Mobile, AL
Public Hearing on 21 October
tentative determination to issue
permits to CWM/OCS.
At-Sea Incineration, Inc.
initiates incineration-at-sea
permit application process.
EPA's Office of Policy, Planning,
and Evaluation (OPPE) initiated
an Incineration Study to collect
more data on at-sea incineration
and land-based alternatives, and
to review risks, benefits, and
costs associated with both
disposal alternatives.
launching of the incinerator ship
APOLLO I, built by the Tacoma
Boat Co. for At-Sea Incineration,
Inc.
April 1984 EPA Science Advisory Board (SAB),
Environmental Effects, Transport
and Fate Committee initiated a
review of ocean and land
incineration.
23 April Brownsville/Mobile Public Hearing
1984 Officer's Report recommended
against EPA's tentative
determination to issue a Special
Permit to CWM; suggested issue of
new Research Permits to conduct
additional testing and
monitoring. The report also
recommended that issuance of
Special Permits be delayed until
specific ocean incineration
regulations were promulgated.
23 May EPA formally denied the special
1984 and research permits; initiated
development of specific ocean
incineration regulations and a
comprehensive research strategy.
MTE EVENT
Nov 1984 Environmental Oceanic Services
Corp. initiates incineration
permit application process.
Nov 1984 Public meeting to discuss/develop
Research Strategy.
19 Feb EPA published Final Ocean
1985 Incineration Research Strategy.
28 Feb EPA's Proposed Ocean Incineration
1985 Regulation published in Federal
Register (50 FR 8222).
March 1985 EPA's OPPE published an
Assessment of Incineration as a
Treatment Method of Liquid
Organic Hazardous Wastes
(Incineration Study).
April 1985 EPA's SAB released its Report on
the Incineration of Liquid
Hazardous Wastes by the
Environmental Effects, Transport,
and Fate Committee.
April-May EPA held five public hearings on
1985 the Proposed Ocean Incineration
Regulation.
16 Dec EPA published tentative
1985 determination to issue a Research
Permit to CWM to incinerate PCB
wastes at the MAIS aboard the M/T
VULCANUS H (50 FR 51360).
Jan Series of Public Hearings on
1986 EPA's tentative determination to
grant CWM a research permit.
1 May Hearing Officer's Report,
1986 summarizing January 1986 public
hearings, was released.
28 May EPA denied the Research Permit to
1986 CWM and decided to grant no
permits until Ocean Incineration
Regulation was finalized.
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TABLE 2. SUMMARY OF OCEAN INCINERATION BURNS MONITORED BY EPA
Date
Vessel
1974-75 Vulcanus I
Type of. Waste Location Reference Results
Organochlorines Gulf of Wastler et
Mexico al., 1975
Greater than 99.95% DE
No detectable
emissions in
marine water samples
1977
Vulcanus I Organochlorines
Gulf of
Mexico
Clausen et
al., 1977
• Greater than 99.99% DE
• Possible PICsc
• No observed effects
on plankton
1977
Vulcanus II
Herbicide
Orange
South Ackerman • Greater than
Pacific et al., 999.999% DE for
1978 chlorinated organics
• Limited environmental
tests; no observed
effects
1981-82 Vulcanus I
PCBs/
Chlorobenzenes
Gulf of
Mexico
Metzger et
al., 1983;
Ackerman et
al., 1983
Greater than
99.99989% DE for
PCBs and 99.99993%
for chlorobenzenes
No waste detected in
plume, organisms or
water samples
from U.S. Congress, Office of Technology Assessment, 1986
Destruction Efficiency
Products of Incomplete Combustion
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Two types of vessels are currently being considered for ocean
incineration operations. One type is a tanker ship that has a
double hull and double bottom with segregated below-deck
compartments for storage of the wastes to be burned. Segregated
tanks minimize hazards in the event of an accident. The vertically
mounted incinerators on the tanker vessels are without scrubbers
and release emissions directly into the atmosphere. The Vulcanus
ships, which are currently being used in Europe, fall into this
design category. In addition to the Vulcanus !_ and II, there are
two other tanker-type incineration vessels available for operation
in the U.S. The M/T Apollo ^ is a fully constructed vessel and
the M/T Apollo II is partially constructed.
The second type of vessel being considered for ocean incineration
is a container vessel, either in the form of a self-propelled
vessel or an ocean-going barge. This type of vessel transports
intermodal (IM) stainless steel tank containers. The wastes would
be pumped into the IM tanks at the generator's site, sealed, and
readily transported via rail, truck, barge, or ship to the
container vessel without requiring additional pumping of the
wastes. For incineration vessels employing IM tanks, horizontally
designed incinerators equipped with seawater scrubbers are
proposed for use. The horizontal orientation is required to
accommodate the two combustion chambers and scrubbers.
Horizontally oriented incinerators also reduce the altitude of the
emissions plume by cooling the hot exhaust gas. The seawater
scrubbers are designed to remove hydrogen chloride from the
atmospheric emissions and deposit the acid/seawater directly into
the wake of the vessel where it would be quickly mixed into the
sea.
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DECISION TO DEVELOP REGULATIONS MID CONDUCT RESEARCH
Following the 1982 burn of PCB waste in the Gulf of Mexico ?.nd the
1983 burn of organochlorine waste in the North Sea, EPA received
an application from Chemical Waste Management, Inc. (CWM) for
special (permits to operate commercially) and research permits.
CWM proposed to burn PCB and DDT wastes at the Gulf of Mexico
Incineration Site. EPA issued a proposed permit and held hearings
to obtain public input. Upon evaluation of both oral an^ written
comments, the presiding officer recommended that EPA deny the
special permits, based on inadequate demonstration of need for the
permit (Hearing Officer's Report, U.S. EPA, 1984). The report
recommended that EPA consider granting additional research permits
to test incinerator performance and to conduct research
activities. It also recommended that EPA delay granting any
special permits until promulgation of specific ocean incineration
regulations.
Shortly following the release of the Hearing Officer's Report,
EPA's Assistant Administrator for Water published an announcement
(U.S. EPA, 1984) that generally supported the report's
recommendations and denied all permits to the applicant. The
Assistant Administrator directed EPA to initiate development of
specific ocean incineration regulations and to design a
comprehensive research plan for more accurately and completely
examining the potential risks of incinerating wastes at sea. This
plan would describe how the work conducted to date and new
information would be used to develop a greater understanding of
the ocean incineration process.
OVERVIEW OF THE STATUS DOCUMENT
This status document describes the status of EPA's ocean
incineration program, including 1) the process of developing
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effective regulations, 2) development of an operating program to
guide site designation, permitting, and management processes, and
3) conduct of research to ensure that the regulations and the
operating program have a firm technical base, and that public
concerns are addressed. This document includes a discussion of
EPA's completed and ongoing activities conducted in support of
developing a safe and technically sound ocean incineration program
in the U.S.
This document is intended to be a resource for elected officials,
citizens, citizen groups, and educators. It will also serve as a
resource to participants within the ocean incineration program so
that those involved in specialized portions of the work may better
understand the program as a whole. It is important that the
technology, the regulation, and the operational activities
associated with the program be understood so that a carefully
designed, regulated, and monitored ocean incineration program can
be developed.
10
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CHAPTER 2
OCEAN INCINERATION REGULATION
In the U.S., the statutory authority for regulating ocean waste
disposal, including ocean incineration, rests in the Marine
Protection, Research, and Sanctuaries Act (MPRSA) of 1972 (P.L.
92-532). EPA is responsible for designation of potential sites
for incinerating wastes, for evaluating and granting or denying
applications for permits to incinerate wastes at designated sites,
and for monitoring both permit compliance and possible
environmental effects of ocean incineration activities.
Although the MPRSA (also known as the Ocean Dumping Act) gives EPA
the authority to regulate ocean incineration, the actual
procedures, guidelines, and requirements for regulating ocean
incineration were initially included in the Ocean Dumping
Regulations (40 CFR, Part 228), which were developed to
specifically regulate the disposal of waste materials at sea. The
Ocean Dumping Regulations address direct dumping of dredged
materials, dumping of other solid and liquid wastes, and
incineration of waste materials. The procedures and requirements
of the Ocean Dumping Regulations are, however, more relevant to
direct dumping than to ocean incineration of wastes. The Ocean
Dumping Regulations relied on the ocean incineration guidelines of
the London Dumping Convention (LDC), an international agreement
that governs the disposal of waste materials at sea.
The ocean incineration provisions of the LDC are not as
comprehensive as current U.S. land-based incineration regulations.
Although most basic requirements are the same, the detailed
procedures for permit application, review,- public comment, and
compliance are not completely described. All previous U.S. ocean
incineration permits have relied on the combined requirements of
the Ocean Dumping Regulations and the LDC guidelines.
11
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In order to bring the ocean incineration regulatory procedures and
requirements more in line with land-based incineration
regulations, EPA issued a Proposed Ocean Incineration Regulation
(50 FR 8222) in February 1985. Site designation and management
procedures of this rule are modeled after the Ocean Dumping
Regulations '"and the LDC; incinerator performance requirements and
hazardous waste handling provisions are adapted from RCRA and the
Toxic Substances Control Act (TSCA).
Major provisions of the 1985 proposed regulation include the
requirement to demonstrate need for ocean incineration; criteria
for site selection and site designation; procedures for
permitting; and specifications for incineration operations and
site monitoring. The proposed regulation also includes
information on incinerator performance, waste specifications and
limitations, and procedures for calculating allowable
concentrations of metals in the waste mixture.
The public comment period for the 1985 proposed regulation was
initially open for 90 days following publication in the Federal
Register (50 FR 8222, 28 February 1985). During that period, EPA
received many comments on various aspects of the regulation. To
ensure that concerns of the public are fully addressed in the
final ocean incineration regulation, EPA has decided that the
public comment period on some major issues should be reopened.
Therefore, the comment period will be reopened in late 1987 on the
following issues:
• Determination of "need."
« Financial responsibility of the applicant.
• Concentration limits for trace metals in
the waste mixture.
• Implementation of environmental performance
standards.
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• Protocols for waste sampling and analysis.
• Port siting.
• Permit applicant integrity.
• Permit application fees.
In preparing the final ocean incineration regulation, EPA will
consider all comments on these issues as well as all comments
received to date on the 1985 proposed regulation.
ISSUES FOR PUBLIC COMMENT
Determination of Need
Many of the public comments received on the Proposed Ocean
Incineration Regulation expressed concern about the "needs"
>
determination. Under the provisions of both the LDC and MPRSA,
the need for ocean incineration must be established before a
permit can be issued. According to the 1984 Eighth Consultative
Meeting of the LDC, the requirement to demonstrate "need" was
interpreted to mean that alternative disposal methods should be
considered in light of a comparative assessment of hazards and
risks, environmental effects, future uses of the disposal site,
and economics. Similarly, under Section 102 of the MPRSA, EPA is
required to consider alternate disposal or recycling methods in
evaluating the need for an ocean incineration permit.
The 1985 proposed regulation states that need would be evaluated
on a national scale through a generic assessment. It was
proposed that need would be presumptively demonstrated if ocean
incineration posed less or no greater risk than practical
land-based alternatives. EPA has recently modified the proposed
approach and has developed a system for determining need. Public
13
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comment on this system will be requested when the comment period
is reopened in late 1987.
Liability Limits and Financial Responsibility
Liability limits represent maximum amounts of money that the
permittee can legally be required to pay for damages resulting
from ocean incineration operations. Financial responsibility must
be demonstrated to assure that the permittee has sufficient
financial resources to meet the liabilities that may be incurred.
The MPRSA does not specify liability limits, nor does it
explicitly authorize EPA to impose financial responsibility. The
Proposed Ocean Incineration Regulation (§234.10) states that a
permit applicant must demonstrate an annual aggregate insurance
coverage for cleanup and mitigation of any unauthorized or
accidental release of hazardous wastes. In December 1986,
Congress ordered, under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), the establishment of
specific limits of liability for an owner/operator of an
incinerator vessel and directed EPA to impose financial
responsibility requirements on owners/operators of incinerator
vessels. Under this authority, EPA has developed a financial
responsibility demonstration level and mechanisms that a potential
operator can use to establish financial responsibility. EPA will
allow comment on these proposals during the reopening of the
comment period in late 1987.
Concentration Limits for Trace Metals
Section 234.45 of the proposed regulation prohibits ocean
incineration of wastes containing metals in concentrations greater
than 500 parts per million (ppm). In addition, the concentration
of a
uu parts per minion i ppm; . in auuj.Lj.un, cue <~
-------
dilution in the water column, would not exceed its marine water
quality criterion. Because the distinction between a metallic
waste (i.e., containing greater than 500 ppm of a metal) and a
metal-contaminated waste (i.e., containing less than 500 ppm of a
metal) has been arbitrarily made, this section of the Proposed
Ocean Incineration Regulation is being reexamined by EPA, and the
revisions to be included in the final regulation will be open to
additional public comment in late 1987.
Environmental Performance Standards
The use of an oceanic dispersion model to determine environmental
performance standards is required by the LDC. Environmental
performance standards are limits for the highest concentrations of
chemicals that can safely be emitted in the incinerator stack
emissions without endangering human health or the environment.
EPA has developed a two-part atmospheric and oceanic dispersion
model to determine allowable concentrations of metals and
organochlorines in the waste stream such that, after incineration,
the concentrations of the constituents in the emissions will not
exceed environmental performance standards. In reviewing the
public comments on this issue, EPA identified several weaknesses
of the proposed model. For example, the release zone for
incinerator emissions is defined by the model as the upper 20
meters of surface water. This assumption, adopted from the Ocean
Dumping Regulations, may not be appropriate for incinerator
emissions, which are more likely to settle on the surface of the
ocean than to undergo mixing in the upper 20 meters of the water
column.
The Agency has recently developed a new model (INSEA; short for
iNcineration at SEA) that has both atmospheric and oceanic
components. The INSEA model, which is a "worst case" model, is
proposed for use in determining environmental performance
standards. Public comment on the INSEA model will be accepted by
EPA during the reopening of the comment period.
15
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Waste Sampling and Analysis
As part cf the permit application, the proposed regulation
(§ 234.15) requires applicants to submit to EPA a chemical
analysis of" every shipment of waste covered by a separate
manifest. This procedure would ensure that prohibited substances
(listed in § 234.45) are not included in the wastes destined for
ocean incineration. The proposed regulation additionally
specifies analysis of the final blended waste mixture to ensure
that the waste components meet the limits specified in the permit.
Public comments received by EPA on these requirements indicate
that analyses of separately manifested waste shipments by both EPA
and potential applicants are unreasonable due to analytical costs.
Separate waste analyses are not required for land-based
incineration operations.
EPA is considering an option that does not require analysis of
each separately manifested waste, but imposes rigorous EPA spot
checks on these waste shipments and requires monitoring and record
keeping by the permittee. In addition, EPA would require chemical
analysis of the final blended waste, or a statistically
representative number of tanks containing the final blended waste,
for the prohibited and restricted substances. EPA will request
comment on- this approach.
Port Siting
EPA
The 1985 proposed regulation did not address port siting.
recently completed a study characterizing U.S. ports and the risks
associated with their use, based on historical data (ECO, 1986).
The Agency will submit for public comment guidance for evaluation
of ports by an applicant.
16
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Applicant Integrity
A proposal to require an evaluation of the integrity of permit
applicants was considered by EPA, but later rejected for inclusion
in the Proposed Ocean Incineration Regulation. EPA believes that
there is no equitable basis for making such an evaluation.
Instead, EPA proposes to address the integrity issue by focusing
on the permittee's adherence to permit conditions, and the
permittee's compliance record and general enforcement efforts.
Application Processing Fees
Public comments on the proposed regulation indicated that the
permit processing fees of $1,000 for use of designated sites and
$4,000 for nondesignated sites were inadequate. The Agency is
considering increasing these fees to recover actual costs of
processing an application. Comment on this concept will be
i
solicited during the reopening of the public comment period.
PROPOSED SCHEDULE FOR REGULATORY PROCESS AND SITE DESIGNATION
The ocean incineration regulatory process is outlined in Figure 1.
This process includes EPA's current schedule for issuing the final
ocean incineration site designation regulation and, before
finalizing this part of the rule, for reopening the comment period
on the issues discussed above. The proposed final rule for site
designation, which will be issued separately from the remainder of
the final ocean incineration regulation, will be available by late
1987 and will allow initiation of the site designation process.
Reopening of the public comment period on the issues described
above is also scheduled for late 1987. No permit-related
activities will occur until both parts of the ocean incineration
regulation are final.
17
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PR(
3POSED OCEAN INCINERATION REGULATION
February 28, 1985
Permit Application Procedures/Requirements
Permit Application Processing Procedures
Criteria for Evaluating Ocean Incineration Activities
Permit Requirements
Criteria for Site Management
Criteria for Site Selection
Criteria and Procedures for Site Designation
oo
PROMULGATE FINAL RULE
Late 1987
Criteria for Site Selection
Criteria and Procedures for Site Designation
Begin Site Designation Process
Operating Program
REOPEN COMMENT PERIOD
ON CERTAIN ISSUES
Late 1987
PROMULGATE FINAL RULE
Late 1988
Permit Application Procedures/Requirements
Permit Application Processing Procedures
Criteria for Evaluating Activities
Permit Requirements
Criteria for Site Management
FIGURE 1. REGULATORY PROCESS FOR THE OCEAN INCINERATION REGULATIONS
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A preliminary schedule for the site designation process and
development of ElSs for site designation is shown in Figure 2.
The publication of the final rule for site designation will be
accompanied by a site designation guidance manual (described in
the section that follows). EPA's site designation activities
include coordination with the EPA Regions associated with each
proposed site and with other federal agencies including the Fish
and Wildlife Service (FWS) and Minerals Management Service (MMS)
of the Department of the Interior; the National Marine Fisheries
Service (NMFS) and other offices within the Department of
Commerce, National Oceanic and Atmospheric Administration (NOAA);
and the United States Coast Guard (USCG) of the Department of
Transportation. The process outlined in Figure 2 includes several
opportunities for state and local agencies, as well as citizen
groups, to become involved in the site designation process.
Development of site designation EISs or EIS supplements is
currently scheduled for four U.S. locations: the north Atlantic,
the Gulf of Mexico, the southeast coast, and the west coast.
19
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to
o
SITE DESIGNATION REGULATION
MAIN OCEAN INCINERATION REGULATION
NORTH ATLANTIC INCINERATION SITE EIS
GULF INCINERATION SITE EIS
SOUTHEAST COAST INCINERATION SITE EIS
WEST COAST INCINERATION SITE EIS
1987
Final
Reopen
Comment
Period
NOI/SM
NOI
NOI
1988
Final
DEISS FEISS
FR FR
DEISS FEISS
FR FR
PDEIS DEIS
SM FR
PDEIS DEIS
SM FR
1989
— : : : .
FEIS
FR
FEIS
FR
LEGEND
DEISS = Draft EIS Supplement
FR - Federal Register Announcement
FEISS = Final EIS Supplement
NOI = Notice Of Intent
SM = Scoping Meeting
PDEIS = Preliminary Draft Environmental Impact Statement
DEIS = Draft Environmental Impact Statement
FEIS = Final Environmental Impact Statement
FIGURE 2. PRELIMINARY SCHEDULE FOR OCEAN INCINERATION SITE DESIGNATION
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CHAPTER 3
DEVELOPMENT OF AN OCEAN INCINERATION
OPERATING PROGRAM
Effective management of EPA's ocean incineration program has
required development of an operating program. The operating
program encompasses the site designation process, ocean
incineration permitting, and management of sites and permits
(Figure 3 ) .
SITE DESIGNATION
Designation of sites enables EPA, other Federal agencies, and the
public to define specific areas or "sites" where incineration
could occur without endangering human health or the environment.
>
Designation of a site does not imply authority to use the site.
Rather, the site becomes available for potential users to apply
for its use through a permit application. The site designation
process includes several opportunities for public review and
comment. Sites are proposed for designation in the Federal
Register and a draft EIS (DEIS) is made available to anyone
requesting a copy. Public hearings and briefings are held to
obtain public comment; comments are additionally solicited on the
site designation DEIS. If the proposed site is found to be
acceptable for designation, EPA prepares a final EIS (FEIS) and
designates the site through notice in the Federal Register.
EPA's site designation program currently involves preparation of a
site designation guidance manual that will serve as a companion to
the 1987 ocean incineration site designation regulation. The
manual will describe the legislative and regulatory framework for
the site designation process. It will also present the
considerations that guide decisions concerning designation of a
21
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OCEAN INCINERATION OPERATING PROGRAM
40 CFR PART 234
SITE DESIGNATION
• Site Selection Criteria
- Location, water depth and
to | distance from land
- Avoidance of sensitive areas,
fisheries, major shipping lanes
- Site meteorology/oceanography
- Waste types/quantities
- Site environmental conditions
- Navigational aids/ease of surveillance
• Designation Process
PERMITTING
Permitting Issues
- Waste composition/quantity
- Trial burn
- Incinerator operations
- Contingency plan
- Monitoring requirements
- Loading port/facilities
~ Application requirements
PERMIT/SITE MANAGEMENT
• Permit Compliance
• Impact Assessment
- Movement towards shorelines
or sensitive areas
- Absence of pollution-sensitive biota
- Progressive change in water quality
- Accumulation of materials in the
water column or biota
FIGURE 3. EPA'S OCEAN INCINERATION OPERATING PROGRAM INCLUDES SITE DESIGNATION,
PERMITTING, AND MANAGEMENT
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site. The guidance manual will outline the procedures for
selecting a site, preparing an EIS (or EIS supplement to update an
existing EIS), and receiving input from EPA regional offices,
other federal agencies, states, and the public.
The manual will also present an outline and sample format for
draft and final EISs. It will describe the formal designation of
a site from publication of a proposed designation in the Federal
Register for public comment to final designation of the site in
the Federal Register.
Other activities in EPA's site designation program include ongoing
evaluations of designated or potential sites. EPA is currently
reviewing and updating EISs that have been prepared for the Gulf
Incineration Site (EPA, 1976) and for the North Atlantic
Incineration Site (EPA, 1981). The Agency is also evaluating two
additional areas off the southeast and west coasts of the U.S. for
consideration as incineration sites.
In 1976 EPA designated a location in the Gulf of Mexico for
incineration of liquid organohalogen wastes and redesignated the
site in 1982. In response to public concern about the site, EPA
has decided to supplement the existing EIS for the site, adding
new criteria from the ocean incineration site evaluation,
selection and designation regulation, adding new information
pertaining to the appropriateness of using the site for
incineration activities, and evaluating alternative locations in
the Gulf of Mexico. A scoping meeting will be planned for
discussion of the issues to be addressed in the EIS supplement,
and the draft EIS supplement will be made available to the public
for comment. During this process, the Gulf Incineration Site will
remain designated as an ocean incineration site.
The EIS for the proposed North Atlantic Incineration Site, which
was completed in 1981, is being updated (in the form of an EIS
23
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supplement) to include information gathered during recent EPA
surveys of the site and other relevant data that have become
available since 1981. The EIS supplement will be made available
to the public for comment. The NAIS could be designated for ocean
incineration when the regulation becomes final.
An area off the southeast coast of the U.S. (off South Carolina,
Georgia, and Florida) is being evaluated through preliminary
review of available data, including Department of Commerce NOAA
data and EPA surveys of the vicinity, to determine whether an area
suitable for consideration as an incineration site can be located.
Potential sites would then be evaluated through the full site
designation process previously described, prior to a decision to
designate any site in the area off the southeast U.S. coast.
The west coast of the U.S. is also under evaluation for a
potential ocean incineration site. Data from NOAA and other
sources, combined with data from an EPA survey off the west coast,
will be used to determine whether suitable areas for ocean
incineration can be located. Potential sites would be evaluated
through the full site designation process.
EPA is conducting a comprehensive evaluation of these four areas
for potential future ocean incineration operations so that wastes
from the U.S. could be brought to the nearest designated site for
destruction. Figure 4 illustrates the congressional estimate of
the percent of total hazardous wastes generated by each state.
Because more than 60 percent of the U.S. hazardous waste is
generated by coastal states, the availability of designated sites
on each of the U.S. coasts would minimize land-based
transportation risks.
Since 1983, EPA has conducted several baseline surveys of the
proposed NAIS, the CIS, and an area off the southeast coast on the
Blake Plateau. Data collection has included evaluation of air and
24
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0.30
~" ----- — •-,_!_
o
9 0.5
i
"— L
r
r
1 0.7
I
........
L
i
0.1
-
1
1
2.3
^
i
\ 3.2
0.3
/
t
\
1.4
^— — — "
1
0.8 j
J
\ \
7.4
0.3(DE)
0.5(MD)
FIGURE 4. PERCENT OF TOTAL OCEAN-INCINERABLE HAZARDOUS WASTE GENERATED BY
STATE, 1983 (U.S. CONGRESS, 1986)
-------
water for background levels of organic compounds of the type that
may be incinerated or that may result from incomplete combustion
of wastes; evaluation of water quality parameters to describe the
water masses in each of the areas; characterization of the neuston
community to describe the kinds and types of organisms (such as
fish eggs or larvae) in the surface waters; and quantification of
seabirds and endangered species of whales and turtles in each of
the areas to determine whether the areas are frequented by them.
EPA will include the data from these surveys in site designation
ElSs or EIS supplements. These baseline data will be used to
assess the amounts of organic materials in the air and water prior
to any incineration operations, and to determine whether any
seabird, whale, or turtle species would be adversely affected by
incineration activities. Table 3 lists the activities conducted
during the most recent survey of the southeast coast siting area
in July 1987.
PERMITTING
After the final ocean incineration regulation is issued, EPA could
receive applications for ocean incineration. After an application
is received and found to be complete, it would be reviewed and
evaluated by EPA. EPA would then prepare a notice for publication
in the Federal Register requesting public comments on the proposal
to grant the applicant an operating permit. Permit-related
activities are completely separate from the site-designation
activities previously discussed.
The permitting process is long, complex, and includes an
opportunity for public comment and participation. Figure 5
presents an overview of the steps involved in the permitting
process. To request an ocean incineration permit, the
owner/operator of an incinerator vessel prepares a detailed
26
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TABLE 3. ACTIVITIES CONDUCTED ON EPA'S BASELINE SURVEY TO
THE SOUTHEAST COAST SITING AREA
Collection of sea-surface microlayer for the
determination of background levels of semivolatile
organic compounds, total organic halcgens (TOX), and
trace metals and for microbiological characterization.
Collection of surface-water for the determination of
background levels of semivolatile organic compounds,
TOX, trace metals, water quality and biochemical
parameters (pH, alkalinity, temperature, salinity,
dissolved oxygen, total suspended solids, chlorophyll
a, phaeophytin, and adenosine triphosphate) .
Hydrographic characterization of the water column
using expendable bathythermographs (XBTs) and a
conductivity-temperature-depth instrument (CTD).
Collection of neuston for species characterization and
determination of background levels of semivolatile
organic compounds.
Collection of air samples for determination of
background levels of semivolatile organic compounds.
Collection of precipitation samples for determination
of background levels of semivolatile organic
compounds, TOX, pH, and alkalinity.
Meteorological observations that include atmospheric
profiling.
Current measurements by ARGOS satellite drogue and
radio drogue tracking methods.
Observations of endangered species of cetaceans,
marine turtles, and seabirds.
27
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OWNER/OPERATOR OF INCINERATOR VESSEL
APPLIES FOR PERMIT
JEPA REVIEWS APPLICATION]
EPA PREPARES DRAFT PERMIT I
EPA HOLDS PUBLIC HEARING AND ACCEPTS
COMMENTS ON DRAFT PERMIT
EPA REVIEWS AND RESPONDS TO COMMENTS
EPA DECIDES TO APPROVE OR DENY APPLICATION)
PUBLIC MAY APPEAL DECISION
IF FINAL PERMIT IS PREPARED, OWNER/OPERATOR
MUST CONDUCT TRIAL BURN
EPA REVIEWS RESULTS OF TRIAL BURN
TRIAL BURN DATA MADE AVAILABLE
TO PUBLIC FOR COMMENT
IF DATA ARE ACCEPTABLE,
EPA ISSUES OPERATING PERMIT
FIGURE 5. OVERVIEW OF THE PERMITTING PROCESS
28
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application to EPA. The type of information required in the
permit application is listed in Table 4. EPA reviews the
application and, if it is complete, prepares a draft permit. The
public is notified that an ocean incineration application has been
received. EPA schedules briefings and a public hearing to discuss
the proposed permit, and accepts comments on the draft permit for
a period of 45 days from the date of announcement. The Agency is
required to review and respond to all comments received. Based on
the public comments, EPA can either deny the permit application or
prepare a final permit. Either decision may be appealed by the
applicant or any individual or group participating in the
hearings. If EPA approves the permit application and a final
permit is prepared, the permittee is required to conduct a trial
burn that includes a series of tests to evaluate the incinerator
system on the vessel proposed in the permit. The results of the
trial burn, which are made available for public review, are
evaluated by EPA to determine whether the incineration system is
>
in regulatory compliance. If the trial burn results are
acceptable, a letter of approval to initiate ocean incineration
operations is issued to the applicant.
As part of the development of the ocean incineration permit
program, EPA is preparing guidance documents for the permitting
process, for developing contingency plans, and for conducting
trial burns. These documents are intended to inform potential
permit applicants, EPA personnel involved in the ocean
incineration program, and the public of the specific procedures
and steps involved in the permit process. The Agency is also
developing a model to be used as a screening tool to limit the
concentrations of chemicals in the wastes proposed in the permit
so that environmental impact of incineration emissions can be
prevented.
The permitting guidance manual for preparing or evaluating permit
applications will describe the entire permitting process,
29
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TABLE 4. APPLICATION REQUIREMENTS FOR AN OCEAN
INCINERATION PERMIT
• Proof of financial responsibility.
® Description and certification of the vessel.
• Description of the incinerator devices.
® Description of monitoring and recording devices.
e Description of the waste loading, storage and
analysis procedures.
@ Trial burn plan.
• Proposed incineration site(s), port(s), and
incineration schedule; rate of incineration.
® Contingency plan.
• Endangered or threatened species assessment.
• Certification of consistency with the approved state
Coastal Zone Management Plan.
e Description of coordination activities with other
federal, state, and local agencies.
» Permit processing fee.
e Description of the waste.
• Assessment of the need for a permit.
30
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including the types of permits available for ocean incineration,
preparation of a permit application, procedures for processing the
application (including public review and comment), criteria for
evaluating the application, and preparation of the permit. The
manual is primarily intended to guide the permit applicant and the
permit writer, but will also inform the general public of the
overall permitting process.
As part of the permit application package, an ocean incineration
contingency plan is required. This plan must detail the
procedures and steps to be taken by the permittee in the event of
an accident or other unplanned event. EPA is developing a
contingency plan guidance manual to assist the permit applicant in
the preparation of a contingency plan and to help the public
understand the level of preparedness that EPA requires of anyone
seeking an ocean incineration permit. The contingency plan
guidance manual will specify general topics that the applicant
should address in the contingency plan, including recommended
waste release and marine casualty response procedures, detailed
precautions, and port-specific contingency measures (Table 5).
Before granting an operating permit, EPA will require a permittee
to perform a trial burn. The objective of a trial burn is for the
permittee to demonstrate that the incinerators are capable of
operating at the conditions specified by the regulations and can
achieve the required destruction efficiencies (DE). The trial
burns also give EPA the opportunity to evaluate the sampling and
measuring devices that will be used during operational burns to
monitor compliance with permit conditions. The trial burn
guidance manual will detail the methods to be used during these
burns. It will fully describe the performance standards that must
be met by the incinerators and will provide Standard Operating
Procedures (SOPs) for the measurements that must be made.
31
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TABLE 5. TOPICS TO BE INCLUDED IN AN OCEAN INCINERATION
CQfrlTINGENCY PLAN
I. Contingency Plan Administration
Applicant Responsibility
Federal Involvement
II. Incident Response Plan
Response Network
Waste Release Response Procedures
Cargo Loading
Vessel Enroute to Pilot Disembarkation
Point
Vessel Enroute to Incineration Site
Vessel at the Incineration Site
III. Precautionary Measures
Personnel Preparedness
Vessel Preparedness
Waste-Specific Precautions
Appendix: Port-Specific Information
Land-Based Transport
Cargo Transfer Facility
Vessel Loading Plan
In-Port Waste Release Response Resources
In-Port Marine Casualty Plans
Evacuation Plans
Transit Between Port and Pilot Disembarkation
Point
32
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EPA must ensure that the emissions from incinerating at sea do not
cause any adverse environmental effects. To this end, EPA has
developed the INSEA model as a screening tool to be used in the
permitting process. The model will be used to estimate the
maximum concentrations of chemicals allowed in the waste (and
specified in the permit) such that the resulting mixture of
incinerator emissions and seawater does not exceed EPA's water
quality criteria for a specified set of contaminants. Water
quality criteria are maximum concentrations of chemicals permitted
in water such that adverse environmental effects (e.g., growth
depression or bioaccumulation) do not result. These criteria are
developed through rigorous long- and short-term exposure toxicity
(including bioaccumulation) tests using sensitive aquatic
organisms.
The two-part INSEA model considers the primary atmospheric and
oceanic processes that disperse the incinerator emissions into the
environment. INSEA can be used to simulate a "worst case"
incineration operation over a period of days to weeks, and up to a
distance of 50 kilometers from the incinerator. For the purposes
of screening, it is assumed that, if water quality criteria can be
met with the proposed wastes under a "worst case" scenario, the
criteria will be met under any other conditions. The model was
developed to be run with both speed and ease on an IBM or
compatible personal computer, and would be run by EPA and
prospective applicants to specify in the permit the maximum
concentrations of chemicals allowed in the final blended waste
mixture.
PERMIT AND SITE MANAGEMENT
In designating sites and issuing permits, EPA believes that
criteria developed both for site designation and for permitting
will adequately protect the marine environment. Monitoring
33
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programs are designed to confirm this presumption. EPA's
monitoring activities include assessment of whether permit
conditions are being met and whether incineration of hazardous
wastes at sea impacts the marine environment. The Agency intends
to conduct both compliance monitoring and site monitoring
programs. Results of monitoring efforts may be used in making
decisions about 1) continuing or discontinuing site designation,
2) maintaining, changing, or revoking a permit, or 3) maintaining
or changing the monitoring program itself.
Compliance monitoring will verify that the permittee is operating
in accordance with the conditions specified by the permit.
Compliance monitoring will include monitoring of waste
constituents and emissions through chemical analyses of wastes,
continuous monitoring of incinerator operating conditions,
surveillance by an EPA shiprider, and monitoring of a trial burn.
EPA is developing an information management system specifically to
facilitate compliance monitoring activities. This system will
primarily be used to rapidly evaluate permit information and to
assess compliance with permits. Types of data that may be entered
into the information management system include vessel position and
course, incinerator performance measurements, incinerator
monitoring data, and waste characterization data.
Although EPA believes the criteria in the regulation are
sufficiently stringent to protect the environment, EPA must
periodically monitor the environment near incineration sites to
ensure that emissions constituents are not causing adverse effects
or that there are no long-term changes at the site that might
suggest altering the use of a site. EPA intends to monitor sites
most closely during early years of use; the data collected during
early monitoring would be used to more clearly define long-term
34
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monitoring needs. Site monitoring would include
Determining atmospheric transport of emissions under
various meteorological conditions.
Measuring concentrations of emissions constituents in
the atmosphere downwind from the incinerators and the
subsequent concentrations in the air-sea interface,
surface-dwelling organisms (neuston), and surface
water at the site of plume touchdown on the sea.
Recording the occurrence in the site area of
endangered or threatened species or other important
species that could be affected by incinerator
operations.
Characterizing the site's oceanographic conditions
that could disperse or condense emission-related
substances in the ocean.
A monitoring plan for the North Atlantic Incineration Site (NAIS)
has already been prepared and will serve as a model for developing
monitoring plans for other sites. The NAIS monitoring plan
includes a description of the regulatory framework for monitoring
ocean incineration operations; a summary of the incineration
process, including a general description of probable waste
characteristics; a description of the incineration site; and the
plan for monitoring the site for impacts. This information is
used for predicting possible impacts of incineration. These
predictions provide the basis for monitoring activities.
The monitoring plans will address predictions of possible impact
through formulation of specific testable hypotheses concerning
waste characteristics, disposal operations, nearfield fate and
short-term effects, and farfield fate and long-term effects. The
hypotheses are tested according to a tiered approach (Zeller and
Wastler, 1986) designed to ensure that all data collected in a
monitoring program follow a rational progression and that the most
likely areas of impact are monitored most closely. The monitoring
plans will also describe the statistical basis for specific
35
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measurements and provide information on recommended sampling and
analytical methods.
Collection of baseline data at a site is important both in
developing and implementing the monitoring plans. Baseline
information *has been instrumental in determining the parameters
that should be monitored. Ultimately, baseline data resulting
from the surveys conducted in support of site designation
(discussed above under Site Designation) will be compared to data
collected during research or operational burns to determine
whether impacts occur and to assist in updating EPA's assessment
of risk for ocean incineration.
36
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CHAPTER 4
EPA'S RESEARCH STRATEGY
BACKGROUND OF THE RESEARCH STRATEGY
EPA has been involved in ocean incineration research for more than
10 years. Beginning in 1974, four research burns were conducted
under EPA permits to gather scientific information about ocean
incineration of hazardous wastes and to evaluate ocean
incineration as an alternative to land-based treatment and
disposal.
In 1984, EPA developed a draft comprehensive strategy to obtain
information necessary for effective development and implementation
of an ocean incineration operational program. The draft strategy
was circulated and was the focus of a public meeting held ip
Washington, DC, on 13 November 1984. Based on comments received,
the final strategy was prepared in 1985 (EPA, 1985). The major
focus for the research strategy was the development of a rational,
scientifically defensible methodology for an updated environmental
risk assessment of ocean incineration of hazardous waste.
Given the scientific concerns regarding previous research, EPA
based the research strategy on the most important issues that
needed to be addressed to develop an adequate risk assessment for
ocean incineration.
RISK ASSESSMENT FOR OCEAN INCINERATION
There is a significant difference between a risk assessment based
on a specific hazardous compound and a risk assessment based on
hazardous waste emissions from an incinerator. The latter
assessment is much more complex because incinerator emissions are
37
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difficult to sample at high temperatures; they may exist in two
phases (emissions gas and scrubber water) and they are not well
characterized. The emitted material is potentially a complex
mixture of extremely small amounts of the original waste material
(principal organic hazardous constituents), partially destroyed
original waste material (products of incomplete combustion), and
new compounds formed during the incineration process or during
cooling of the emitted gases in air or in scrubber waters. As
described in more detail below.- the Agency is conducting risk
assessment of hazardous waste incinerator emissions.
Even if emissions could be completely characterized and
quantified, toxicity and environmental exposure issues must still
be addressed. Incinerator emissions are complex materials with
potentially additive, synergistic, or negative toxicological
implications. Defining the composition of the emissions and
developing a toxicity database for each constituent of the
emissions would require extensive chemical analysis and toxicity
testing. EPA proposes, instead, to chemically analyze the
emissions to identify the most abundant constituents in the
mixture and to base the risk assessment upon the toxicity of the
mixture itself.
EPA has evaluated the existing information regarding the
substances emitted from ocean and land-based incinerators, and
believes that the risks from well-run ocean incinerators are
small. EPA plans, however, to use future research activities to
more accurately assess these risks. Risk assessments for a series
of exposure conditions are proposed to be conducted at several
stages of the research strategy. This approach permits assessing
risks of incinerator vessel operations at some prescribed level of
efficiency. The risk assessment process is tiered to examine
acute and chronic effects of a range of spatial and temporal
environmental concentrations of emissions.
38
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Data and assessments of potential risks of incineration, generated
from implementation of the research strategy, are expected to be
used in preparing ocean incineration permits and in management of
incineration sites.
RESEARCH STRATEGY STUDY AREAS
The Research Strategy developed by EPA in 1985 is divided into
three major areas, each having specific objectives. These
research areas are briefly described in Table 6. Specific
activities in each study area are discussed in the remainder of
this chapter. This discussion does not include related research
being conducted by EPA as part of its land-based incineration
program.
STUDY AREA 1:
DEVELOPMENT OF METHODS FOR EMISSIONS SAMPLING
AND TOXICITY TESTING
Development of methods to sample incinerator emissions for
chemical characterization and to introduce the emissions into
seawater for conducting toxicity tests are the primary objectives
of Study Area 1. Toxicity testing is required to determine the
potential toxicity of emissions constituents to the marine
environment and to assess the risks of ocean incineration.
It was proposed that the preliminary toxicity tests use emissions
from a land-based hazardous waste incinerator to field-test the
methods and to characterize potential toxic effects of ocean
incinerator emissions. Tests were also required to determine the
need for stack traversal while collecting high-temperature, low-
particulate emissions for chemical characterization or for
toxicity testing.
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TABLE 6. STUDY AREAS OF EPA'S RESEARCH STRATEGY
Study Area 1 - Development of Methods for Emissions
Sampling and Toxicity Testing
The research in Study Area 1 involves development of
methods for sampling incinerator emissions for chemical
characterization and toxicity testing. To test the
toxicity of the emissions to aquatic organisms, it was
necessary to develop a system for removing a known
volume of emissions from an incinerator stack and
incorporating the emissions into seawater. The
emissions-in-seawater mixture could subsequently be
subjected to toxicity tests to determine its toxicity to
various standard laboratory aquatic test organisms.
Study Area 2 - Monitoring Ocean Incineration Operations
(Conduct of a Research Burn)
Study Area 2 of the Research Strategy involves
determining the potential environmental impacts of
incinerator emissions during actual ocean incineration
operations. Many of the methods developed under Study
Area 1 will be field-tested during a research burn or
burns.
Study Area 3 - Additional Research
Studies to evaluate potential impacts of ocean
incineration activities on the marine environment or on
public health and welfare are included in Study Area 3.
Areas for additional research include detailed studies
of transport and fate of emissions in the air and water
column, toxicity studies using organisms indigenous to
burn sites, air-sea interface studies, and long-range
chronic studies of emission toxicity and
bioaccumulation.
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Obtaining the desired toxicity data required development of
methods to trap the emissions and introduce them into aquatic
laboratory systems at a known dilution of emissions in seawater.
Several methods for sampling emissions for chemical
characterization were adopted from those used by EPA to sample
emissions from land-based hazardous waste incinerators. These
methods would be used to to determine concentrations of volatile
and semi-volatile organic substances such as PCBs, dioxins, and
other potential constituents of the emissions.
Development of a method to sample incinerator emissions for use in
toxicity tests has posed a special challenge. In addition to
taking representative samples of incinerator emissions, those
samples must be introduced into seawater without otherwise
contaminating the water or rendering it toxic to marine organisms.
EPA considered several designs for such a sampler, and selected a
modification of an existing EPA emissions sampling system. This
>
modified system has become known as the Marine Biological
Assessment Sampling (MIBAS) system. The MIBAS system (Figure 6)
consists of several chambers containing seawater (sampling train)
through which the emissions gas from the incinerator is passed.
Materials in the emissions gas are trapped in the seawater, which
is then removed and used in the toxicity tests.
The MIBAS system is being evaluated through a series of tests
conducted burning just fuel oil at the Battelle Multifuel Furnace
in Columbus, Ohio, and incinerating hazardous materials at the EPA
Combustion Research Facility in Jefferson, Arkansas. These tests
have included experiments in which known chemicals are introduced
into the MIBAS system during sampling, and the seawater in the
MIBAS is subsequently analyzed to determine how much of the added
chemicals were collected in the system. These procedures are
known as spike-recovery tests.
With the use of the MIBAS system, large volumes of emissions gas
41
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5 FEET FLEXIBLE
HEATED TEFLON LINE
TC
_ TC
ACID TRAP/COLOR
INDICATOR
OPEN HOLE
OR PRONGED
TC
TC
o
VACUUM
PUMP
DRY GAS
METER
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are passed through the system, and hydrogen chloride, as well as
other chemical components of the gas, is trapped in the sampling
train. The volume of emissions gas drawn through the sampler is
much higher than the volume of emissions that would contact the
volume of water in the MIBAS system in the environment. Because
gas sample volumes are so large compared to the volume of seawater
in the MIBAS, the seawater-plus-emissions sample obtained from the
MIBAS system has a very high salinity and a very low pH. It was,
therefore, necessary to develop procedures for adjusting the
salinity and pH of MIBAS samples before using them for toxicity
tests. Under actual at-sea conditions, the emissions gas would be
diluted in the atmosphere prior to settling on the sea surface.
The ocean's buffering capacity and the rapid dilution of the
emissions in seawater are expected to mediate any impacts from
these water quality parameters. Failure to adjust salinity and pH
in the MIBAS seawater samples would make it impossible to assess
the toxicity of the emissions to the marine environment.
For toxicity tests, the emissions-in-seawater medium is used to
dose standard test animals that have documented tolerances to a
wide range of toxic substances. The MIBAS system is designed to
collect an emissions sample so highly concentrated that subsequent
dilution with seawater for dose-response toxicity tests results in
realistic exposure levels, and can generate a dose-response curve
showing emissions concentrations that cause effects and lower
concentrations that do not cause effects.
When the methods for obtaining this medium were developed, EPA
selected a series of five toxicity tests that have been evaluated
simultaneously with the evaluations of the MIBAS system. These
tests include a sea urchin fertilization test that can be
conducted in approximately four hours and thus makes an effective
screening tool; and four short-term, chronic tests that last from
two to seven days. The chronic tests use a fish (Menidia
beryllina) , a crustacean (Mysidopsis bahia), an alga (Champia
43
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parvula), and a worm (Dinophilus gyrociliatus), and include tests
for growth, reproduction and survival. The toxicity tests have
been evaluated in a mobile laboratory designed so that the tests
may be run at sea during a research burn.
EPA intends to use the MIBAS and associated toxicity tests to
conduct ocean incineration risk assessments using emissions from
at-sea incinerators. EPA plans to use the MIBAS sampler and the
five toxicity tests to determine how various concentrations of
emissions in seawater affect various species of organisms. These
concentrations would then be compared to levels observed in the
environment during actual burns at sea and levels predicted in the
environment using models such as the INSEA model described
previously or the MESOSEA model described under Study Area 2.
A prediction of hazard is made by comparing the predicted
environmental exposure concentration of the emissions (exposure
assessment) and the concentration producing biological effects in
laboratory studies (effects assessment). When properly
synthesized, these data provide an estimate of the probability
(risk) of unacceptably altering the aquatic environment as the
result of the ocean incineration process.
STUDY AREA 2;
MONITORING OCEAN INCINERATION
(CONDUCT OF A RESEARCH BURN)
Study Area 2 of EPA's Research Strategy involves determining the
potential environmental impacts of ocean incineration operations
at sea. Ultimately, this area will include testing the methods
developed under Study Area 1 in a research burn program. To date,
EPA's activities in Area 2 involve testing of methods and
preparation of documentation that will be employed in the research
burn program. Many of these issues, which would have been studied
44
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in the proposed 1985 research burn (EPA, 1985), are included in
plans for future testing after the final ocean incineration
regulations are issued.
The research burn field program was primarily designed to respond
to EPA concerns and to issues raised by the public and scientific
community on the variability of the waste destruction efficiency
during normal operation of the incinerator; on characterization of
the incinerator emissions; and on the fate of emissions leaving
the stack. An additional component of the field program was
characterization of a control area of the research burn region for
background environmental conditions.
During the research burn, the emissions sampling and bioassay
methods developed under Study Area 1 will be tested during actual
incineration operations at sea. Emission samples for chemical
analysis and environmental samples for plume fate and transport
model verification will also be collected during the fie^d
program. Activities that will be carried out during research burn
programs are described in Table 7 and include the following:
• Monitoring the air and waste feed to the incinerators
to determine what is entering the incinerator.
• Sampling emissions to determine what substances
(particularly those that impact the environment) are
exiting the incinerator.
• Conducting toxicity tests using emissions as test
media for subsequent risk analysis.
• Measuring meteorological parameters to determine
probable emissions transport.
• Tracking the emissions plume to test models and to
determine the location and touchdown of the plume.
• Measuring physical oceanographic parameters to
determine the distribution of emissions-related
substances following contact with the ocean.
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• Sampling air and precipitation for emissions
components.
• Sampling the water column to determine whether
emissions-related substances can be detected in
surface water.
• Determining the abundance, distribution, and behavior
of endangered species to ensure that they are not
impacted by incineration activities.
Many of the sampling and research activities listed above have
already been developed under Study Area 1 of the Research Strategy
and have been tested at EPA's Combustion Research Facility in
Arkansas. EPA is currently preparing detailed plans for
conducting the above activities at sea.
Plans for the research burn program include various sampling
schemes (Table 8) depending upon the behavior of the emissions
plume (contact with the sea surface or dispersion in the
atmosphere) and the weather during the burn. A separate scheme is
being developed for monitoring an incinerator ship equipped with
scrubbers.
Sampling Activities
Because of the very low concentrations of organic compounds and
trace metals in open ocean waters, large volumes of seawater must
be collected and extracted to quantify chemical components above
the detection limits of analytical instrumentation. A high-volume
water sampler, which effectively collects large volumes of
seawater from a depth of 10-20 centimeters for chemical analysis,
was designed and field tested. For analysis of organic chemicals,
the high-volume sampler pumps water directly into an on-board
extraction system. The extraction tank (Figure 7) is a 1000-liter
stainless steel cylindrical tank equipped with mixing shafts and
propeller blades that mix a solvent into the seawater to carry out
multiple solvent extractions. The solvent removes organic
46
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TABLE 7. DETAILED SAMPLING ACTIVITIES AND MEASUREMENTS TO BE
MADE DURING AT-SEA BURNS
• Determining composition and density of
specific chemical constituents in the
waste feed.
e Monitoring air and waste feed rates, and
incinerator flame and wall temperatures.
• Measuring emissions velocity across the
diameter of stack.
• Measuring hydrochloric acid, carbon
dioxide, carbon monoxide, oxygen, and
other gases in the stack emissions.
• Determining principal organic hazardous
constituents (POHCs), products of
incomplete combustion (PICs), and trace
metals in stack emissions.
• Determining the toxicity of stack
emissions to five animal species.
• Determining organic constituents and trace
metals in ballast water, tank washings,
and incineration residues.
• Atmospheric profiling of near-surface
(10-meter height) and airborne
meteorological parameters through the
lower atmosphere.
• Vertical profiling of meteorological
parameters through the lower atmosphere.
• Tracer tracking of emissions plume.
• Determining surface water current
direction and velocity.
• Vertical profiling of current direction
and velocity in surface waters.
• Using meteorological and physical
oceanographic data with the plume tracking
results to test the MESOSEA and INSEA
models.
• Determining POHCs, PICs, total organic
halogens (TOX), trace metals, toxicity
(using sea urchin embryos),
microbiological densities, and water
quality parameters (pH, alkalinity) in
microlayer samples.
• Determining POHCs, PICs, TOX, trace
metals, water quality parameters (pH,
alkalinity, dissolved oxygen, total
suspended solids, salinity, temperature),
and biochemical parameters (chlorophyll a,
phaeophytin, adenosine triphosphate) in
emissions-impacted surface water samples.
• Determining the taxonomy of and specific
organic contaminants in neuston.
• Determining specific organic constituents
in the emissions plume downwind of the
incinerator stack.
• Determining specific organic constituents,
trace metals, and water quality parameters
in rain and mist.
• Determining the abundance, distribution,
and behavior of endangered species of
cetaceans, marine turtles, and seabirds in
the area of the incineration site.
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TABLE 8. VARIATION IN SAMPLING ACTIVITIES FOR THREE SCENARIOS OF
EMISSIONS PLUME FATE AND METEOROLOGICAL CONDITIONS
Plume Touchdown Situation
• Atmospheric vertical profiling
• Air sampling and plume tracking by research vessel
• Air sampling and plume tracking by airplane
• Drifter/drogue deployment and tracking of touchdown
area
• Water column sampling (including microlayer, surface
water, and neuston) in touchdown area
Non-Touchdown Situation
• Atmospheric vertical profiling
• Air sampling and plume tracking by airplane
• Long-term drifter/drogue tracking of emissions-impacted
water
• Water column sampling downcurrent of touchdown area
tracked by drifters
• Control site sampling
Rain Situation
• Precipitation sampling
• Atmospheric vertical profiling
• Air sampling by research vessel
• Drifter/drogue deployment and tracking of water mass
impacted by emissions-scavenged precipitation
• Water column sampling of rain/emissions-impacted water
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Top View
1" hole
2 1/2" tube
for solvent
addition
2 1/2" tube
for solvent
addition
'••-Sight Glass
Drain Hole
Side View
FIGURE 7. THE 1000-LITER STAINLESS STEEL EXTRACTION TANK ALLOWS
ONBOARD PROCESSING OF HIGH-VOLUME WATER SAMPLES
49
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materials from the seawater, is collected from the tank, and is
stored for later chemical analysis. This on-board extraction
process effectively reduces the volume of each sample from 1000
liters to 10 liters with minimal risk of contamination.
Sulfur hexafluoride (SFg) nas been tested at sea as a tracer for
the emissions plume. A plume tracer helps locate and track the
plume for emissions sampling activities. SFg is an artificial
tracer that can be detected at extremely low concentrations. It
is injected at a known rate into the incinerator emissons effluent
near the stack to aid in positioning personnel for downwind
sampling tasks and to provide information on plume dispersion
during transport. Air samples are collected and analyzed by
injection into a portable SFg gas chromatograph.
High-volume samplers to collect ambient air samples for detection
of emissions-related organic substances have also been tested and
successfully employed in the field. These samplers collect up to
250 cubic meters of air to determine concentrations of
semivolatile (e.g., PCBs, dioxins) and volatile organic compounds.
The surface microlayer, the ultra-thin layer (upper 50 microns) of
hydrophobic material on the sea surface, can contain high
concentrations of both living organisms and contaminants. The
microlayer is the first contact point for incinerator emissions
entering the ocean and, therefore, the most likely place to detect
emissions-related substances. For this reason, environmental
monitoring programs for the ocean incineration program include
chemical and microbiological examination of this microenvironment.
Collection of the sea-surface microlayer is possible with the use
of a specially designed Teflon-coated rotating drum sampler
(Figure 8). The 45- by 61-centimeter drum is constructed of
aluminum and is mounted in a Teflon-coated aluminum tubing frame
supported in the water by two aluminum floats.
50
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Lifting Bridle
Towing Bridle
y
Drum Driving
Belt
Collection Tray
Tow Direction
Pontoon
FIGURE 8. THE ROTATING-DRUM MICROLAYER SAMPLER IS DRIVEN BY WATER TURBINES
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The activities conducted under Study Area 2 in preparation for
research burns and future monitoring studies have resulted in the
preparation of more than 50 written Standard Operating Procedures
(SOPs) for the ocean incineration program. These SOPs (Table 9)
detail the objectives, preparation, conduct, and quality control
procedures for each protocol associated with the program. The
research activities have also resulted in ongoing preparation of
plans for the conduct of research burns. In conjunction with
these activities, EPA is also developing a model, MESOSEA, which
is expected to be used for predicting atmospheric plume trajectory
and dispersion. MESOSEA will be used to locate areas for
environmental sampling during research or monitoring surveys-
Data generated during research burns will be used to assess
potential risks of incineration, to refine the monitoring plans
being developed for potential ocean incineration sites, and to
update our understanding of nearfield fate and short-term impacts
of incinerator emissions. These data may be used in developing
guidelines to modify incineration permit conditions to ensure that
environmental impacts from ocean incineration of hazardous wastes
do not occur. By combining the results of the emissions bioassay
dose-response tests (developed under Study Area 1) and the plume
transport and exposure models (developed under Study Area 2), EPA
can estimate potential impacts of the emissions on the environment
(risk assessment). Analysis of field samples collected from
control and plume areas during the research burn will serve to
define and quantify potential impacts to the marine environment in
the plume touchdown area.
STUDY AREA 3;
ADDITIONAL RESEARCH
The objective of Study Area 3 of the Research Strategy is to
conduct additional tests to determine potential impacts of ocean
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Table 9. STANDARD OPERATING PROCEDURES PREPARED FOR EPA'S OCEAN
INCINERATION PROGRAM
EPA
SOP Clipboard Measurements
No. and Sample Collection
4-19 Acquiring Temperature/Depth Profiles of
the Water Column with an Expendable
Bathythermogaph (XBT)
4-20 The Calibration and Operation of the
Water Column Rosette/CTD Sampling
System
4-23 Shipboard Determination of Turbidity of
Seawater Using the Hach Model 2100
Turbidometer
4-22 Shipboard Determination of Salinity in
Seawater with the Beckman Model RS-7C
Induction Salinometer
4-48 Shipboard Determination of Alkalinity
in Water Samples
4-21 Shipboard Determination of pH Using the
Beckman Model 4500 pH Meter
4-26 Shipboard Measurement of Dissolved
Oxygen in Seawater Using the YSI Model
57 Dissolved Oxygen Meter
4-34 Operation of the High-Volume Air
Sampler
4-40 Operation of the Hydrogen Chloride
Analyzer
4-36 Measurement of Vertical Velocity
Profiles in Open Oceans
4-37 Deployment and Tracking Near-Surface
Current Drifters/Drogues
4-38 Meteorological Measurements Associated
with Incineration-at-Sea Activities
4-41 Precipitation Collection for Organic
Analysis
4-51 Collection of Air Samples for Volatile
Organic Compound Analysis
EPA
SOP Shipboard Measurements
No. and Sample CoLLection
4-17 Collection of Water Samples for Organic
Analysis with the High-Volume Water
Sampler
4-18 High-Volume Extraction of Selected
Organic Compounds from Seawater
4-50 Collection of Trace Metal Water Samples
with Modified High-Volume Water Sampler
4-35 The Collection and At-Sea Processing of
Neuston Samples
4-39 SF, Tracer Release
0
4-42 SF, Sample Collection and Analysis
Using a
Portable Tracer Gas Monitor
4-43 Operation of the SF6 Continuous
Analyzer
4-25 Shipboard Preparation and Laboratory
Analysis of Seawater Samples for
Adenosine Triphosphate
4-24 Shipboard Extraction and Analysis of
Chlorophyll a and Phaeophytin in
Seawater Using the Turner Model 1000
Field Fluorometer
4-29 Collecting Samples of Aquatic Surface
Microlayers
4-30 Sampling and Analysis of Microorganisms
in Aquatic Surface Microlayer
TcKJcity Te
3-01 Preparation and Assembly of the MIBAS
Sampling
Train
3-04 Cleaning MTBAS Glassware Between Tests
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Table 9. (CONTINUED) STANDARD OPERATING PROCEDURES PREPARED FOR
EPA'S OCEAN INCINERATION PROGRAM
EPA
SOP
No. ToKJclty Testing
3-02 Collecting Emissions Samples using the
MIBAS Sampling Train
3-4)3 Recovery of MESAS Samples Prior to
Water Quality Adjustment and Toxicity
Testing
3-05 Water Quality Adjustment of Aqueous
Emission Samples
3-08 Conducting Sea Urchin Sperm Cell
Toxicity Tests
4-33 Conducting an Acute Static Toxicity
Test with Sea Urchin Embryos
3-07 Conducting Static-Renewal Rapid Chronic
Toxicity Tests with Mysidopsis bahia
3-08 Conducting Seven-Day Growth/Survival
(Static Renewal) Studies with the
Inland Silverside, Menidia beryllina
3-09 Estimating Chronic Reproduction Effects
with Champia
3-10 Life-Cycle Toxicity Tests with
Dinophilus gryociliatus
laboratory Methods
4-04 Preparation of High-Volume Air Samples
for Organic Analyses
4-52 Analysis of Volatile Organic Compounds
in Air
4-08 Analytical Scans of Environmental
Sample Extracts Using Gas
Chromatography-Electron Capture
Detector (GC-ECD)
4-09 Analytical Scans of Environmental
Sample Extracts Using Gas
Chromatography-Hall Electrolytic
Conductivity Detector (GC-HECD)
EPA
SOP
No. laboratory Methods
4-10 Analytical Scans of Environmental
Sample Extracts Using Gas Chroma-
tography/Mass Spectrometry (GC/MS)
4-14 Determination of Biomass of Neuston
Samples
4-13 Identification and Enumeration of
Neuston
4-05 Preparation of Neuston Samples for
Organic Analysis
4-01 Preparation of Surface Water Samples
for Organic Analyses
4-16 Preparation of Sample Extracts for
Analysis of PCDD and PCDF
4-06 Preparation of Sample Extracts for
Analytical Scans
4-44 Preparation of Labeled Organic
Solutions for Spiking Water, Air, and
Biota Samples
4-28 Extraction and Analysis of Total
Organic Halogens (TOX) in Seawater with
Gas Chromatography-Hall Electrolytic
Conductivity Detection
4-11 Analysis of Marine Samples for PCB
4-12 Analysis of Marine Samples for PCDD and
PCDF
4-31 Analysis of Aquatic Surface Microlayer
Samples for Metals
4-02 Preparation of Microlayer Samples for
Organic Analyses
4-27 Determination of Total Suspended Solids
in Seawater
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incineration on the marine environment or on public health and
welfare. These tests are to be conducted either in parallel with
research burn efforts or after the completion of the research
burns. Activities suggested to be conducted under Area 3
included, for example, laboratory testing of the transport of
emissions constituents; sampling incinerator emissions in front of
and behind a scrubber to determine scrubber efficiency; toxicity
testing with other species or other methods of exposure? and
applying the methods developed under Study Area 2 to research on
other incinerator vessel technologies. Because some of the
activities proposed under Area 3 have been conducted in
conjunction with on-land tests and in preparation for at-sea
research burns, many of the research activities of Study Areas 1,
2 and 3 have merged.
For example, EPA's research has included an evaluation of the
sea-surface microlayer as a test medium for toxicity studies.
Conducted in conjunction with the toxicity tests that use
incinerator emissions samples (from the MIBAS system) as test
media, the microlayer toxicity tests may afford a more complete
assessment of acute and chronic effects of ocean incineration
emissions. Additional research activities include an assessment
of the feasibility of using endemic species for evaluating the
toxicity of incinerator emissions.
Plans for alternative types of incinerator vessels, either
horizontal incinerators with scrubbers or vertical incinerators
that release emissions directly into the atmosphere, have also
been incorporated into the plans for the research burns. An
example of such additional studies is the sampling and analysis of
emissions in front of and behind a land-based incinerator scrubber
system to determine the efficiency of the scrubber in removing
organic constituents of the emissions.
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CURRENT STATUS OF THE RESEARCH PROGRAM
EPA has been implementing the ocean incineration research strategy
since it was adopted in 1985. The results of research for Study
Areas 1, 2, and 3 will be used in developing, refining, or
implementing an ocean incineration operating program. Results of
the research program will be made available to the public when
final reports have been prepared and reviewed by the scientific
community.
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GLOSSARY
ACUTE EFFECTS — Effects (usually measured as mortality) produced
on an organism by a single, short-term exposure to a substance
or condition.
AIR-SEA INTERFACE — The point or plane at which the ocean surface
meets the atmosphere.
ATMOSPHERIC DISPERSION MODEL — A computer model that simulates
reality for the purpose of predicting the dissemination of
emissions into the surrounding body of air.
BASELINE SURVEY — A program conducted to describe environmental
conditions of an area or site prior to influence of ocean
incineration operations.
BIOACCUMULATION — The uptake of substances other than food (e.g.,
environmental pollutants) leading to elevated concentrations of
those substances within animal tissues.
BUFFERING CAPACITY — The ability of a substance (e.g., seawater)
to maintain a specific acidity, alkalinity, or neutrality -
CHRONIC EFFECTS — Effects on organisms from long-term, usually
low-level exposure.
CHRONIC TOXICITY TESTS — Tests designed to measure sublethal
effects (such as growth depression, inhibition of reproduction,
or bioaccumulation) of a substance or condition on an organism.
COMBUSTION EFFICIENCY — A measure of the operational efficiency
of an incinerator on the waste stream and/or auxiliary fuel (if
used) at a given time. Combustion efficiency (CE), expressed
as a percent, is calculated by comparing the concentration of
carbon monoxide (CO) in the incinerator emissions to the
concentration of carbon dioxide (C02) in the incinerator
emissions:
(C07) - (CO)
CE = £ x 100%
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DESIGNATED OCEAN INCINERATION SITE — A location that has been
specifically identified by EPA and listed in the Federal
Register as an area in which high-temperature oxidation
techniques can be used to destroy hazardous wastes without
endangering human health or the environment.
DESTRUCTION EFFICIENCY — A measure of the destruction of an
individual organic constituent in a waste mixture during
incineration. Destruction efficiency ( DE ) , expressed as a
percent, is calculated by the following formula:
x 100
Wi"
Where :
W. = mass feed rate of one constituent in the waste stream
in feeding into the incinerator
W mass emission rate of the same constituent present in
ou the exhaust emission prior to release to the atmosphere.
DOSE-RESPONSE TOXICITY TEST — A test to correlate the amount of
an agent to which an organism is exposed with the resultant
deleterious effect on the organism.
EFFECTS ASSESSMENT — Laboratory studies performed to determine
the concentration of emissions that produce biological
consequences .
EMISSIONS — Substances (gaseous or particulate) discharged into
the atmosphere from an incinerator.
EMISSIONS TRANSPORT MODEL — A computer model used to simulate
reality for the purpose of predicting the direction in which
substances discharged from incinerator stacks will travel.
ENDEMIC SPECIES — Biological organisms native to a particular
location .
ENVIRONMENTAL IMPACT STATEMENT (EIS) — A document required under
the National Environmental Policy Act for major projects or
legislative proposals. ElSs are used in making decisions about
the positive and negative effects of the undertaking.
ENVIRONMENTAL IMPACT STATEMENT SUPPLEMENT — A document updating
an existing Environmental Impact Statement.
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ENVIRONMENTAL PERFORMANCE STANDARD — A numerical value for the
highest concentration of a residual chemical mixture that can
be safely emitted from the stack of an ocean incinerator
without unreasonably degrading or endangering human health,
welfare, or amenities; or the marine environment, ecological
systems or economic potentialities; or recreational or
commercial shipping or boating; or recreational uses of beaches
or shorelines. Ocean incineration activities will only be
permitted if the operator can demonstrate that the performance
standards will not be exceeded.
FARFIELD — At or beyond the boundaries of the incineration site.
FEDERAL REGISTER — A daily publication of the U.S. Government
that chronicles the regulatory activities of Congress and other
government agencies.
GAS CHROMATOGRAPH — An analytical instrument used to
differentially separate a complex mixture of vaporized
chemicals. Separation of the mixture into individual
components is based on selective adsorption of the gaseous
mixture on a solid material contained in a column.
HALOGENS -- The nonmetallic elements that exist in the free state
as diatomic molecules. Halogens include fluorine, chlorine,
bromine, and iodine, and are often incorporated into organic
molecules (organohalogens).
HYDROGEN CHLORIDE — The anhydrous form of hydrochloric acid; the
primary product resulting from the incineration of
organochlorines.
INCINERATION PLUME — The cloud of emissions that is ejected from
the incinerator into the atmosphere.
INCINERATOR PERFORMANCE STANDARDS — A set of conditions that must
be met by an ocean incineration permittee to assure that the
required efficiency of destruction is being met and that the
incineration process will not cause adverse environmental
effects.
INSEA MODEL -- A computer model that uses atmospheric and oceanic
data to predict the dispersion of incinerator emissions into
the environment. Modeled results will be used to determine
environmental performance standards.
MARINE INCINERATION BIOLOGICAL ASSESSMENT SAMPLER (MIBAS) — An
all-glass device for obtaining samples of the incineration
gases from an incinerator for use in toxicity tests with marine
organisms. The MIBAS draws a sample of the stack gases from
the incinerator stack through containers filled with seawater.
The seawater is then used as the medium for toxicity tests.
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MESOSEA MODEL — A computer model that uses atmospheric and
meteorological data to predict the trajectory and dispersion of
the incineration plume.
MICROLAYER — The interface between the atmosphere and the surface
of the ocean, usually considered to be the upper 0.05
millimeters (50 micrometers) of the water column.
MONITORING PROGRAM — Periodic or continuing observations of an
area to detect changes from baseline conditions.
NEARFIELD — Within the boundaries of the incineration site.
NEUSTON — The organisms generally restricted to the upper 0.5
meters of the water column.
ORGANOCHLORINE WASTE — Any waste composed predominantly of carbon
and hydrogen and containing covalently bound chlorine atoms.
ORGANOHALOGEN WASTE — Any waste composed predominantly of carbon
and hydrogen and containing covalently bound halogen atoms.
Organochlorine wastes are also organohalogen wastes.
PLUME TRACER — A compound (e.g., sulfur hexafluoride) that can be
added to incinerator emissions to aid in tracking and locating
the emissions plume.
POLYCHLORINATED BIPHENYLS (PCBs) — A group of industrial
organochlorine compounds used primarily in the manufacture of
electronics components. PCBs were outlawed in the U.S. because
of their extreme toxicity and persistence in the environment.
PRINCIPAL ORGANIC HAZARDOUS CONSTITUENTS (POHCs) — Major
hazardous organic constituents of the waste stream on which
tests of incinerator destruction efficiency are conducted.
PRODUCTS OF INCOMPLETE COMBUSTION (PICs) — New organic compounds
formed from the original waste constituents during
incineration. PICs are produced by the processes of heat-
induced molecular fragmentation (pyrolysis) and rearrangement
(pyrosynthesis). Pyrolysis and pyrosynthesis are favored by a
fuel-rich flame (low oxygen-to-fuel ratio).
PUBLIC HEARING — An open meeting at which any interested person
may express concerns, present opinions and ideas, and obtain
information concerning a specific issue.
RANGE FINDING — Toxicity testing that uses a broad spectrum of
concentrations of a substance to determine the narrower limits
that should be used for definitive testing.
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RISK ASSESSMENT — The evaluation of predicted hazard from
incinerator emissions that provides an estimate of the
probability of unacceptably altering the aquatic environment as
the result of the incineration process.
SCRUBBER — An air pollution control device attached to the stack
of an incinerator and designed to remove a particular fraction
or fractions of materials from the stack gases. Scrubbers
proposed for incinerators on some ocean incineration vessels
would use a stream of seawater to physically wash the
incinerator exhaust stream. The scrubber would lower the
temperature of the exhaust gases, neutralize acids in the
effluent, and remove some particulate materials.
SCRUBBER WATER — The seawater that has been used to wash the
incinerator exhaust stream and which is discharged from the
scrubber directly into the ocean.
SPIKE-RECOVERY TESTS — Procedures in which known quantities of
known chemicals are introduced into a test system (e.g.,
MIBAS) and the test medium is subsequently analyzed to
determine how much of the added chemicals was collected in and
recovered from the system.
STANDARD OPERATING PROCEDURE (SOP) — A formal written document
that gives detailed instructions for an operation, analysis, o'r
action that could directly or indirectly influence data quality
or integrity. SOPs must be sufficiently complete and detailed
to ensure that data of known quality and integrity are
generated during a particular operation.
TRIAL BURN -- A test of the operational performance of the
incinerator with a particular waste type, performed prior to
operational burns. The purpose of the trial burn is to
demonstrate that the incinerator is able to attain the
incinerator performance standards and that incinerator
emissions meet environmental performance standards. Trial
burns allow EPA to evaluate and approve the sampling and
measuring devices that will monitor the operational burns and
to determine the operating requirements to be specified in an
operating permit.
VOLATILE ORGANIC COMPOUNDS — Carbon-containing compounds that
vaporize readily at relatively low temperatures.
WASTE FEED — The mixture of hazardous constituents supplied to
the incinerator.
WASTE STREAM -- A general term used to denote the waste material
output of an area, location or facility.
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WATER QUALITY CRITERIA — Elements of federal or state water
quality standards, expressed as constituent concentrations,
levels, or narrative statements, representing a quality of
water that supports a particular use. These criteria generally
describe maximum concentrations of chemicals permitted in water
such that adverse environmental effects do not result.
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LIST OF ABBREVIATIONS
CE — Combustion Efficiency
CERCLA — Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (Superfund)
CFR — Code of Federal Regulations
CTD — Conductivity-Temperature-Depth
DE — Destruction Efficiency
DEIS — Draft Environmental Impact Statement
DEISS — Draft Environmental Impact Statement Supplement
DOI — U.S. Department of the Interior
DOT — U.S. Department of Transportation
EIS -- Environmental Impact Statement
EPA — U.S. Environmental Protection Agency
FEIS — Final Environmental Impact Statement
FEISS — Final Environmental Impact Statement Supplement
FR -- Federal Register
FWS — U.S. Fish and Wildlife Service
CIS — Gulf of Mexico Incineration Site
LDC — London Dumping Convention
MIBAS — Marine Incineration Biological Assessment Sampler
MMS — Minerals Management Service, U.S. Department of the
Interior
MM5 — EPA Modified Method 5
MPRSA — Marine Protection, Research and Sanctuaries Act
NAIS — North Atlantic Incineration Site
NMFS -- National Marine Fisheries Service, National Oceanic and
Atmospheric Administration, U.S. Department of Commerce
NOAA -- National Oceanic and Atmospheric Administration, U.S.
Department of Commerce
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NOI — Notice of Intent
OMEP — Office of Marine and Estuarine Protection, U.S.
Environmental Protection Agency
OPPE — Office of Policy, Planning and Evaluation, U.S.
Environmental Protection Agency
PCBs — Polychlorinated Biphenyls
PDEIS — Preliminary Draft Environmental Impact Statement
PIC — Product of Incomplete Combustion
POHC — Principal Organic Hazardous Constituent
ppb — Parts per Billion
ppm -- Parts per Million
RCRA — Resource, Conservation and Recovery Act of 1976
SAB — Science Advisory Board, U.S. Environmental Protection
Agency
SCIS — Southeast Coast Incineration Site
SFC — Sulfur Hexafluoride
b
SOP — Standard Operating Procedure
TOX — Total Organic Halogens
TSCA — Toxic Substances Control Act of 1976
USC — U.S. Code
USCG — U.S. Coast Guard
VOST — Volatile Organic Sampling Train
WCIS — West Coast Incineration Site
XBT — Expendable Bathythermograph
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BIBLIOGRAPHY
Ackerman, D.G., H.J. Fisher, R.J. Johnson, et al. 1978. At-Sea
Incineration of Herbicide Orange Onboard the M/T Vulcanus.
EPA-600/2-78-186, prepared for the U.S. Environmental
Protection Agency, Industrial Environmental Research
Laboratory, Office of Research and Development, Washington,
DC.
Ackerman, D.G., J.F. McGaughey, and D.E. Wagoner. 1983. At-Sea
Incineration of PCB-Containing Wastes Onboard the M/T
Vulcanus. EPA 600/7-83-024, prepared for the U.S.
Environmental Protection Agency, Research Triangle Park, NC.
Ackerman, D.G., R.G. Beimer, and J.F. McGaughey. 1983.
Incineration of Volatile Organic Compounds by the M/T
Vulcanus II. Prepared for Chemical Waste Management, Inc.,
Oak Brook, IL.
Badley, J.H., A. Tefler, and E.M. Fredricks. 1975. At-Sea
Incineration of Shell Chemical Organic Chloride Waste, Stack
Monitoring Aboard the M/T Vulcanus. Technical Progress Report
BRC-CORP 13-75-F, Shell Development, Bellair Research Center,
Houston, TX.
Battelle Columbus Laboratories, Ocean Sciences and Technology
Department. 1987. Analytical Results of Samples Collected
During the 1985 North Atlantic Incineration Site Survey.
Final Report prepared for the U.S. Environmental Protection
Agency, Office of Marine and Estuarine Protection,
Washington, DC.
Battelle Columbus Laboratories, Ocean Sciences and Technology
Department. 1987. Analytical Results of Samples Collected
During the 1985 Southeast Coast Area Survey. Final Report
prepared for the U.S. Environmental Protection Agency, Office
of Marine and Estuarine Protection, Washington, DC.
Battelle Columbus Laboratories, Ocean Sciences and Technology
Department. 1986. Monitoring Plan for Incineration-at-Sea
Sites. Draft Report prepared for the U.S. Environmental
Protection Agency, Office of Marine and Estuarine Protection,
Washington, DC.
Battelle Columbus Laboratories, Ocean Sciences and Technology
Department. 1985. Toxicological and Emissions Sampling
Methodology Development Related to Ocean Incineration of
Hazardous Wastes: Study Area 1, Level 1 Studies. Draft
Final Report prepared for the U.S. Environmental Protection
Agency, Criteria and Standards Division, Office of Water
Regulations and Standards, Washington, DC.
65
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Battelle Pacific Northwest Laboratories. 1986. User's Manual for
incineration-at-Sea (INSEA) Model. Draft Final Report
prepared for the U.S. Environmental Protection Agency,
Criteria and Standards Division, Washington, DC.
Clausen, J.F., H.J. Fisher, R.J. Johnson, E.L. Moon, C.C. Shih,
R.F. Tobias, and C.A. Zee. 1977. At-Sea Incineration of
Organochlorine Wastes Onboard the M/T Vulcanus.
EPA-600/2-77-196, prepared for the U.S. Environmental
Protection Agency, Industrial Environmental Research
Laboratory, Office of Research and Development,
Washington, DC.
ECO, Inc. 1986. Small Tanker Spill Rates and Port
Characteristics. Prepared for the U.S. Environmental
Protection Agency, Office of Marine and Estuarine Protection,
Washington, DC.
Guttman, M. et al. 1983. Ambient Air Monitoring of the August
1982 M/T VULCANUS PCB Incineration at the Gulf of Mexico
Designated Site. Prepared for the U.S. Environmental
Protection Agency, Office of Marine and Estuarine Protection,
Washington, DC.
Metzger, J.F. and D.G. Ackerman. 1983. A Summary of Events,
Communications, and Technical Data Related to the At-Sea
Incineration of PCB-Containing Wastes Onboard the M/T
Vulcanus, 20 December, 1981 - 4 January, 1982. Prepared for
the U.S. Environmental Protection Agency, Washington, DC.
U.S. Congress, Office of Technology Assessment* 1986. Ocean
Incineration: Its Role in Managing Hazardous Wastes.
OTA-0-313, U.S. Government Printing Office, Washington, DC.
U.S. Department of State and U.S. Environmental Protection Agency.
1979. Final Environmental Impact Statement for Incineration
of Wastes at Sea, Under the 1972 Ocean Dumping Convention.
Washington, DC.
U.S. Environmental Protection Agency, 1983. Hearing Officer's
Report on the Tentative Determination to Issue Special Ocean
Incineration Permits and a Research Permit to Chemical Waste
Management, Inc. and Ocean Combustion Services, BV, April 23,
1983.
U.S. Environmental Protection Agency. 1981. Environmental Impact
Statement for the North Atlantic Incineration Site. EPA
440/5-82-025, Washington, DC.
U.S. Environmental Protection Agency. 1976. Environmental Impact
Statement for the Designation of a Site in the Gulf of Mexico
for Incineration of Chemical Wastes, Washington, DC.
66
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U.S. Environmental Protection Agency, Criteria and Standards
Division, Marine Protection Branch. 1984. The North
Atlantic Incineration Site 1983 Preliminary Baseline Cruise.
Draft Final Report, Washington, DC.
U.S. Environmental Protection Agency, Criteria and Standards
Division, Office of Water Regulation and Standards, Office of
Water. -1983. Background Document on the Tentative
Determination to Issue Incineration-at-Sea Permits HQ 83-001
(Special), HQ 83-002 (Special), HQ 83-003 (Research)
Washington, DC.
U.S. Environmental Protection Agency, Office of Policy, Planning
and Evaluation. 1985. Assessment of Incineration as a
Treatment Method for Liquid Organic Hazardous Wastes:
Summary and Conclusions, Washington, DC.
U.S. Environmental Protection Agency, Office of Water. 1985.
Incineration-at-Sea Research Strategy, Washington, DC.
U.S. Environmental Protection Agency, Office of Water Programs.
1984. Decision on Ocean Incineration Permits, Washington,
DC.
U.S. Environmental Protection Agency, Science Advisory Board.
1985. Report on the Incineration of Liquid Hazardous Wastes
by the Environmental Effects, Transport and Fate Committee,
April, 1985, Washington, DC.
Wastler. T.A., C.K. Offutt, C.K. Fitzsimmons, and P. Des Rosiers.
1975. Disposal of Organochlorine Wastes by Incineration At
Sea. EPA-430/9-75-014, Report prepared for the U.S.
Environmental Protection Agency, Office of Water and
Hazardous Materials, Division of Oil and Special Materials
Control, Washington, DC.
Zeller, R.W. and T.A. Wastler. 1986. Tiered Ocean Disposal
Monitoring Will Minimize Data Requirements. Proceedings,
Oceans '86, Volume 3, Monitoring Strategies Symposium,
Washington, DC.
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