United States Office of the Administrator April 1985
Environmental Protection Science Advisory Board A-101
Agency 401 M Street, SW
Washington, DC 20460
*S'EPA Report on the Incineration
of Liquid Hazardous Wastes
by the
Environmental Effects,
Transport and Fate
Committee,
Science Advisory Board
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UNTED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
April 5, 1985
Honorable Lee M. Thomas
Administrator
U. S. Environmental Protection Agency THt A'o'v",'","<,?•!^
401 M Street, S. W.
Washington, D. C. 20460
Dear Mr. Thomas:
The Science Advisory Board has completed its review of a number of
scientific issues related to the assessment of the public health and
environmental impacts associated with the incineration of hazardous
wastes on land and at sea. The Board's review was carried out by its
Environmental Effects, Transport and Fate Committee. The charge to the
Committee included six major issues, including 1) the transfer of wastes;
2) combustion and incineration processes; 3) stack and plume sampling;
4) environmental transport and fate processes; 5) human health and
environmental effects assessment; and 6) research needs.
The Committee has engaged in an extensive dialogue on these issues
over the past year, with EPA staff, officials' of Federal'and state agencies
and members of the public. Each of these groups contributed scientific
data to the Committee's inquiry and provided a valuable perspective on
the interpretation of such data.
The Committee believes that hazardous waste incineration is a very
important part of the Agency's strategy to properly manage and dispose
of hazardous chemicals. It further believes that by acquiring additional
information on a number of technical issues the Agency will enhance its
capability to not only defend its incineration programs but also to enable
the public to realize the benefits of this waste disposal technology.
This will become especially true if, as anticipated, the program expands
in future years.
The report concludes that the operation of both land and sea based
hazardous waste incinerators has produced no adverse consequences to the
public health or the environment. Considerable uncertainty surrounds the
data that lead to this conclusion, however, and the Committee recommends
a number of steps the Agency ought to undertake to reduce this uncertainty.
These include fuller assessment of fugitive emissions from all phases of
waste management and disposal processes; better characterization of
incinerator emissions and effluents so that the identity and quantity of
chemicals released into the environment can be estimated; determination
of emissions under all incinerator operating conditions; and development
of a coordinated research strategy involving both laboratory toxicity
studies and field assessments to address both the possibility of short-
terra and long-terra public health and environmental effects.
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We believe the report should prove useful to you, other Agency
officials and the general public in promoting a wider understanding of the
scientific data needs and the public policy choices that have to be
addressed in improving the nation's ability to properly dispose of
hazardous wastes. The Board appreciates the opportunity to present its
views and stands ready to provide any additional assistance that is
needed by the Agency. We request that the Agency respond to our report.
Sincerely,
Lf Hartung, Chairman
Environnental Effects, Transoort
and Fate Committee
Science Advisory Board
.Norton Nelson, Chairman
Executive Committee
Science Advisory Board
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REPORT
on the
INCINERATION OF LIQUID HAZARDOUS WASTES
by the
ENVIRONMENTAL EFFECTS, TRANSPORT AND FATE COMMITTEE
SCIENCE ADVISORY BOARD
U. S. ENVIRONMENTAL PROTECTION AGENCY
April 1985
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NOTICE
The following Report has been written as part of the activities of
the Environmental Protection Agency's Congressionally established Science
Advisory Board. The Board consists of independent scientists and engineers
who provide scientific advice to the EPA Administrator on a number of
issues before the Agency. The Board provides a balanced, independent and
expert assessment of the scientific issues it reviews. The contents of
this report do not necessarily represent the views and policies of the
Environmental Protection Agency.
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-ii-
TABLE OF CONTENTS
Preface ill
Synopsis 1
Chapter 1 Introduct ion 6
Chapter 2 Problems Encountered in Storage, Transfers and
Transportation of Liquid Hazardous Wastes 8
Chapter 3 Problems Associated with Hazardous Wastes
Incineration Processes 15
Chapter 4 Monitoring of Stack Emissions 23
Chapter 5 Atmospheric Transport and Fate 25
Chapter 6 Transport and Fate of Incineration Products in Aquatic
Sys terns 32
Chapter 7 Transport and Fate of Incineration Products in
Terrestrial Systems 38
Chapter 8 Effects on Aquatic Systems 41
Chapter 9 Effects on Terrestrial Systems 44
References 48
Appendix I List of Environmental Effects, Transport and Fate
Committee Members and Consultants
Appendix II Charge to the Committee
Appendix III List of Source Materials Consulted
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iii
PREFACE
This is the final report of the Environmental Effects, Transport and
Fate Committee (EETFC) of the EPA's Science Advisory Board (SAB) on the
review of scientific issues related to the public health and environmental
impacts associated with the incineration of liquid hazardous wastes at
sea and on land. In this review the EETFC was assisted by representatives
of the SAB's Environmental Engineering Committee. Committee members
carried out their review at the direction of the Executive Committee of
the SAB to which they report.
On October 13, 1983, Administrator William D. Ruckelshaus requested
that the Executive Committee assist the Agency in its scientific assessment
of incineration at sea. On April 12, 1984 Deputy Administrator Alvin L.
Aim requested that the Executive Committee expand the scope of the review
to include an examination of public health and environmental impacts
related to land incineration of hazardous wastes and to make a generic
comparison of the major scientific issues between incineration at sea and
on land. The Executive Committee accepted both of these requests and
referred them to the Environmental Effects, Transport and Fate Committee.
(For a list of Members and Consultants serving on the Committee, see
Appendix I.)
The EETFC began its review in February 1984 with a series of briefings
from Agency staff, subsequently made site visits to EPA laboratories and
regional offices, commercially operating incinerators and incinerator ships
under construction, and received public input at its open meetings. The
Committee is acutely aware of the need to provide information and advice
to EPA policy makers to meet the exigencies of near-term decisions and to
accumulate knowledge over the long-term to provide an improved understanding
of the relationship between emissions and health and environmental effects
from incineration activities. The Committee's recommendations are aimed
at strengthening the Agency's capability to meet both of these objectives.
A. Charge to the Committee
After discussions with EPA staff, the Committee identified six areas
to evaluate the incineration of hazardous wastes at sea and on land. The
Committee set out to determine whether the Agency had considered and
interpreted the appropriate data for each area in a scientifically adequate
manner. These areas include the following:
1) Transfer of wastes.
What are the various handling, loading, transportation, and routing
problems? What potentials exist for collisions, explosions, and spills?
Should the Agency develop worst-case scenarios to evaluate the potential
impacts of accidential discharges?
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iv
2) Combustion and Incineration Processes.
Is the efficiency of destruction properly addressed? Are the
quantitative and qualitative characteristics of the combustion products
released into the environment appropriately evaluated?
3) Stack and Plume Sampling.
What specialized sampling protocols are needed to adequately
charaterize representative emissions from the stacks exhaust and plume?
4) Environmental Transport and Fate Processes.
How should known and modeled atmospheric and oceanic circulations at
the burn sites be considered? Are potential food web influences adequately
assessed?
5) Biological Effects.
Do data on incineration efficiency, composition of emission products,
and environmental transport and fate processes provide an adequate basis
for evaluating biological effects? Have other issues, such as the
bioavailability and toxicity of emitted compounds, been adequately
addressed?
6) Research Needs.'
What key scientific issues should the Agency address in its incineration
research strategy?
B. Key Assumptions Guiding the Committee's Review
Because of the complexity of the scientific issues under review and
the time constraints for carrying out the review, the Committee has
restricted and simplified the scope of its work in a number of important
ways. The following considerations which guided the Committee's work
reflect these limitations:
o The Committee concurs with the Agency's position that the
destruction of wastes is an important activity and that, in many instances,
such destruction is preferable to their storage. The Committee considers
landfilling and deep well injection of toxic wastes, for example, to
constitute forms of storage and not toxic waste disposal.
o The Committee approached the scientific comparison of hazardous
waste incineration issues at sea and on land by examining the entire path
of liquid hazardous chemicals from the point of generation through trans-
portation, incineration, and ultimate transport, fate and effects of
residues. The Committee is, however, aware of many alternative methods
of waste disposal, including other types of thermal degradation, chemical
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detoxification, biological degradation, and solidification, which were
not within the scope of its review.
o The Committee did not undertake any economic analyses of the
various waste management and disposal processes, nor did it conduct any,
comparative cost-benefit analyses.
o The Committee recognizes that EPA's efforts to implement
programs to incinerate liquid hazardous wastes are in various stages of
development. For example, regulations to define the conditions for
incinerating such wastes on land have already been promulgated under the
authority of the Resource Conservation and Recovery Act (RCRA) and under
the Toxic Substances Control Act (TSCA) for Polychlorinated BIphenyls
(PCBs). The Agency, however, is currently taking public comment on its
proposed regulations to govern the Incineration of liquid hazardous
wastes at sea under the auspices of the Marine Protection Research and
Sanctuaries Act.
o The Committee is aware that its comments concerning at sea
incineration have implications for regulations already in place for the
burning of wastes on land. There are always areas in which understanding
can be improved, and any scientific review of a technology or procedure
runs the risk of seeming to be negative by virtue of asking new questions.
In view of this situation, the Committee would like to make several
observations:
1) Incineration is a valuable and potentially safe means for
disposing of hazardous chemicals, and EPA has made progress in developing
an appropriate regulatory strategy. However, this Committee has been
asked to address the shortcomings and needs of this program, and its
comments should be considered in the light of what probably is, in fact,
a valuable technology.
2) The Committee's comments, both positive and negative, should be
interpreted by the Agency and the public as a desire to strengthen already
existing incineration programs rather than to discontinue what is already
in place.
3) The state of scientific knowledge for many of the issues reviewed
by the Committee is such that although definitive answers to many policy
questions are not possible, the Agency needs to make policy and permitting
decisions in the face of uncertainties, given the limitations of
alternative technologies and facilities. It is also the EPA's responsi-
bility, however, to address and to reduce the levels of uncertainty
associated with this activity by carrying out and/or sponsoring the
needed research. The Committee also encourages the Agency to use the
permitting process in such a way as to increase the knowledge base on
monitoring and possibly other issues.
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vi
4) The Committee has limited its review to the assessment of
human health and environmental risks from the incineration of liquid
hazardous wastes. It is the Agency's responsibility to choose among
existing technological alternatives to minimize such risks in an
acceptable manner. For example, the Agency needs to decide whether
land based and ocean based incineration regulations should be equally
stringent.
5) The Committee believes that many of the conclusions and
recommendations derived from this review are also applicable to
other combustion processes, such as those which occur in fossil fuel
power plants and home heating units.
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SYNOPSIS
This synopsis contains the major conclusions and recommendations
developed by the Environmental Effects, Transport and Fate Committee
which apply to liquid hazardous waste incineration both at sea and on
land. The Committe generated many other conclusions and recommendations,
but these appear only in the body of the report because they deal with
more specific rather than generic aspects of the incineration of hazardous
wastes. The reader is cautioned against drawing his/her conclusions
after reading only the synopsis. Because of the complexity of the issues,
the report should be read in its entirety.
The ordering of the conclusions and recommendations follows the path
of the waste and its daughter products from generator to final receptor.
This ordering of recommendations does not imply a prioritization but
rather reflects the path of the Committee's analytical thought processes.
The Committee believes that its most important conclusions and recom-
mendations relate to the ultimate impacts incineration practices have on
human health and the environment (see conclusions and recommendations 11
and 12).
Major Conclusions and Recommendations
Conclusion 1:
Nearly all types of hazardous waste management and disposal involve
the collection, temporary storage, pumping and transport of the wastes.
Accidental spills and fugitive emissions* can occur during any of these
processes. Based upon presently available data, the Committee cannot
assess the full magnitude of this problem, but it acknowledges a possibility
that fugitive emissions and accidental spills may release as much or more
toxic material to the environment than the direct emissions from incomplete
waste incineration.
RECOMMENDATION 1:
THE AGENCY SHOULD ASSESS THE ENVIRONMENTAL RELEASES OF FUGITIVE
EMISSIONS OF CHEMICAL WASTES AND WASTE-DERIVED MATERIALS FROM ALL PHASES
OF EACH WASTE MANAGEMENT AND DISPOSAL PROCESS, INCLUDING THOSE NOT
ADDRESSED IN THIS REPORT. INSOFAR AS INCINERATION INVOLVES UNIQUE
EXPOSURES OR EVENTS, THESE SHOULD BE SPECIFIED.
Conclusion 2:
The Agency adopted the concept of destruction efficiency to monitor
whether or not incineration destroyed liquid hazardous wastes. This
approach emphasizes the identification of several preselected compounds
in the waste and does not fully address either partial oxidation or
chemical recombinations which may create new toxic compounds. To date,
only a very small portion of the compounds found in emissions from
incinerators has been identified qualitatively or quantitatively.
As a consequence, the concept of destruction efficiency (while valid for
comparing the relative operating performance of incinerators) does not
completely address the problem of what is emitted from the incinerator
stack and does not, therefore, constitute a reliable basis for developing
exposure assessments.
Fugitive emissions in this report refer to instances of uncontrolled
releases from valves, inadvertent minor ruptures in containers or
pipes, and small spills that occur during waste storage or transfer
operations. The Committee does not apply this term to major accidents,
collisions, explosions or spills.
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RECOMMENDATION 2:
THE EMISSIONS AND EFFLUENTS OF HAZARDOUS WASTE INCINERATORS NEED TO
BE ANALYZED IN SUCH A WAY THAT THE IDENTITY AND QUANTITY OF THE CHEMICALS
RELEASED INTO THE ENVIRONMENT, INCLUDING THEIR PHYSICAL FORM, CAN BE
ESTIMATED. THE AGENCY SHOULD DEVELOP A REVISED DESTRUCTION EFFICIENCY
PARADIGM SO THAT ITS ASSESSMENT OF INCINERATION PERFORMANCE CAN ACCOUNT FOR
THE VARIABILITY OF EMISSIONS AND EFFLUENTS.
Conclusion 3:
Research on the performance of incinerators has occurred only under
optimal burn conditions and sampling has, on occasion, been discontinued
during upset* conditions which take place with unknown frequency. Even
relatively short-tern operation of incinerators in upset conditions can
greatly increase the'total incinerator emitted loadings to the environment.
RECOMMENDATION 3:
THE DETERMINATION OF THE ACTUAL EMISSIONS AND EFFLUENTS OF AN
INCINERATOR SHOULD RESULT FROM AN ASSESSMENT OF THE TOTAL MASS LOADINGS
TO THE ENVIRONMENT UNDER ALL OPERATING CONDITIONS.
Conclusion A:
The existing analytical data for emissions from hazardous waste
incinerators have serious limitations. Among the major problems are
the limited number of chemicals selected for analysis and the fact' that
the analytical methodologies have not been validated1 either for the
conditions of the test or for the complex mixtures which exist in
incinerator emissions. As a result, there exist no relatively complete
or reliable analyses of mass emissions from either land or sea based
incinerators on which to base subsequent estimates of the potential for
environmental exposures. These analytical problems are particularly
difficult to solve for incinerator stacks with very high exit temperatures.
RECOMMENDATION 4:
SAMPLING AND ANALYTICAL METHODOLOGIES SHOULD BE VALIDATED FOR
MEASUREMENTS OF EMISSIONS FROM HAZARDOUS WASTE INCINERATORS.
Conclusion 5:
The identification of optimal locations for incineration facilities
can be greatly improved through the proper use of modeling and simulations.
Through the use of such analytical techniques, the Agency could evaluate
local, site-specific effects on the dispersion and subsequent exposures
from incinerator emissions. Siting evaluations could incorporate temporal
meteorological variations as well as micro-meteorological differences
among sites. Knowledge of site-specific atmospheric dispersion conditions
is also an important aspect of an emergency response modeling system. Real
tii;2 emergency response models should utilize representative ambient
measurements and site-specific source characteristics to provide planners
* As used in this report, the terra upset condition refers to the operation
of an hazardous waste incinerator under less than optimal performance.
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with reliable estimates of transport patterns, dilution, transformation
features and deposition of released materials.
RECOMMENDATION 5:
EPA SHOULD EVALUATE THE DEGREE TO WHICH LOCAL METEOROLOGICAL CONDITIONS
CAN MAXIMIZE ATMOSPHERIC DILUTION TO AVOID EXCESSIVE AMBIENT CONCENTRATIONS
OF INCINERATOR EMISSIONS. THE AGENCY SHOULD ALSO INCLUDE REAL TIME
SITE-SPECIFIC ATMOSPHERIC DISPERSION SIMULATION MODELS AS PART OF COM-
PREHENSIVE EMERGENCY RESPONSE SYSTEMS FOR ALL MAJOR HAZARDOUS WASTE
INCINERATION FACILITIES.
Conclusion 6:
The Committee found that the Agency's evaluations of the transport and
fate of emissions, while appropriately emphasizing the significance of the
dilution of pollutants, have not sufficiently addressed mechanisms in the
environment which would result in the concentration of emission products.
Knowledge of such mechanisms is important to a fuller understanding of
pollutant transport and fate even though the general picture is one of
dilution of the emitted compounds.
The dynamics of atmospheric and aquatic transport processes will largely
influence which segments of the biosphere are impacted by the emissions
from chemical waste incineration. Within these processes, various mechanisms
are likely to prominently influence the concentrations affecting biota.
These mechanisms include: a) phase separation and-chemical distribution
between phases; b) interphase transport at air/water, air/solid, air/biota,
water/solid, water/biota and solid/biota interfaces, and c) photo- and
biochemically stimulated reactions involving the incinerator emissions
after they leave the stack. Surface micro-layers (i.e., sea slicks) may
play significant roles in the concentration of chemicals in some species.
These transport processes are time dependent and exhibit both short-
terra and long-term variability and trends. Such temporal changes should
influence the selection of the most appropriate averaging time for use in
the analysis of potential effects of liquid waste incineration.
It is possible to use simulation models effectively to evaluate many
aspects of the environmental transport and fate of emitted chemicals. However,
such simulations often have significant limitations which were not always
recognized by the Agency. Such limitations can become significant when
several smaller simulation models are linked into large scale simulations.
The results from these large scale simulations are unconvincing, especially
when they are not supported by some field validations.
RECOMMENDATION 6:
THE DYNAMICS OF ENVIRONMENTAL TRANSPORT, INCLUDING CHEMICAL
DISTRIBUTION BETWEEN PHASES, AND INTERPHASE MASS TRANSPORT, SHOULD BE
EVALUATED IN A WAY THAT IS USEFUL FOR EXPOSURE ASSESSMENT.
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THE ROLE OF MICRO-LAYERS IN THE TRANSPORT AND CONCENTRATION OF
EMITTED CHEMICALS INTO THE BIOSPHERE SHOULD BE INCORPORATED INTO THE AGENCY'S
ANALYSIS OF ENVIRONMENTAL IMPACTS OF HAZARDOUS WASTE INCINERATION.
MODELING OF INTERPHASE TRANSPORT AND FATE OF CHEMICALS EMITTED FROM
INCINERATORS SHOULD BE COUPLED WITH SOME FIELD VALIDATIONS.
Conclusion 7:
Exposures of organisms to chemicals originating from liquid hazardous
waste incinerators on land and at sea take place through various pathways
which differ according to transport processes and the habits of the
organisms involved. Such exposure pathways will certainly include
absorption through lungs or gills, skin, and the food web. In addition,
the mobilization of organic compounds from sediments and the entrainraent
of settled particles constitute transport and fate pathways. The exposures
to organisms will vary over time and in the dose attributable to- each
chemical. The relative proportions of chemicals in the mixture to which
organisms are actually exposed is likely to differ from initial incinerator
emissions because of the differential influences of transport, phase
distribution, and chemical reaction dynamics on the individually emitted
chemicals. The accurate determination of such exposures, which need to
take these variables into account, is thus very difficult. The Agency
has made only limited efforts to assess such exposures and these suffer
from various inadequacies because they resulted from either individual
judgments or computer models without adequate laboratory or field
verification.
RECOMMENDATION 7:
THE EVALUATION OF EXPOSURE DURATIONS AND CONCENTRATIONS SHOULD BE
BASED ON BOTH A DETAILED ASSESSMENT OF ENVIRONMENTAL TRANSPORT PROCESSES
AND THE HABITS OF THE EXPOSED ORGANISMS IN BOTH AQUATIC AND TERRESTRIAL
ENVIRONMENTS. THE ROLE OF FOOD WEBS IN EVALUATING EXPOSURES REQUIRES
PARTICULAR ATTENTION.
Conclusion 8:
It is difficult to associate the burning of hazardous wastes with
observed changes in the terrestrial environment because many land based
incinerators are sited in highly industrialized areas which have other
combustion sources emitting similar compounds. EPA, however, has not
made the fullest use of existing modeling techniques to evaluate the
transport, fate and effects of incinerator products in terrestrial systems.
In addition, currently available data for evaluating the environmental
effects of incineration on terrestrial systems are inadequate. Thus,
subsequent Agency exposure assessments to biota and humans are unreliable.
RECOMMENDATION 8:
THE TRANSPORT AND FATE OF INCINERATION PRODUCTS IN TERRESTRIAL
ECOSYSTEMS NEEDS TO BE EVALUATED BY STATE-OF-THE-ART FIELD MONITORING IN
CONJUNCTION WITH IMPROVED SIMULATIONS.
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Conclusion 9:
The toxicities of emissions and effluents from land based and ocean
based incinerators are largely unknown.
RECOMMENDATION 9:
THi TOXICITIES OF REPRESENTATIVE EMISSIONS AND EFFLUENTS FROM .
INCINERATORS SHOULD BE TESTED, AT A MINIMUM, ON SENSITIVE LIFE STAGES OF
REPRESENTATIVE AQUATIC AND TERRESTRIAL VERTEBRATES, INVERTEBRATES, AND
PLANTS OF MAJOR ECOLOGICAL IMPORTANCE.
Conclusion 10:
The assessment of biological effects of incineration products is a
very complex undertaking. The data needed for assessing effects will not
result from an exclusive reliance on laboratory studies, partial field
studies, or complex field studies alone.
RECOMMENDATION 10:
THE ASSESSMENT OF THE POTENTIAL EFFECTS OF INCINERATION PRODUCTS
REQUIRES A COORDINATED APPROACH INVOLVING BOTH LABORATORY TOXICITY STUDIES
AND FIELD ASSESSMENTS. THESE INVESTIGATIONS NEED TO BE COUPLED IN A
RESEARCH STRATEGY WHICH ADDRESSES BOTH SHORT-TERM AND LONG-TERM EFFECTS.
Conclusion 11:
The Committee found no documentation that the operation of liquid
hazardous waste incinerators on land or at sea has produced acute
adverse ecological effects. However, monitoring programs used to date
were few and narrow in scope.
RECOMMENDATION 11:
APPROPRIATELY DESIGNED FIELD STUDIES ARE NEEDED TO PROVIDE ASSURANCE
THAT, THE LONG-TERM OPERATION OF INCINERATORS DOES NOT PRODUCE SIGNIFICANT
ADVERSE EFFECTS TO THE ENVIRONMENT.
Conclusion 12:
The Committee found no documentation that the operation of liquid
hazardous waste incinerators on land or at sea has produced acute adverse
effects to public health. However, monitoring programs used to date were
few and narrow in scope.
Recommendation 12:
EPA should evaluate the possible long-term consequences to human
health of a continuing program of hazardous waste incineration.
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Chapter 1
INTRODUCTION
During the past year the Environmental Effects, Transport and Fate
Committee of the Science Advisory Board has investigated the incineration
of liquid hazardous wastes and the potential human health and environmental
effects of incineration products. The Committee has not carried out a
detailed comparative assessment of potential effects from other combustion
activities, such as the burning of fossil fuels or wood, nor has it
evaluated the incineration of other wastes such as those generated by
hospitals or municipalities. The quantities of materials combusted,
under often partially or uncontrolled conditions, in these other processes
are much greater than those involved in the incineration of liquid
hazardous wastes. The Committee is not aware of comparative data of the
potential risks from these various fuels and wastes prior to combustion
and the consequent potential risks after combustion.
The evaluation of the incineration of liquid hazardous wastes on
land and at sea was a much more complex project than originally anticipated.
A large amount of source materials which dealt with the incineration of
these wastes exists. (The list of source materials consulted is presented
in Appendix III.) The Committee expended considerable effort to collect and
analyze the information that eventually formed the basis of its conclusions
and recommendations. A major difficulty resulted from the fact that the
Agency has no single or even coordinated repository of the relevant
information. Therefore, the Committee had to collect this information
piecemeal from the Office of Water, Office of Solid Waste, Office of Policy,
Planning and Evaluation, Office of Research and Development, EPA Regional
Offices in Dallas and Chicago, transcripts of EPA hearings, and occasionally
from reports originating outside of the Agency. New communications were
still found or volunteered by EPA very late in the development of the
Committee's report. Even though the Committee perused and/or studied in
detail an estimated hundred pounds of materials, it seems unlikely that
it has identified every document relevant to this scientific review. We
believe, however, that the information obtained is representative of the
available scientific data base for understanding the issues discussed in
this report and for supporting the Committee's conclusions and recom-
mendations.
The Agency has studied and managed programs for incinerating
hazardous wastes for some time. The various EPA programs have merit in
that they offered a solution to several hazardous waste problems. The
Agency's approach to hazardous waste incineration in many cases emphasized
the engineering aspects of the problem of destroying wastes. In the course
of the rapid development of incineration technologies, it appears that
inadequate resources were devoted to a holistic and scientific review of
these technologies regarding their environmental impacts and acceptability.
The program depended heavily on concepts of "destruction efficiency," and
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"destruction and removal efficiency," which did not sufficiently account
for the mass of partially destroyed wastes and the nass of compounds
newly synthesized during the combustion process. The existence of
these conditions does not necessarily mean that the incineration of liquid
hazardous wastes is environmentally unacceptable, or that destruction
efficiency is not a logical first step in evaluating incinerator perfor-
mance, but the Committee believes that the existing base of information
is insufficient to make a definitive statement about its environmental
impacts over time.
In summary, the task of adequately evaluating the potential impacts
of emissions from liquid hazardous waste incinerators on land or at sea
is difficult because, while large amounts of source materials exist, they
oftentimes do not address the issues raised during the Committee's review
nor are they equal for the two environments. In addition, exposures
to incineration related pollutants are not directly comparable between
media. Different organisms, for example, exhibit different types of
effects as the result of such exposures. Whether these effects occur
below our detection capability or whether they will prove to be more
significant due to a continuing incineration program cannot be stated with
much certainty at this time. The Agency should consider these factors
within the context of evaluating the full range of waste management and
disposal alternatives which may produce exposures and effects.
Conclusion:
The-programs for incinerating liquid hazardous wastes on land and at
sea, and the destruction of other hazardous wastes by incineration,
present the Agency with risk assessment and risk management issues that
include engineering, environmental monitoring, residue management, and
estimation of the effects on humans and other biota. Because these
issues do not fall neatly within the boundaries of its current and
historical organizational structure, the Agency continues to experience
difficulties both in assessing and managing hazardous waste incineration
programs. In general, the Agency did not assess a number of scientific
issues relating to the incineration of liquid hazardous wastes, and
addressed in this report, until its programs were either in later stages
of development or already implemented.
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Chapter 2
PROBLEMS ENCOUNTERED IN STORAGE, TRANSFERS AND TRANSPORTATION
OF LIQUID HAZARDOUS WASTES
Much of the public concern about storage, transportation and transfers
of toxic chemicals is directed toward the problem of exposures resulting
from uncontrolled leaks and spills. The Committee believes the Agency
should take steps to further minimize the occurrence of leaks and spills
and initiate the preparation of emergency response plans to anticipate
such events. Such plans should address the most probable emergency
situations and require the involvement of trained personnel to execute
the plans, perform periodic drills, and provide for necessary equipment
and other resources. Typically, an emergency plan will need to consider
the probability of chemical spills, fires and explosions, atmospheric
dispersion and exposures of chemicals, and incidences of poisonings and
injuries. These plans should also include the development of population
evacuation procedures.
In connection with the problem of incineration at sea, the Committee
reviewed background literature pertaining to a pending- request for burning
PCB wastes stored at Eraile, Alabama. The plan for transporting PCS wastes
from Smile to Mobile, Alabama for subsequent incineration at sea did not
appear to address all these issues raised in the preceding paragraph. In
addition, it failed to address problems associated with the handling of
wastes at Eraile. The Committee did not have access to a similar plan for
a land based incinerator for timely review. Also, there appears to be
no document which explicitly defines the roles of the EPA and the Department
of Transportation with regard to any overlapping responsibilities for
implementing the Resource Conservation and Recovery Act (RCRA) and the
Hazardous Materials Transport Act (HMTA).
A potential exists for environmental and human exposures as chemicals
are removed from storage containers at the generator site, moved to
transportation vehicles, shipped to the incinerator, and moved about within
the incineration facility. For ocean incineration, where the incinerator
is mobile, an additional chance for exposure exists as the incinerator
ship leaves port and travels to the burn area.
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Exposures can result from three principal events. These include:
1. Fugitive emissions fron tanks and vessels where the toxic
chemicals are stored. These emissions are likely to be higher when
chemical transfers occur between storage containers. Common sources
of fugitive emissions include leaks around pump packings and through
tank ventilation fittings.
2. Spills during transfer to and from tanks and transportation
vessels. Faulty couplings between transfer lines and storage tanks, and
spills during coupling activities are important causes of exposure.
Inattentive supervision of loading operations leading to spills by overflow
can also contribute to fugitive emissions.
3. Spills can occur during transportation because of fire, explosion
or damage to the transport vehicle resulting from a collision.
As with many other aspects of the toxic waste problem, limited
information exists regarding the handling and transportation of these
wastes. A brief summary of the data made available to the Committee is
presented below.
A. Nature and Frequency of Accidental Spills
As required by the 1980 Comprehensive Environmental Response
Compensation and Liability Act (CERCLA) and Section 311' of the Clean
Water Act, EPA compiles information on reportable spills of ten pounds
or more of material. The frequency of spills for PCBs, for example, in
amounts over ten pounds is reported in Table 1^:
Table I
Number of PCB Spills Over Ten Pounds, 1980 - 1983
1980 303
1981 •. 381
1982 689
1983 (8 months) 569
Personal telephone communication. John Riley, Chief of Response,
Standards and Criteria Branch, Emergency Response Division, U. S.
Environmental Protection Agency. July 25, 1984.
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The Committee found no statistics on the quantity of spilled materials.
During transportation, handlers treat all chemicals similar to gasoline and
consider them as hazardous whether or not they are wastes. Federal
regulations require that only flammable liquids be transported in special
U. S. Department of Transportation (DOT) trucks. DOT, however, is not
responsible for the environmental impacts associated with the transportation
and handling of chemicals. The general public also seems not to be aware
of how to report chemical spills.
B. Fugitive Emissions
The Agency should more fully estimate the quantity of fugitive
emissions. Emission factors exist for hydrocarbon liquids and petroleum
refinery equipment applications which have been applied to estimate
emissions in toxic waste handling facilities, but this work needs to be
validated.
At least two types of events related to transportation cause fugitive
emissions. First, the decanting of small containers (and/or handling of
leaking containers) into trucks or rail tankers leads to releases. Second,
fugitive emissions occur when chemicals held in tankers or trucks are
decanted into the storage tank farms at the incinerator site or at dockside
for at sea incineration. Additional emissions from lines, pumps, and
other sources are released in the lines between tank farm storage and
incinerators. Good housekeeping practices and frequent inspections will
reduce these fugitive emissions. The levels of fugitive emissions under
'good housekeeping practices should be estimated and compared with emissions
from incinerator stacks to better attribute the source of human and
environmental exposures.
Technical flaws, however, exist in certain types of incinerators
which lead to higher levels of fugitive emissions. Specifically, rotary
kiln incinerators, because they lack a positive seal between rotary drum
and stationary parts, experience conditions of "puff back" whenever the
kiln receives a sudden high thermal loading of chemicals. These loadings
occur usually when feeding solid chemicals or sludges contained in drums
into the incinerator. Although the kilns normally operate at negative
pressure with respect to the environment, a positive pressure is produced
in these instances which forces some of the chemicals in the kiln through
the annular space between drum and stator into the environment. The
level of emissions resulting from these design characteristics needs
evaluating, and the technical flaws should be eliminated in cases where
EPA determines that unacceptable emission levels exist.
ICF, Inc. has estimated release rates of chemicals from containers
as a fraction of the container capacity and the distance they are
shipped. Table 2 presents these data.
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Table 2
Fractional Losses of Liquid Chemicals from Containers as a Function of
Distance Transported*
ONE WAY DISTANCE
Container Type
Open Metal Container •
14 MILES 25 MILES
8_ i o— 6**___ i •». i o— 5 ___
3 10 —4 __ /, ., 10 —4 _ _
X 1U — — — 4 X J.U
1 x jo-3 i x iQ-3
250 MILES
•3 _ 1 0— 5
J X J.U
9., i o— 4
X I U
3 x ID'3
** To obtain volume of chemicals lost, multiply fractional losses by the
volume of the container.
Table 2 is based upon modeling techniques used by ICF, Inc-^ which
summarize estimates of fractions released for each container type for
three shipment distances. These estimates result from incident, frequency
and release rate data, information on shipment distance, truck volume and
accident data. The Committee wishes to stress the point that Table II
presents only theoretical data on chemical losses. There is a need for
real world data to replace this table.
The Committee believes, as do other observers, that the possibility
exists that, with current management practices, fugitive emissions from
handling at the generator site, as well as transportation losses en route
to the incinerator and in chemical waste storage areas surrounding certain
incinerators may be as great or greater than the toxic chemicals emitted
from the incinerators as a result of incomplete combustion.^
1 ICF, Inc. Report on the RCRA Risk-Cost Analysis Model Phase III,
March 1, 1984.
2 Abkowitze M.A. Eiger and S. Srinivasan. Assessing the Risks and Costs
Associated with Truck Transport of Hazardous Wastes. Draft Final
Report for the Office of Solid Waste of U.S. EPA, Washington, DC 1984.
Systems Applications, Inc. Human Exposure to Atmospheric Concentrations
of Selected Chemicals. Prepared Under EPA Contract 68-02-3066 for the
Office of Air Quality Planning and Standards, 1983.
* The Committee assumes that volatilization accounts for some portion of
these losses.
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C. Handling Procedures
The Federal government has not specified procedures to handle
toxic chemical wastes, nor has it evaluated alternative procedures to
determine which are most effective in minimizing spills and fugitive
emissions4 The Committee was informed that the Department of Defense
decanted and transferred Agent Orange and DDT wastes to the vessel
Vulcanus I under controlled conditions at the Navy Base at Gulfport,
Mississippi,1 but it could not establish what procedures private industry
uses for handling similar wastes.
Issues relating to the incidence of leaks and spills during
transport and storage operations are similar for incineration on land and
at sea until the moment the chemicals are loaded aboard the incinerator
ship. At this point the causes and magnitude of fugitive emissions and
spills may diverge. The complex motions of the ship on an open sea may
increase the problem of stable operation of the onboard incinerator.
The risks of exposure to human and non-human populations are
associated with factors such as-the location of the sources of chemical
wastes, the siting of incinerator facilities, and to the mass and
composition of chemicals to be incinerated. The greater the traffic
between a source and an incinerator, the more likely is the incidence of
spills. The Agency should prepare or direct the preparation of a
statistical profile of spills, based upon historical data, to assess the
probability of various exposure scenarios. This analysis should include
a discussion of optimum transport methods. If shipment sizes are large,
the number of shipments and, consequently, the number of spills are
reduced; however, the amount of .material released to the biosphere
increases in the event of a spill. Theoretical emission factors of
storage plant equipment should be used to estimate fugitive releases; in
addition, actual toxic waste storage facilities should be visited to
determine plant component emission factors. The protocol to determine
the likelihood of exposure resulting from incineration should consider
factors such as human population density at the waste source, along
the route,-and at the site of the incinerator; and fugitive emissions and
potential spills at the source, the waste storage plant, during transit
to the incineration site, and at the incinerator waste storage plant.
These factors, in turn, will be influenced by the total annual
amount of material incinerated in a region and the capacity of transport
vehicles. Available capacity determines the frequency of transport,
which influences the likely number of spills and the mass emitted during
spills. Estimates of the total emissions due to loading and unloading
operations can then be specified. Once this step takes place the
development of an exposure analysis which expresses the summation and
Personal telephone communication. Russel H. Wyer, Director, Hazardous
Site Control Division, Office of Emergency and Remedial Response,
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assessment of all likely emissions and the determination of the human
populations exposed to the emissions can occur. Subsequently, Agency
staff can evaluate the human health and environmental effects believed to
occur from such exposures. The Committee believes that the above procedure
can be formalized in a series of algorithms to conduct a systematic
evaluation of exposure conditions.
Catastrophic accidents, especially near incineration sites where
large quantities of liquid hazardous wastes are stored and burned, require
the ability to mount rapid emergency responses. Since the major route
for the initial movement of hazardous wastes during an accident is likely
to be through the atmosphere, a real-time emergency response simulation
capability should be developed to provide a site-specific analysis of the
atmospheric transport and dispersion of toxic gases and particles released
or evaporated into the air. The simulation model should have the capability
of using local meteorological observations and objectively evaluating the
effects of local topographic features on wind flow, and addressing factors
such as plume rise and initial diffusion. The simulation model should be
readily usable at all major incineration facilities and for all major
transportation routes.
Conclusion:
Nearly all types of hazardous waste management and disposal involve
the collection, temporary storage, pumping and transport of the wastes.
Accidental spills and fugitive emissions can occur during any of these
processes. Based upon presently available data, the Committee cannot
assess the full magnitude of this problem but acknowledges a possibility
that fugitive emissions and spills may release as much or more toxic
material to the environment as the direct emissions from incomplete waste
incineration.
RECOMMENDATION:
THE AGENCY SHOULD ASSESS THE ENVIRONMENTAL RELEASES OF FUGITIVE
EMISSIONS OF CHEMICAL WASTES AND WASTE-DERIVED MATERIALS FROM ALL PHASES
OF EACH WASTE MANAGEMENT AND DISPOSAL-PROCESS, INCLUDING THOSE NOT
ADDRESSED IN THIS REPORT. INSOFAR AS INCINERATION INVOLVES UNIQUE
EXPOSURES OR EVENTS, THESE SHOULD BE SPECIFIED.
Conclusion:
The probabilities of the magnitude and duration of human and non-
human population exposures to hazardous chemicals are influenced by many
factors, such as the occurrence of fugitive emissions, which could be
minimized by changed operational procedures for incineration activities.
Examples of such procedures include the use of traps on storage
containers and low leakage interconnects between storage tanks and
transport vehicles.
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RECOMMENDATION;
EPA SHOULD EVALUATE THE POSSIBILITY OF ADOPTING ALTERNATIVE MANAGERIAL
PROCEDURES THAT COULD REDUCE THE PROBABILITIES OF CHEMICAL SPILLS, THE
MAGNITUDE OF FUGITIVE EMISSIONS, AND THEIR POTENTIAL EFFECTS.
Conclusion;
Based upon the data submitted for its review and observations made
during site visits of operating facilities, the Committee is concerned,
in the absence of qualified on-site inspectors, about the reliability of
operating large-scale land based incinerators, especially for critical
chemical burns (e.g., dioxins, PCBs, dibenzofurans, etc.).
RECOMMENDATION:
THE AGENCY SHOULD SERIOUSLY CONSIDER THE USE OF ON-SITE INSPECTORS
FOR AT LEAST LARGE VOLUME, HIGHLY HAZARDOUS CHEMICAL INCINERATIONS ON
LAND. THIS IDEA IS SIMILAR TO THE SHIP-BOARD RIDER CONCEPT EMPLOYED FOR
INCINERATION AT SEA.
Conclusion:
Responses to accidental releases need to be rapid and objective and
must be initiated with minimal lead, time to avoid or minimize any adverse
health impact on the surrounding populations. A knowledge of site-speciffc
atmospheric transport conditions is an important element for an emergency
response capability at major incineration sites, transfer points, and
along major transportation routes.
RECOMMENDATION:
REAL-TIME, SITE-SPECIFIC ATMOSPHERIC TRANSPORT SIMULATION MODELS
SHOULD BE AN INTEGRAL PART OF PLANNING EMERGENCY RESPONSES FOR INCIN-
ERATION PLANTS, AND TRANSPORT, STORAGE AND TRANSFER FACILITIES.
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Chapter 3
PROBLEMS ASSOCIATED WITH HAZARDOUS WASTES INCINERATION PROCESSES
Incineration of toxic chemicals in the context of this report refers
to high temperature oxidation of liquid hazardous wastes in specially
designed incinerators. Due to tine and resource constraints, the Committee
did not examine in great detail non-oxidative high temperature destruction
processes as a means of thermal destruction of toxic chemicals, although
the high temperature pyrolysis methods may prove to be another promising
chemical waste management approach.
Typically, the incinerators under discussion in this report operate
between 900°C and 1,200°C and are fueled by the toxic chemicals with
auxiliary heating supplied by a fuel oil or natural gas when burning
chemicals with low heating values. Design gas phase residence times in
the high temperature zones range from 0.2 seconds to several seconds.
The completeness of conversion of the incinerated wastes to carbon
dioxide (C02), water (H£0), hydrochloric acid (HC1) and carbon monoxide (CO)
depend upon a complex interplay of chemical and physical variables including
combustion temperatures, gas-phase mixing, waste atomization, and residence
time in the combustion zone. Incinerators discussed in this report
have the capability to burn a wide range of liquid hazardous wastes.
Major attention has focused on the oxidation of halogenateri hydrocarbons
since these substances are relatively difficult to completely incinerate.
The detailed pathways for the combustion reactions have not been defined,
although a more complete understanding of the chemistry would undoubtedly
provide significant information which would prove useful to enhance the
design and operation of incinerators.
The destruction of complex halocarbons occurs in a sequence of
reaction steps. These consist of bond scission creating chemical fragments
which undergo further fragmentation and oxidation. The reaction times for
the individual steps last on the order of milliseconds at typical
incineration temperatures. The availability of hydroxyl (OH) radicals
appears to promote the rate of decomposition of many hazardous compounds.
Because chlorine serves as an OH radical scavenger, chlorocarbons have been
used as fire retardants, thus slowing down oxidation rates. Chemicals
with high chlorine to hydrogen ratios tend to soot readily. In general,
the chlorocarbons must be burned with large quantities of excess air
relative to hydrocarbons to prevent soot formation during combustion.
Ideally, all wastes entering the incinerator will eventually
degrade into their simplest forms, e.g., 002, ^0, HC1. Because none
of these processes is 100% efficient, however, incomplete combustion of
wastes, or the synthesis of new compounds due to recombination of molecular
fragments outside of the combustion zone, complicates considerably the
evaluation of the completeness of combustion.
In the case of the Vulcanus I_ and Vulcanus II incinerator vessels,
operated by Chemical Waste Management, Inc., the residence time of components
in the incinerator is about one second. Tests of land based incinerators
have used residence times of less than 1 second to 6.5 seconds. Gas
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- 16 -
chroraatogram analyses of stack gas samples collected from both land and
sea based incinerators indicate that organic compounds are emitted.
Whether these compounds are unburned portions of the original waste or
the result of chemical recombinations is unknown. In either case, it is
clear that substances other than C02, CO, 1^0 and HC1 exit the incinerator
stack. The degree of destruction achieved is, therefore, imperfect.
Given the difficulties of analyzing all of the stack emissions, a
completely detailed analysis nay be impossible. The Agency chose to
emphasize measurement of the disappearance of selected waste constituents
as a means of testing the performance of incinerators and to use ratios
of CO/C02 as indicators of incinerator performance. The Agency assumed
that, by analyzing the waste to be burned and selecting an abundant
component with a low heat of combustion, thereafter called a Principal
Organic Hazardous Constituent (POHC), and monitoring the stack emissions
for the POHC, one could determine the amount of destruction for other
components with higher heats of combustion. In other words, by monitoring
the feed and emissions for carefully selected compounds during trial burns
and monitoring the levels of 02 and CO in the gas, one could estimate
the destruction efficiency (DE) for the total waste and estimate the
operational performance of the incinertor.
The hypothesis of incinerability based upon relative heats of
combuston is an approximation founded on thennodynaraic assumptions.
EPA has ranked organic compounds according to their heats of combustion
based on the list of such compounds in Appendix VIII 40CFR Part 261.
The Agency has published this list in its "Guidance Manual for Hazardous
Waste Incinerator Permits." The list allows one to track a suitable
POHC as incineration proceeds. The assumptions underlying the general
applicability of the POHC concept for all compounds in the waste stream
will be valid only if the kinetics of combustion and destruction for all
the waste compounds are fast enough for the reactions to take place before
the wastes exit the incinerator. The data collected during research and
trial burns generally support the Agency's position that incinerators
can be built and run under a set of optimal conditions so that the
destruction efficiency for the selected POHCs can meet specified criteria
of 99.99% to 99.9999% DE (for PCB's). Apparently, the Agency developed
this approach as a policy choice to guide the development of regulations
for land based incinerators. However, as long as the definition of
destruction efficiency addresses only the disappearance of the parent
POHC and does not take into account products of partial decomposition or
products newly synthesized in the incineration process, the definition is
limited in its ability to aid in the assessment of total emissions and
subsequent assessments of environmental exposures.
The fact that numerous compounds have appeared in the emissions of
liquid hazardous waste incinerators causes the Committee to question the
assumption that a POHC can be used as a surrogate for the destruction of
all other compounds in the waste. EPA is cognizant of this problem, for
it has recognized an additional group of compounds which may be in the
stack gas. These are called Products of Incomplete Combustion (PICs).
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PICs are defined as compounds on the Appendix VIII list but present in
the feed at levels of <100mg/l. By definition, compounds absent from the
Appendix VIII list can be neither POHCs nor PICs. Therefore, they are
seldom determined. It is possible that the aggregate of all compounds in
the emissions, which are neither categorized as POHCs or as PICs, are
more toxic and pose higher environmental risks than those listed. Data
on the toxicities of combustion products relative to parent compounds are
lacking.
A review of all documents supplied to the Committee that pertained
to past monitoring of incineration events, as well as data requested
from EPA officials, have failed to yield a single "complete" analysis of
the identities and quantities of organics emitted from an incinerator
stack. Even data on PICs in the emissions are extremely scarce. This
view is supported by Trenholm (Trenholm et. al., November 1984) who stated
that "...the data base for PICs from combustion of the complex matrices
of organic constituents which currently are being fed to hazardous waste
incinerators was virtually nonexistent before the Midwest Research Institute
[Gorman, P. and K. P. Ananth, 1984] study".1 In the MRI study, PICs were
defined as compounds in the stack gas samples that appear in Appendix
VIII and under 100 ppm in the feed. Twenty-nine PICs were identified.
Travis et al. 1984, estimate that only 1% to 10% of the total hydrocarbon
emissions were identified in the MRI study. Trenholm et. al. (1984) also
present data on the amount of PICs emitted from the eight incinerators
studied as a percent of the POHC input. This can be presented in the
following equation:
7, =» PIC output (g/min) x 100
POHC input (g/min)
The various results range from 0.00029% to 0.012% with a mean of
0.0031% (Travis et. al., 1984). 'In the Trenholm et. al. (1984)
study, the eight incinerator operators received advance notice of the
visitation of EPA contract personnel so that operations at the facilities
may have been at or near optimal performance. In addition, in one case
when optimal operation was not achieved, the sampling probe was removed
and reinserted after the situation was corrected. Therefore, one could
logically assume that normal emissions often contain more PICs than
reported.
Midwest Research Institute was requested by EPA to characterize more
completely the organic emissions of one of the eight incinerators tested.
Retrospective studies of this type are difficult to do since no quanti-
tative standards were used during the actual chemical analyses; thus, any
subsequent interpretation of the data for such unquantitated chemicals is
Letter from James L. Spigarelli to Timothy Oppelt regarding the
characterization of organic chemical emissions from a selected hazardous
waste incinerator, July 25, 1984.
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somewhat speculative. The data retrieved were from gas chromatography-mass
spectrometry (GC-MS) records. Even so, 53 compounds were observed of
which 29 were POHCs. Total hydrocarbon emissions averaged 1900 ng/1 in
the stack gas; however, only 610 ng/1 were identified by the GC-MS.
Utilizing 1900 ng/1 as the output term in the DE equation, the calculated
DE is approximately 99.99%. This particular incinerator was a large
rotary kiln with afterburner unit followed by water sprays, two packed
beds and an ionizing wet scrubber. Without such an air pollution control
system, it is very likely that the calculated DE would be less than
99.99%.
Based on the data of Trenholm et. al., EPA could approximate the
chemical emissions from incinerators, but they remain only as approxi-
mations because the representativeness of the data is unknown. These
estimates may be used to indicate whether or not to raise concern over
the potential organic emissions from incinerators. In the case of an
hypothetical incinerator ship, the following assumptions could be made:
A. Ship capacity = 4.1 x 10^ metric tons
- 4.1 x 106 kg
B. Maximum permitted PCB concentrations = 35% in waste
C. Average % PIC output of POHC input = 0.0031%
for 8 land based incinerators
D. Maximum % PIC output of POHC input = 0.021%
for 8 land based, incinerators
E. Only 1% of total emitted hydrocarbons detected
These assumptions form the basis for the following calculations:
A. Maximum amount of PCB input per burn
(4.1 x 106 kg/burn) (0.35) - 1.4 x 106 kg/burn
B. PIC output per burn assuming average land based incinerator
performance:
(1.4 x 106 kg/burn) (3.1 x 10~5) - 4.3 x 101 kg/burn
= 43 kg/burn
C. PIC output per burn assuming worst land based incinerator
performance
(1.4 x 106 kg/burn) (1.2 x 10~A) = 1.7 x 102 kg/burn
= 170 kg/burn
D. Unburned hydrocarbon output assuming only 1% of hydrocarbons
detected
1. For average land based incinerator performance
(43 kg/burn) (102) = 4.3 x 103 kg/burn
2. For worst land based incinerator performance
(170 kg/burn) (102) - 1.7 x 104 kg/burn
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The literature supplied to the Committee on the DEs or Destruction
and Removal Efficiencies (DREs) of PCB burns claims 99.99% or 99.9999%
efficiencies throughout. These statements rely solely on POHCs, as
expressed in the following equation:
POHC - POHC
in out
DE = x 100 > 99.99%
POHC
in
If one substitutes the calculated unburned hydrocarbon output (for
the worst noted land based incinerator performance and assuming that only
1% of the unburned hydrocarbons are detected) for the POHC output in the
above formula, perhaps another approximation of the Total Destruction
Efficiency (TDE) may be obtained in the form of:
POHC - total organics
"TDE" = in out x 100
POHC
in
"TDE" = 1.4 x 106 kg - 1.7 x 10A kg x 100
1.4 x 106kg
= 98.8%
Even if other combustible material made up the remaining 65% of the
feed stock and 4.1 x 10^ kg were substituted for the POHC, the modified
destruction efficiency as calculated above would achieve 99.6%. If the
average land based incinerator performance, using data inputs received
from EPA, is assumed with detection of only 1% of the unburned hydrocarbons,
the resulting modified destruction efficiencies for the two POHC estimates
(1.4 x 106 kg and 4.1 x 106 kg) would attain 99.7% and 99.9%, respectively.
In any case, 99.99% destruction efficiency does not appear to be achieved
if compounds other than POHCs in the stack gas are considered.
To further stress the importance of measuring more compounds in the
stack gas than just POHCs and perhaps a few PICs, the Committee would
like to comment on data included in two reports prepared by the Rollins
Corporation. One report^ measured total organics in stack samples (gas
samples, GC-FID, no column) and found an average of 1.1 Ibs/hr. emitted.
PCB incineration test made by Rollins Environmental Services, Deerpark,
November 12-16, 1976. Submitted to Jim Sales, EPA Region 6, Dallas
Texas.
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The other report^ which looked for PCBs, dibenzofurans and EPA priority
chlorinated hydrocarbons in stack samples, found less than 6.10"^ Ibs/hr
of these compounds emitted—a difference of A to 5 orders of magnitude.
Admittedly, the feed rates of the two incinerators would differ, but it
is unlikely that they would vary by this amount.
It is apparent that even with the uncertainties related to sampling
efficiencies and inadequate chemical analyses, as much as 1%'of the mass
of waste feed could exit an incinerator as compounds other than C02, CO,
H20 and HC1. Without a thorough quantitative and qualitative analysis of
these compounds, reliable estimates of their transport, their fates, and
ultimately their human health and environmental impacts appear impossible.
The Committee believes that relying on destruction efficiencies, as presently
defined, to estimate the quantity and quality of all generated incinerator
emissions is scientifically inadequate.
When the time varying nature of the incinerator performance is
considered, DE as previously computed does not reflect the consequences
of flame outs or other process upsets. Assuming a destruction efficiency
of 99.9999% for an incinerator ship, a 10 second flame out could increase
PCS emissions five-fold, assuming that the 10 second feed is vaporized
and undestructed materials leave the stack. However, assuming a
destruction efficiency of 99.99%, the effect of a ten second flame out
may increase PCB emissions by 5 percent. In other words, two 10 second
flame outs are equivalent to reducing the average DE from 99.9999% to
99.99%. These failure estimates are probably exaggerated, if the
incinerator can maintain sufficiently elevated temperatures and other
conditions to permit at least some destruction of the PCBs. The reader is
cautioned that these calculations are hypothetical, but they served as
illustrations to support the viewpoint that the higher the target
destruction efficiencies, the more sensitive the entire system is to the
effects of temporary upsets.
Comparison of Land Based and At Sea Incinerators
The Committee has observed the following differences between
incinerators operating at sea and on land:
1. Incinerators on land tend to operate at lower temperatures and
have longer residence times than incinerators at sea. Land based units
may also be designed to operate on toxic chemical sludges as well as
toxic liquids and, consequently, they may be segmented into a volatili-
zation chamber and an afterburner.
Determination of polychlorinated dibenzo-p-dioxins, dibenzo-furans,
and biphenyls in stack effluents and other samples from PCB incineration
test at Deer Park, Texas and Insco, El Dorado, Arkansas, February 15,
1981. Submitted to James Sales, EPA Region 6, Dallas, Texas.
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2. Existing incinerators at sea operate without scrubbers and,
therefore, emit acid mists.
Some new ocean incineration vessels under construction are
designed to use sea water for scrubbing or quenching. This scrub water
will entrain some combustion products and have the potential to form
saturated solutions of hydrocarbons in water. If the scrub water is
returned to the ocean, it will remain at the surface because is it warmer
than the ambient sea water. Exposures to surface dwelling marine organisms
(neuston) will occur at much higher concentrations of combustion products
than through transfer of these products from the plume to the water
surface. However, these comments may not apply to all ocean based
incinerator designs. In addition, the potential impact of combustion
products from these vessels on aquatic biota may be easier to assess
under controlled conditions in the laboratory.
Scrubber waters from land based incinerators also contain hazardous
materials which must be disposed of in an environmentally acceptable
manner. In at least one case, the Committee observed that scrubber water
was discharged to the local sewer system; ultimately, some of the
materials might enter local waterways.
3. Land-based incinerators operate on a stable base while ocean
incinerators may operate on rolling and pitching seas. Sloshing of
liquids in partially filled vessels can create surges in the operation of
pumps, meters, and the incinerator, and may contribute to the'possibility
of operational upsets.
The Agency has not characterized the differences among various
incineration technologies at sea and on land to assess the expected
differences they may cause in incinerator performance. It should
undertake such a comparison to complete a comparative risk analysis
between the two technologies.
Conclusion:
To monitor whether or not liquid hazardous wastes were destroyed
in the incineration process, the Agency adopted the concept of destruction
efficiency. This approach emphasizes the elimination of several pre-
selected compounds in the waste and does not fully address either partial
oxidation or chemical recombinations, either of which may create new
toxic compounds in the incineration process. To date, only a very small
portion of the compounds found in emissions from incinerators has been
identified qualitatively or quantitatively. As a consequence, the Com-
mittee finds the concept of .destruction efficiency used by the Agency to
be incomplete and not useful for subsequent exposure assessments.
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RECOMMENDATION:
THE EMISSIONS AND EFFLUENTS OF HAZARDOUS WASTE INCINERATORS NEED TO
BE ANALYZED IN SUCH A WAY THAT THE TOXICITY OF THE CHEMICAL MIXTURE AND
THE IDENTITY AND QUANTITY OF THE CHEMICALS RELEASED INTO THE ENVIRONMENT,
INCLUDING THEIR PHYSICAL FORM AND CHARACTERISTICS (PARTICLES, DROPLETS,
GASES), CAN BE ESTIMATED.
THE AGENCY SHOULD DEVELOP A REVISED DESTRUCTION EFFICIENCY PARADIGM
SO THAT ITS ASSESSMENT OF INCINERATOR PERFORMANCE CAN ACCOUNT FOR THE
VARIABILITY OF EMISSIONS AND EFFLUENTS.
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Chapter 4
MONITORING OF STACK EMISSIONS
Obtaining accurate information on which organic materials exit
an incinerator stack depends on the adequacy of quality assurance/quality
control procedures in sampling and analyzing stack emissions. These
procedures include obtaining representative gas samples, separating and
quantitatively storing the sampled organic components, quantitatively
retrieving the stored materials, and determining what compounds are
present and in what amounts. The accuracy and precision of these steps
will determine the confidence in the predictions of both transport, fate
and biological effects of the materials that are identified.
To date, the sampling of stack gas emissions has not occurred in a
manner which would allow appropriate scientific evaluation. For example,
the sampling trains used to collect the organic emissions for analysis
were not consistent in either operation or design. As a result, it is
difficult, if not impossible, to compare results from the various studies.
Often a single sample point in the stack was used to gather the sample
for chemical analysis. Vagaries in flow, temperature, and gas composition
that can occur within a typical large scale commercial stack require
sampling at many locations in the stack to gather a composite of the
emissions.
A serious drawback of all the sampling programs carried out during
previous incineration research burns is the collection of data for only
short durations and under normal or "optimal" operating conditions. During
periods of abnormal operating conditions, Agency staff informed the
Committee that the sampling probe was removed or that sampling was terminated
prematurely when sampling trains became clogged. Such practices lead to
inaccurate results. On a few occasions, the Committee questioned whether
the sample train was adequately washed with a variety of solvents prior
to sampling to remove condensed residues of high molecular weight components
and particulate materials. Such practices would, of course, introduce
additional inaccuracies.
One of the most notable sources of error was associated with the
methods used to calibrate the sampling apparatus for recovery of suspected
organic compounds. It appears that some recovery information was collected
by spiking the sample train under ambient conditions and not under
circumstances that at least simulate actual field conditions. The most
obvious of these conditions was a gas stream at high temperature that is
enriched with CO, C02» 820, and HC1. The Committee recognizes that
recoveries of organic compounds from various gas streams can be markedly
influenced by the inorganic components present, but it believes that the
Agency should undertake efforts to develop recovery protocols that at
least approach field conditions. EPA can use information obtained from
such methods not only to evaluate past analytical information but also
to optimize future sampling efforts.
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There appears to be a general lack of information on the repro-
ducibility of the sampling processes employed to date. The simple and
most direct method to establish the limits of reproducibility consist of
conducting multiple samplings of the same stack gas emissions under the
same conditions.
Most stack sampling has addressed the problem of measuring the
presence of unmodified feed components in the stack gas emissions. In
those cases where investigation of combustion by-products occurred, the
sampling most often focused on smaller molecules of low polarity.
Although such materials are important, they do not address the considerable
contribution to the stack gas from polar compounds. The sampling, recovery
and analytical methods employed have not recognized these possibilities.
The polar by-products, if formed, may be of special toxicological
significance because of their increased water solubility.
To calculate mass emission rates of specific compounds, the stack gas
temperature and velocity should be measured at the sample points with the
results integrated over the stack cross section to determine the mass flow
to each component.
Conclusion;
Previous sampling efforts during research burns have occurred either
under optimal burn conditions, or through the use of inadequate sampling
procedures during upset conditions which occur with unknown frequency.
Even relatively short-terra operation of incinerators in upset conditions
can greatly increase their total loadings to the environment.
RECOMMENDATION;
THE DETERMINATION OF THE ACTUAL EMISSIONS AND EFFLUENTS OF INCINERATORS
SHOULD RESULT FROM AN ASSESSMENT OF THE TOTAL MASS LOADING TO THE ENVIRONMENT
UNDER ALL OPERATING CONDITIONS.
Conclusion:
The existing analytical data for emissions from hazardous waste
incinerators have 'a variety of limitations. Among the major problems are
the limited number of chemicals selected for analyses and the fact that
the analytical methodologies have not been validated for either the
conditions of the test and for the complex mixtures which exist in
incinerator emissions. As a result, no relatively complete and reliable
analyses of mass emissions from either land or sea based incinerators
exist on which to develop subsequent estimates of the potential for
environmental exposures. These analytical problems are particularly
difficult to solve for incinerators with very high exit temperatures.
RECOMMENDATION;
SAMPLING AND ANALYTICAL METHODOLOGIES SHOULD BE VALIDATED FOR
MEASUREMENTS OF EMISSIONS FROM HAZARDOUS WASTE INCINERATORS.
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Chapter 5
ATMOSPHERIC TRANSPORT AND FATE
Source configuration, topography, and ambient meteorology all
strongly affect subsequent environmental transport and fate of chemicals.
Once emitted, stack gases and particles are transported varying
distances through the atmosphere until ultimately they are either
destroyed through such mechanisms as photo-decomposition or deposited
on land or sea surfaces. Any prediction of the biological impact of
incinerator emissions needs to consider these factors.
Atmospheric properties which determine the transport and fate of
these emissions are highly variable in space and time. On-shore and off-
shore meteorological conditions can differ widely and need to be considered
separately. Scientists have a general understanding and documentation of
both large-scale weather and climate over coastal seas and water circulation
patterns. On the other hand, micro-scale conditions that determine plume
dispersion and deposition are less well known, and the available data
base is limited to several experimental studies conducted within 10 km off
the shoreline of the coasts of Long Island (Raynor et. al., 1975, 1978),
Louisiana (Dabberdt et. al., 1982), and south-central California
(Zanneti et. al., 1981, and Dabberdt et. al., 1984). In general, better
documentation exists for meteorological conditions over land, both on
large and small scales.
The behavior of plumes, such as those from incinerators, has under-
gone extensive study and, with care, can be modeled adequately for the
purpose of simulating worst-case or even typical concentrations. Some
attempts at simulating concentrations and dosages from land and sea based
incinerators exist in the available literature. In one study (O'Donnell
et. al., 1982), EPA requested that Oak Ridge National Laboratory determine
atmospheric concentrations resulting from several actual incinerators
that were then hypothetically located (for modeling purposes) in various
U. S. cities. The study authors used a historical weather data base of
several years. Although the results may be considered "typical" of what
usually happens, they do not depict a range of conditions resulting from
local meteorology (e.g., inversion capped valleys) or adverse combinations
of source location and demographic distributions. Another EPA-contracted
study (JRB Associates, 1984) attempted to evaluate worst case impacts from
shipboard incinerator operations 200 km off shore. The meteorological
input data used to drive the model, as well as some of the physical
assumptions, were questionable at best. Furthermore, the model utilized
was not appropriate to conditions involving a moving source and a fixed
receptor. Additionally, the final Environmental Impact Statements for
the Gulf of Mexico (EPA 1976) and North Atlantic Ocean (EPA 1981) burn
sites discuss the atmospheric and oceanic characteristics but do not
discuss plume behavior and atmospheric stability in sufficient detail to
evaluate the atmospheric dispersion calculations that were presented.
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Although limitations to the precision and accuracy of the available
over-land and over-water dispersion models exist (Hannati et. al., 1984),
analysts can obtain simulations of sufficient accuracy for the purpose of
evaluating incineration impacts.1 The more important uncertainties arise
from assumptions of estimates regarding the nature and rate of the effluent
emissions, wet and dry deposition rates, meteorological inputs and
atmospheric reactions (dry and aqueous).
Important differences in dispersion rates can be achieved over water
by selecting the time and place for incineration and varying the navigation
of the ship (e.g., cruising across the wind). Atmospheric mixing and
transport exhibit strong regional differences in rate and extent, and
large changes occur under different seasonal and weather conditions. The
North Atlantic Ocean has much better atmospheric conditions for dispersion
year round than does the Gulf of Mexico, but the latter exhibits more
optimal dispersion conditions in fall than in late winter. Incineration
over land should take into consideration the large range of dispersion
efficiencies encountered. There will be periods when poor dispersion
conditions produce high, local concentrations, and the EPA should consider
reducing or eliminating incineration at these times. Agricultural
burning is controlled in the western states in an analogous manner.
The Agency has treated the plume rise issue in a cursory manner even
though the scientific literature documents that it has an important
impact on pollutant transport and removal. Plume rise can be a critical
determinant of downwind concentrations by governing whether emissions get
trapped below an elevated inversion, embedded in a surface based inversion,
or contained above an elevated inversion that the plume has penetrated.
The EPA/JRB dispersion analysis (JRB, 1984) assumes a worst case temperature
lapse rate for a surface based inversion that is an order of magnitude less
than actually observed in Gulf of Mexico dispersion studies (Dabberdt et.
al., 1982). Subsequent plume rise considerations are thus unrepresentative.
To enhance the credibility of these efforts, EPA should eliminate discrep-
ancies of this type and initiate more rigorous and representative model
simulations.
In a number of places, EPA estimates and calculations assume that
emissions from incinerator stacks will be deposited in the Gulf of
Mexico. Agency staff also implicitly stated this position in some
of their briefings to the Committee. In actuality, some of the compounds
may have atmospheric lifetimes of weeks or more during summer and fall
and may be dispersed over the hemisphere. During these periods, the
Such model simulations are typically within a factor of three of
representative observations.
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atmosphere is unstable, and the contaminants will rapidly move through
the depth of the nixed layer which frequently is capped by a thermal
inversion at a 300 meter (m) to 600 m altitude. However, plume rise of
the heated incinerator emissions may be sufficient to penetrate the
inversion, effectively isolating the elevated plume from the underlying
water surface and leading to long distance'transport and dispersion.
Should plume rise not reach above the inversion surface, the low
atmospheric concentrations in the mixed layer below the inversion will
limit deposition.
Meteorological dispersion conditions are different during winter
and early spring when Gulf of Mexico surface water temperatures are low
(15°C-20°C) and the advection of relatively warm air results in a steep,
shallow inversion from the sea surface to heights of 100 m to 250 m.
Experimental studies in stable atmospheres over both the western Gulf and
the Pacific Ocean (off the coast of south-central California) indicate
very small diffusion rates for non-buoyant plumes; for example, the
second moment of the vertical concentration profile of gases released at
a height of 13 m above the sea surface typically ranges from 25 ra to 60 n
at a fetch of 8 km from the source, while the second moment of the
corresponding horizontal concentration distribution is typically 100 m to
500 m. Thus, concentrations can be high, but the impact area small. The
plumes of some ocean based incinerators, however, may have high temperature
and high exit velocities. Under these conditions, the plume is dominated by
buoyancy factors in its initial stages and may penetrate low level
i nve rs ions.
Land incinerators with scrubbers have cooler plumes and may not
penetrate low level inversions. In addition, local topographic
conditions on land have profound influences on air circulation and mixing
with subsequent impacts on the fate of the plume. It is important that
the Agency examine these different cases in some detail to define more
clearly the plume rise and dispersion conditions that will exist.
Plume contact with the sea surface would only occur when the plume
either cannot penetrate a surface based or elevated inversion or is
entrained by the atmospheric wake in the lee of the ship. The former
requires additional calculation using more representative, meteorological
data already available. The latter (downwash) phenomenon is unlikely,
though possible, and should be analyzed more rigorously than has been
done to date (only anecdotal arguments have been suggested). Even when
the plurae touches the sea surface, the small concentrations in a convective
atmosphere and the very low diffusivity of the air near the water surface
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in a stable atmosphere will likely minimize the diffusion of gases into
the water or the fallout of particulates. Sorption of organic gases
occurs upon cooling, and when attached to particles, the removal rates
will accelerate. If the volatile materials are not attached to particles,
few of these compounds are likely to deposit in the immediate area of
the Gulf of Mexico.
EPA should address the issue of wet deposition in more depth.
Precipitation is often an important factor which supplements dry removal
and may incorporate soluble compounds by direct contact and scrubbing or
by absorbing onto particles of a wide variety upon which water condenses
to form cloud drops. Rain drops are formed by the coalescence of millions
of cloud drops, each of which initially had a solid nucleus. While rain
will quickly remove HC1, other compounds need examination to determine
whether they will attach to particles in the air or are efficiently
removed by rain.
Conversion processes are also a factor in atmospheric transport. It
is likely, for example, that particles will form downwind in the plume as
well as in the stack. Photochemical processes will destroy some compounds,
while others will remain as gases for long periods, and some disperse
into the stratosphere. Those gases with low vapor pressures may condense
or adsorb on suspended particles.
EPA did not give sufficient consideration to a few additional
atmospheric factors. These concern the separation distance between an
incineration vessel and receptors (such as people) and the development of
a range of meteorological scenarios. The EPA/JRB (JRB 1984) scenario
assumes that the vessel locates at 200 km offshore and that the nearest
receptor is at the shoreline. This assumption ignores the consideration
of exposure to people on offshore platforms and on other vessels. The
EPA/JRB (JRB 1984) worst case, over water analysis assumes a single
atmospheric regime: a steady wind into which the incineration vessel
cruises continuously at a steady speed and heading (three stability
assumptions are given as well). While this is one valid transport regime,
others should be considered. One example would involve a calm period
(with the ship making a circular or other closed course) followed by a
period of on-shore transport for a period followed by a wind reversal
with subsequent on-shore transport (in effect, a doubling of the effective
emission rate). If negative impacts result, these could be minimized by
appropriate movement of the ship or control of the burn period. The
latter is especially appropriate to land based incineration.
In addition to the dispersive nature of the atmosphere and the
possibility of local direct deposition of stack emissions into the ocean
for long periods, one must consider the complexity of ocean circulation.
Here, too, there are surface circulations of varying vigor and dimension
driven by larger circulations such as the Gulf Stream or the gyres that
spin off from such large circulations. The mixed layer of the ocean
also reflects winds and convection patterns in the atmosphere. Some of
these patterns become well established and are transported by larger
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scale currents. Thus, a ship moves through these patterns of flow which
are, in turn, transported laterally and changing with time. Simultaneously,
the incinerator plume discharges into a similarly complex atmospheric
circulation. This is likely to result in a very short and erratic exposure
of any portion of ocean to a segment of the plume.
The dynamics of the emissions and their potential impacts on biota
are exceedingly complex. Unless an adequate baseline of the quantitative
and qualitative nature of the emissions and their subsequent fate exists,
it is very difficult to design a sampling program which can assess
environmental impacts, especially in a marine setting.
Due to the widespread distribution of gaseous effluents from
incineration at sea covering millions of square miles of ocean and land
and, in fact, the entire globe, one can ask why incineration at sea is
any different from incineration anywhere else. It is possible that land
incineration can produce as much fallout at sea as would ocean incineration
because of the much larger quantities of combusted material emitted over
land, including unregulated on-site incineration and municipal incineration.
Unless a case can be made that the contaminants quickly attach themselves
to very large particles with appreciable fall rates of several centimeters
per second, or unless they disperse into rain showers, the local influence
of incineration at sea may be negligible at the efficiencies given for
the incinerators. If incineration takes place in situations where no
rainfall occurs within a few miles, the rain problem becomes insignificant.
The key issue is to determine whether the incinerators operate properly and
destroy the wastes, and what new compounds, other than those destroyed,
exit the stack and are toxic. The Environmental' Impact Statement for the
designated North Atlantic incineration site (EPA 1981) clearly states
that some substances degrade into more toxic materials than the precursors
and that others produce new compounds as a result of incineration. (This
is also mentioned by Ackerraan et. al,« 1978.) EPA should establish the
characteristics and quantities of these compounds. If they have negligible
environmental consequences, the atmospheric component of incineration at
sea activities may be a nonproblem. In fact, the mobility of the ship
and the ocean can avoid large accumulations of fallout in any particular
area as might occur for a fixed land based incinerator.
Conclusion:
The numerical simulation of atmospheric transport and diffusion
processes and the resulting exposures to environmental receptors requires
technical improvements and greater delineation of the intended uses of
such simulations for over-land and over-water situations. In general,
current models have not sufficiently utilized the large existing
meteorological data base.
For land based evaluations, the modeling procedures have inadequately
considered the local effects of atmospheric circulations (including
topographic effects) which can result in poor dispersion of even recir-
culating conditions. The modeling of emissions also needs to consider
upset conditions because the chemical and physical characteristics of
the emissions are likely to be different at those times. If, upon further
analysis, these compounds exhibit negligible environmental characteristics,
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atmospheric dispersion of such pollutions nay not be a problem.
Over-water simulations also need to take into account the occurrence
of upset conditions in a realistic fashion. Because of the incinerator ship's
nobility, a Gaussian plume dispersion model is not appropriate for this
situation. An unsteady dispersion modeling approach is required to treat
the time-variable source location and intensity conditions. The models
utilized should be able to accommodate plume rise dynamics, ship wake effects,
plume chemistry, and wet and dry deposition. The models should also be
capable of incorporating weather changes, changes in ship movements, and
unusual emission situations, including catastrophic failures, into the
analyses. It should be noted, however, that atmospheric processes over the
ocean, such as rainfall patterns, may mitigate the potential impact of
incinerator emissions.
RECOMMENDATION:
NUMERICAL SIMULATIONS OF ATMOSPHERIC TRANSPORT AND FATE OF INCINERATOR
EMISSIONS ON LAND OR AT SEA SHOULD BE REVISED TO IMPROVE THEIR REALISM.
THE ISSUE IS PARTICULARLY ACUTE WITH RESPECT TO MOVING SOURCES.
Conclusion:
Assessing the transport and fate of chemicals released into the
environment is a necessary precondition for estimating probable exposures
to various organisms and for calculating the potential for adverse effects.
EPA should include both the chemical and physical characteristics of
emitted compounds in the development of exposure estimates. Calculations
can result by direct measurement or by computer simulation coupled with
laboratory or field verification. The Committee found that EPA had
evaluated these phenomena for land based incinerators essentially on the
basis of computer modeling alone with little or no field verification.
In the case of ocean based incinerators, the Committee found the field
measurements to be largely inadequate.
The problems associated with ascertaining the possible impacts from
land based incinerator emissions in the near field ambient environment are
not trivial. This is due, in part, to the high ambient chemical concentration
levels around such facilities from a variety of sources located in developed
areas. To improve the capability to detect and evaluate possible environ-
mental effects, EPA should focus its measurement efforts in those areas
which it estimates receive the highest loadings from incinerators. Such
measurements can be conducted most readily through the combined use of
simulations and' spiking of the plume with suitable tracers, such as
perfluorocarbons.
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RECOMMENDATION:
EPA SHOULD EVALUATE THE ENVIRONMENTAL TRANSPORT AND FATE OF EMITTED
SUBSTANCES TO PROVIDE EXPOSURE ASSESSMENT DATA FOR BIOLOGICAL RECEPTORS,
INCLUDING HUMANS. SOURCE-RECEPTOR RELATIONSHIPS SHOULD BE QUANTIFIED
USING TRACERS AND SIMULATION MODELING TOGETHER WITH AMBIENT GAS AND
PARTICULATE CONCENTRATION MEASUREMENTS.
Conclusion:
A very important application of modeling is the identification of
optimal locations for alternative incineration sites. The siting
evaluations should consider temporal.meteorological variations as well as
spatial micro-meteorological differences associated with the sites. In
this way the Agency could evaluate local, site-specific effects on the
dispersion and subsequent exposures to waste incinerator emissions.
RECOMMENDATION:
DECISIONS ON THE SITING AND OPERATION OF HAZARDOUS WASTE INCINERATORS
SHOULD CONSIDER LOCAL METEOROLOGICAL CONDITIONS TO MAXIMIZE ATMOSPHERIC
DILUTION AND TO AVOID EXCESSIVE AMBIENT CONCENTRATIONS.
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Chapter 6
TRANSPORT AND FATE OF INCINERATION PRODUCTS IN AQUATIC SYSTEMS
After emissions from incineration activities at sea or on land
>
reach the atmosphere they are diluted, transformed, and transported
in very complex patterns. Various mechanisms, such as strong sorption
to particles and/or bioraagnification in food webs, may produce locally
elevated concentrations of an emitted combustion product. However, the
general picture is one of dilution of the emitted compounds, and even
the two apparent concentrating mechanisms cited above are dominated by
entropy rather than by active transport mechanisms working against a
concentration gradient.
The Agency has attempted to model the environmental transport of
combustion products. However, most of these models treat the atmospheric
or the aqueous compartments as uniform matrices.
The first contact of any combustion product with an aquatic marine
or fresh water system occurs at the water surface or near to the surface
if scrubber water is injected into the water column. By the time that
such contact occurs, the combustion products may experience significant
dilution, transport, changes in physical and chemical state, and photo-
degradation. Contrary to popular perceptions, the properties of the
water surface differ significantly from the subsurface properties.
The Surface Microlayer
When combustion products enter water, directly from the atmosphere,
the surface layer (also termed the surface microlayer or the surface
film) is the area of initial impact. The composition and physical
properties of the surface microlayer dictate that it play several roles
in aquatic ecosystems: as a site of physio-chemical processes which
serve in the transport of materials between air and water; as an
intermediary source or sink for airborne organic and inorganic components;
and as an important component in food webs. Because the surface micro-
layer is not part of common knowledge outside the field of oceanography
(Bidelman et. al., 1976 and Pat11, 1982), it receives somewhat more
attention in our report than do other aspects of aquatic ecosystems.
A very thin film of natural organic matter more or less continuously
bounds the water surface. This film is visible as the familiar sea
"slick" in marine systems and fresh water lakes and results when the
film depresses the surface tension of the water sufficiently to damp
capillary waves. It is important to recognize, however, that even when
no "slick" is visible, an organic film usually bounds the water surface.
The surface film is subject to lateral transport primarily influenced
by wind stress rather than water currents. The slick becomes visible
upon the convergence of vectors of wind stress, a water surface convergence,
or a wind stress vector toward a front. Measurements of film formation
rates have recorded changes in surface potential in ocean environments;
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within about 20 seconds a clean surface forms a film that reflects a surface
potential change of about half its initial values (Van Vleet and Williams,
1983). Microturbulence or bubble transport of surface active materials
may double this value within one to two hours. Natural organic materials
largely comprise the film which is continuously fractionated into the
sea surface. There it is trapped when it exhibits even slight hydro-
phobicity due to the loss of the energy of hydration. Much of the surface
organic matter is particulate, with maxima in the 0.2 um to 1 urn range
(Henrichs and Williams, in press). In part, this reflects the high
concentration of bacteria in the film [10^ to 10^ times their concentration
in the subsurface water (Harvey, 1979)]. Much of the organic matter may be
colloidal (Stuintn and Morgan, 1981). The release of ami no acids on
hydrolysis suggests that much of the organic matter is proteinaceous, and
considerable amounts of bound carbohydrate can be detected as probable
glycoproteins and glycolipids. Usually only a small fraction, about 5%,
is lipid (Henrichs and Williams, in press), although other studies indicate
a higher proportion of lipids. The study by Van Vleet and Williams
(1980) of the collection efficiency and bias of 14 collecting techniques
indicates the problems in obtaining representative samples.
The natural film, when under lateral pressure, folds and flocks.
Some speculation exists (Fox, Isaacs, and Corcoran, 1952) that this
collapsed film is one source of "marine snow," the flocculate detritus
present in marine waters. Most marine zooplankton are filter-feeders and
consume this flock in addition to the phytoplankton and microplankton.
The concentration of organic material in the surface layer of marine
systems provides the basis for the food web of -the neuston, the biota
that live in this niche. The possible significance of biota utilizing
freshwater surface films is essentially unknown. In marine systems, the
organic material rapidly metabolizes by large populations of heterotrophic
and mineralizing bacteria, raicroflagellates and ciliates, as indicated by
high concentrations of free amino acids and inorganic nitrogen detected
in surface films. Invertebrate larval forms, such as copepodites and
veligers, feed on this concentration of particulate organic natter,
bacteria, and microplankton (Zaitsev, 1971; Kittredge, personal com-
munication). Above the surface, the ocean-skaters, Halobates, a genus of
marine insects, feed on the surface biota, and below, in the water column,
fish and other organisms also feed in the surface layer.
The Water Column and Sediment
Below the microlayer, the water column extends to the bottom of the
ocean. Investigations have frequently noted the patchiness of both
inorganic and organic nutrients in the water column. It is reasonable
to assume that, as in the case of the raicrolayer, increased concentrations
of organic nutrients in discrete areas of the water column may result in
a parallel partitioning of organic and trace metal contaminants into these
patches. The water column is not only the habitat of the pelagic organisms
but is also the pathway through which zooplankton migrate in their daily
travels between the mesopelagic zone and the surface, and is the highway
through which a rain of detritus falls to the bottom. The water column
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supports, in addition to plankton, a largely non-resident, mobile
population of organisms with daily and seasonal activity patterns. These
populations transport food away from the source to spatially and temporally
distant areas, while zooplankton migrators move materials by vertical
migration. Finally, on the bottom of oceanic systems, scientists have
suggested for some time that a rain of particles functions as a primary
means by which nutritive material reaches organisms at depth (Wiebe et.
al. , 1976). The major components of this material include fecal pellets
(Hinga et. al., 1979), crustacean carapaces, large animal carcasses,
large phytoplankton cells (Wiebe et. al., 1976), and inorganic shells of
foraminiferans and pteropods with absorbed organic natter, all originating
from the surface and the water column below it.
Estimates of the settling rates of organic material from the surface
layer are difficult to obtain but may be quite rapid. Sinking rates for
fecal pellets' occurs within the range of 50 m/day to 940 m/day, and transit
times record depths of more than 2000 m in 9 days to 40 days (Wiebe et. al.,
1976).
The sediments often play a predominant role in freshwater environments
in the migration and storage of hydrophobic materials. The large amounts
of organic carbon in freshwater sediments act as major depots for these
hydrophobic materials through both sorption and partitioning processes
(Neeley, 1980). Considering the mass of sediments and. the concentrations
of PCBs and common chlorinated pesticides in the water, biota, and
sediments of the Great Lakes (Veith et. al., 1977; Haile et. al., 1975), it
appears likely that the sediments contain the greatest amounts of these
hydrophobic materials in fresh water systems. Documentation exists that
PCBs also have contaminated marine sediments at depths of 4 km in the
Mediterranean Sea. (Bernhard, 1981).
From the preceding discussion it should be obvious that the surface
microlayer does not exist in isolation. Though it functions as the site of
entry of atmospheric chemicals into marine ecosystems, it is also closely
coupled to events which occur in the bulk phase and in the sediments.
Those combustion products which enter the aquatic environment sorb onto
particles which descend to the sediment; they will partition into the
bulk phase water; and they will become incorporated into biota directly
and through food webs. All of these processes can be thought of as
competing sinks for the chemicals entering the system; none of these
sinks is independent of any of the others.
Food Webs
Biomagnification through food webs is a complex process which depends
upon partially understood physical/chemical characteristics and upon
interspecies relationhsips in food webs. Compounds which bioconcentrate
readily may not necessarily biomagnify. While models exist which can
provide rough approximations of the extent of bioconcentration, the
ability to project biomagnification is much less reliable.
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While the magnification of chemicals in food webs is a very .complex
process, it can be separated into three component parts. These include
1) the direct uptake of chemicals from water (through cell surfaces,
integument, or gills)—"bioconcentration;" 2) the uptake of chemicals
through contaminated food, in addition to that which is derived directly
from water—"bioaccumulation;" and 3) the uptake of chemicals by all
routes in a context of ecological trophic levels—"biomagnificaion."
For most organic chemicals the bioconcentration process results from
passive diffusion whose driving force is related to the differential
solubility of these chemicals in fats relative to water. In this context,
the fats compete as a sink against the water bulk phase, against the
compounds in the surface microlayer, and against the sorptive potential
of suspended particles and of sedimentary particles. Thus, bioconcentration
can be thought of as the end result of multiple partitioning processes.
The bioconcentration process relates only indirectly to food
webs since it deals only with the direct uptake of chemicals from the
ambient environment. Food webs are important when the uptake through
food is considered in addition to bioconcentration. When a substance can
partition readily between intracellular lipids and water, then bioaccumula-
tion contributes little to the final equilibrium between water and
organisms because bioaccumulated material in excess of that which is
compatible with the bioconcentration coefficient merely results in a net
flux from the organisms to the environment (Hamelink et. al., 1971; Neely,
i960). Even DDT and dieldrin have, on occasion, failed to demonstrate a
biomagnification effect in strictly aquatic systems, as demonstrated by
finding constant concentrations of these simple pesticides in the fat of
several fish species in the Great Lakes, regardless of. trophic level
(Reinert, 1970). Food web processes become prominent when the compounds
have very long residence times. This development is associated with high
lipid solubility combined with high molecular weight at low water solubility
(Neely, 1980). The driving force, which allows the concentration in the
predator to be higher than that of the prey, is not due to any active
transport against the concentration gradient in the gut of the predator
but to the fact that the digestive process involves a phase change of the
lipids of the prey which act as the solvent for the bioaccumulatable
substance. This, as a consequence, alters the basis for the partitioning.
Conclusion:
The Committee found that the Agency's evaluations, while appropriately
emphasizing the dilution of pollutants, have not effectively addressed
mechanisms in the environment which would result in the concentration of
emission products. Knowledge of such mechanisms is important to a fuller
understanding of pollutant transport and fate even though the general
picture is one of dilution of the emitted compounds.
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The segments of the biosphere impacted by the emissions from chemical
waste incinerators will be largely influenced by the dynamics of atmospheric
and aquatic transport processes. Within these processes, mechanisms, such
as the following are likely to influence the concentrations which actually
impact biota 1) phase separation and chemical distribution between phases,
2) interphase transport at air/water, air/solid, air/biota, water/solid,
air/biota, water/biota, and solid/biota interfaces, and 3) photo- and
biochemically stimulated reactions involving the incinerator emissions after
they leave the stack.
RECOMMENDATION;
THE DYNAMICS OF ENVIRONMENTAL TRANSPORT, INCLUDING CHEMICAL PARTITION
BETWEEN PHASES AND INTERPHASE MASS TRANSPORT SHOULD BE EVALUATED IN A
WAY THAT IS USEFUL FOR EXPOSURE ASSESSMENT.
Conclusion:
Surface micro-layers may play significant roles in the concentration
of some chemical species.
RECOMMENDATION:
EPA SHOULD INCORPORATE THE ROLE OF MICRO-LAYERS IN THE TRANSPORT
AND CONCENTRATION OF EMITTED CHEMICALS INTO ITS ANALYSIS.
Conclusions:
Environmental transport and fate processes exhibit both short-term
and long-term variability and trends. These changes should influence
the Agency's thinking for the selection of the most appropriate averaging
time for incineration activities in order to analyze the potential effects
of chemical burns.
It is possible to use simulation models appropriately for many aspects
of evaluating the environmental transport and fate of emitted chemicals.
However, such simulations often have significant limitations which the
Agency has not always recognized in its analyses. Such limitations become
even more significant when several simulation models are linked into
large scale simulations. The results from these large scale simulations
are unconvincing, especially when they are not supported by some field
validations.
RECOMMENDATION:
MODELING OF INTERPHASE TRANSPORT AND FATE OF CHEMICALS EMITTED FROM
INCINERATION SHOULD BE COUPLED WITH SOME FIELD VALIDATIONS.
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Conclusion:
Exposures of organisms to chemicals originating from liquid hazardous
waste incinerators take place through various pathways which differ
according to transport processes and the habits of the organisms involved.
Such exposure pathways will certainly include absorption through lungs or
gills, skin, and food webs. The exposure will vary over time and in the
dose attributable to each chemical. The relative proportions of chemicals
in the mixture to which organisms are actually exposed is likely to be
different from what was initially emitted by the incinerator because of
the differential influences of transport, phase distribution, and chemical
reaction dynamics on the emitted chemicals. The accurate determination
of exposures, which depends on these many variables, is very difficult.
The efforts of the Agency to assess such exposures have been inadequate
because they resulted from either individual judgments or computer models
without adequate laboratory or field verification.
RECOMMENDATION:
THE AGENCY SHOULD EVALUATE EXPOSURE DURATIONS AND CONCENTRATIONS
BASED UPON BOTH A DETAILED ASSESSMENT OF TRANSPORT PROCESSES AND THE
HABITS OF THE EXPOSED ORGANISMS.
Conclusion:
Some toxic chemicals have not biomagnified in aquatic systems such as
the Great Lakes. When chemicals biomagnify, however, a potential exists
for adverse effects on aquatic life and consumers of aquatic life, including
humans. Liquid hazardous wastes may contain chemicals which can biomagnify
or, when burned in an incinerator, may produce combustion products which
biomagnify.
RECOMMENDATION:
EMISSIONS FROM LIQUID HAZARDOUS WASTE INCINERATORS NEED EVALUATION
FOR CHEMICALS WHICH CAN BIOMAGNIFY. THE DEVELOPMENT OF METHODS TO IDENTIFY
THE POTENTIAL OF CHEMICALS IN INCINERATOR EMISSIONS WHICH CAN BIOMAGNIFY
IS NEEDED.
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Chapter 7
TRANSPORT AND FATE OF INCINERATION PRODUCTS
IN TERRESTRIAL SYSTEMS
Land based hazardous waste Incinerators are stationary point sources
which emit pollutants into air, land, and water media. Emissions
may occur as part of the incineration process, as part of the scrubber
operations, or as fugitive emissions. Uptake of emissions by terrestrial
life may occur through air, water, soil, or via the food web.
Functional differences between sea and land incineration require
distinctive approaches in near-field assessment. These functional
differences result from variations in incineration temperatures as well
as from treatment of the exhaust gases. Since land based incinerators
often have scrubbers and precipitators, the resulting emissions are
different, both in quanity and type, from those generated by incinerators
which do not have such units. For instance, land based incinerators
generate scrubber waters, sediments, and sludges that must be disposed.
Their cooler gaseous emissions nay result in a different chemical
composition relative to the hotter emissions of sea based incinerators.
The sampling of exhaust gases is often simpler for land based incinerators.
Land based hazardous waste incinerators tend to be located in developed
areas, and it may be difficult to establish causal relationships between
residues originating from incineration activities and observed environ-
mental changes. The burning of a wide range of fossil fuels for heating,
transportation, and industrial processes, for example, releases by-products
of combustion, many of which may have similar physical and chemical
characteristics as those compounds emitted by hazardous waste incinerators.
Thus, an association of combustion products with environmental degradation
is not necessarily proof of a causal relationship with hazardous waste
incineration.
It is possible to collect representative samples of gaseous, aqueous,
and solid incinerator emissions and effluents to develop a mass balance
estimate of what enters the environment. Many commonly accepted techniques
also exist for sampling which contaminants enter the terrestrial system.
These Include air and deposition samples as well as samples of the physical
and biological systems into which they enter.
Transport models developed for the dispersion and transport of air
pollutants provide a basis for understanding pollutant behavior under a
wide range of atmospheric conditions, including the influences of terrain
features. Models also exist to track the distribution of pesticides from
both ground and aerial application. Modelers have already used some of
these techniques to determine deposition from plumes.
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Models of plume dispersion from known incineration sources should
provide information on appropriate sample sites. Sampling frequency,
location, and subsequent stratification of the impacted area, can be
determined following initial sampling to calculate concentration gradients.
Since routes of input into the ecosystem are important to subsequent
transport and accumulation, the development of sampling systems should
insure and account for these parameters. These include air, particulate
matter, deposition in rain and snow as well as movements in water and in
biota. Tracer releases from incinerators (see Chapter 5) would aid in
evaluating atmospheric transport routes. The distribution of receptors
(human and nonhuman), from near-field/high contamination levels to areas
outside the near-field impact area, should also be considered.
Biological and physical sampling systems for both near and far-field
deposition should initially derive from plume models and the composition
of the physical and biological systems into which the effluent is released.
Plants and non-mobile animals, such as soil invertebrates, would provide
the best insight into near-field estimates of deposition and accumulation.
Evaluation of biomagnification would require sampling of higher trophic
levels and would involve more mobile species and greater sampling variance
as a result of differing exposures in space and time.
The potential hazard of toxicants to the terrestrial ecosystem
depends, in part, upon the physical state of the substance. If the
material is water soluble, it will tend to fall upon the vegetation and
soil with precipitation. This often means that it will tend to wash off
the vegetation and infiltrate the so'il, or that it will absorb directly
into the plant. In the soil, it will partition between the biota, the
soil itself and the downward percolation of water, eventually moving to
groundwater. In the soil or in the plant, it may detoxify or pass into
the food web and undergo bioraagnification.
For most of the known toxicants of concern for land based incineration
of chemicals, few data are available upon which to base estimates of this
partitioning. Data on the uptake of herbicides from soils will yield
some clues to the behavior of other organic molecules in the soil, but
only very rough estimates are possible. Many of the toxicants are nearly
insoluble and will probably wash out of the atmosphere sorbed onto
particulates. Those which deposit on vegetative surfaces may adhere
to the cuticular layer in preference to sorption on the particle surface,
but this has not been sufficiently studied. Whether these residues
adhere to the plant leaves or fall onto the soil surface, some will enter
the food web through ingestion by grazing animals. Even in well grazed
pastures, much of the vegetation degrades as litter by microorganisms.
The toxicants which are only slightly soluble become virtually immobile
in the soil and will persist until microorganisms succeed in attacking
and breaking down those that can biodegrade. Some chemicals will degrade
quickly by soil microorganisms, some will modify slowly, and others will
endure for very long periods. Degradation rates strongly depend upon
soil moisture and temperature and the occurrence of suitable organisms,
and are still far from being adequately modeled.
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Some of the pollutants will find their way into lakes and streams
directly through the precipitation, but others will enter through sorption
on soil particles subject to erosion. Erosion is an inevitable and
natural process involving the uppermost surface layer of the soil upon
which the sorbed material will reside. It is possible to conceive of
fall-out from successive burns concentrating through selective erosion
in the sediments at a much higher density than one might expect on an
average basis. Erosi -n models that might be used to illuminate this
question exist, but the material brought to the Committee's attention
did not show this level of sophistication. In general, the modeling of
the fate of toxicants emanating from incinerators has been rudimentary.
Though this is a difficult and complex problem, the Agency's past
efforts to understand terrestrial transport processes were not thorough.
While terrestrial food webs are as complex as their aquatic counter-
parts, scientists also have a better understanding of them. To date, the
analysis of biomagnification of incineration products relied upon by EPA
apparently derived from a relatively simplistic simulation model (Holton
et al., 1984) limited to relatively volatile compounds whose bioraagnifi-
cation potential is not particularly prominent. The Committee did not
find any systematic field studies with which to compare these simulations.
Conclusion:
It is difficult to associate the burning of hazardous wastes with
observed changes in the terrestrial environment because many land based
incinerators are sited in-highly industrialized areas which have other
combustion sources emitting similar compounds. EPA has not made the
fullest possible use of existing modeling techniques to evaluate the
transport, fate, and effects of incinerator products in terrestrial
systems. Thus, subsequent Agency exposure assessments to biota and
humans in the ecosystem are unreliable.
RECOMMENDATION:
EPA NEEDS TO EVALUATE THE TRANSPORT AND FATE OF INCINERATOR PRODUCTS
IN TERRESTRIAL ECOSYSTEMS BY USING STATE-OF-THE-ART FIELD MONITORING AND
LABORATORY EVALUATIONS IN CONJUNCTION WITH IMPROVED SIMULATIONS.
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Chapter 8
EFFECTS ON AQUATIC SYSTEMS
Before assessing the effects of combustion derived pollutants on
organisms or ecosystems, the characteristics of the toxicants and
an evaluation of the extent of exposure to the respective organisms
and/or ecosystems must be determined. Appropriate sampling methods in
the stack and plume of incinerator facilities should provide a characteri-
zation of the pollutants emitted. Plume dispersion modeling and monitoring
should predict and confirm the dispersion of chemicals into the atmosphere
and suggest the degree of their transfer from the atmospheric to aquatic
systems. In either case, the construction and validation of such dispersion
models depends upon measuring the toxicants in question in both the
atmosphere and in the part of the ecosystem where organism exposures
will occur.
The impact of pollutants on ecosystems is, in part, associated with
the feeding relationships that govern the transfer of materials through a
system, the properties of the medium (whether aquatic or aerial), and the
persistence of the pollutant.
Ingestion of contaminated food is an obvious mechanism by which
pollutants enter the biosphere and are transported within it. If, for
example, a fish eats algae contaminated with a chemical and retains it,
the chemical may transfer to fish-eating birds and perhaps to other
fcprganisras, including humans.
Pollution can affect the abundance of many organisms, and hence it
can indirectly affect the feeding relationships of an ecosystem by causing
either a decrease or an increase in the abundance of a particular species
or a type of food. While some pollutants have a lifetime as short as
a day as they are transformed into harmless substances, others such as
DDT and PCBs degrade very slowly.
Effects Methodology
Field measurements are necessary to assess the degree of aquatic
organism exposure from incinerator emissions and to determine their
impacts. Two existing measurement techniques include 1) chemical
monitoring, which can be used to evaluate the extent of environmental
contamination; and 2) biological monitoring, which measures the pollutant
impact upon aquatic life.
Biological effects monitoring may, in principle, be carried out at
any level of biological organization—from the ecosystem and community
to the cellular and subcellular levels—by measuring aspects of structure
and function. Measurement at higher organizational levels (for example,
community and population structure) can provide an assessment of the
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^immediate impact and recovery after an acute pollution incident or the
Pramatic long-term consequences of high levels of pollution. Although
some documentation exists on the fate and effects of specific halogenated
hydrocarbons, our understanding of pollution effects on community and
ecosystem structure and function is generally insufficient to establish
techniques for the early detection of any gradual deterioration or improve-
ment in environmental conditions. The need for sensitive measurements
of adverse biological effects of toxicants may be partially met by the
structural and functional responses at the organismal, cellular, and
subcellular levels of organization.
;Sampling in aquatic systems, especially in the ocean, is not an easy
task.: The distribution and density of biota in the sea vary extremely
both in space and time. Organisms are distributed non-randomly in patches.
Some organisms migrate vertically on a daily basis and seasonally between
shore and open water. Many larval forms, for example, migrate to the
beach or to shallow depths during maturation. Given this variability,
the probability that spot sampling will provide a representative picture
of the resident biota is slight. Indeed, the combined diluting and
dispersing effects of winds, currents, and wave action, as well as the
effect of a moving vessel, suggest that effective sampling designs will
be extremely difficult to achieve.
Given a general understanding of how ecosystems work, any assessment
of the effect of possible contaminants depends upon addressing two major
Koblems: 1) determining the bioavaliability and toxicity of the possible
ntaminants, and 2) the use of sampling to measure effects.
Effects Found to Date.
Attempts have been made to measure environmental effects during some
of the research and demonstration burns at sea. One of the studies noted
effects. In March 1977, fish (Fundulus grandis) were caged in P-BOMs
and exposed to stack emissions from the Vulcanus _!!_ which reached the
water surface at the ocean incineration site in the Gulf of Mexico.
Subsequent analyses of the livers from the exposed fish found significantly
elevated levels of cytochrome P-450 relative to controls (Pequegant et. al.,
1980), suggesting a response to the exposure. In the laboratory, the
induced levels of cytochrome P-450 returned to normal levels. Further
investigation of these findings did not occur, and thus, the ecological
significance or adverse nature of this response remains uncertain.
Conclusion:
Insufficient techniques exist to detect any gradual deterioration
or improvement in environmental quality for aquatic communities or
systems. However, laboratory studies of the acute, subacute, and chronic
toxicities of combustion products and fractions of combustion products in
surrogate and resident species are well within existing capabilities.
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Such tests, though limited in their direct applicability to aquatic
'systems, do provide information on the relative toxicity of emitted
Compounds. In addition, the capability exists to measure and to assess
pollutant effects, particularly short-term effects, on segments of the
aquatic ecosystem such as organisms residing in the surface microlayer.
.RECOMMENDATION:
EPA SHOULD CONSIDER TESTING INCINERATION PRODUCTS AND MIXTURES ,
FOR THEIR TOXICITY UPON SURROGATE AND RESIDENT SPECIES UNDER CONTROLLED
LABORATORY CONDITIONS. IT SHOULD ASSESS THE IMPACTS OF INCINERATION
PRODUCTS ON ORGANISMS INITIMATELY ASSOCIATED WITH THE SURFACE MICROLAYER.
Conclusion:
Comprehensive assessments of the impact of changes in aquatic
populations on an ecosystem require long-term observations at specific
sites. In this instance, particular attention should be given to sampling
design and statistical determinations of appropriate sample size.
RECOMMENDATION:
BECAUSE OF THE DIFFICULTIES IN ASSESSING CHRONIC EFFECTS ON THE
MARINE ECOSYSTEM, THE TASK OF UNDERSTANDING SUCH EFFECTS NEEDS TO RECEIVE
IMMEDIATE RESEARCH ATTENTION.
Conclusion:
The assessment of biological and ecological effects of incineration
products constitutes a very complex undertaking. It does not make sense
to rely exclusively on laboratory studies, partial field studies, or
complex field studies alone.
RECOMMENDATION:
THE ASSESSMENT OF THE POTENTIAL EFFECTS OF INCINERATION PRODUCTS
REQUIRES A COORDINATED APOROACH INVOLVING BOTH LABORATORY TOXICITY STUDIES
AND FIELD ASSESSMENTS. THE AGENCY SHOULD COUPLE THESE INVESTIGATIONS IN
A RESEARCH STRATEGY WHICH PAYS ATTENTION TO BOTH SHORT-TERM AND LONG-TERM
EFFECTS.
Conclusion:
The Committee found no documentation that the operation of liquid
hazardous waste incinerators at sea has produced acute adverse ecological
effects. However, monitoring programs used to date were few and narrow
in scope.
RECOMMENDATION:
Appropriately designed field studies are needed to provide assurance
that the long-term operation of incinerators does not produce significant
adverse effects to the environment.
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Chapter 9
EFFECTS ON TERRESTRIAL SYSTEMS
The information presented to the Committee indicates that the Agency
has concerns about human exposures to selected compounds which may be
emitted from incinerators and absorbed from air, drinking water, and
food. Evaluations of potential effects on wildlife, plants, and ter-
restrial ecosystems appear to be lacking. Data on the toxicities of
selected emitted mixtures likewise do not exist.
The Committee received no reports on combustion products deposited
in the surroundings of land based incinerator sites, nor any reports of
ecological surveys of plant and animal life adjacent to such sites. All
assessments were based on relatively simple computer simulations of
exposure, without some field validation.
Assessments of Potential Health Effects
The assessments of the potential impacts of emitted compounds on
human health have resulted largely from simulations which produced
projections of ground level air pollutant concentrations. The scientific
community has given wide acceptance to employing the various dispersion
models in the preparation of other air pollution assessments. However,
exposures of humans are expected to occur also through ingestion as well
as through the inhalation pathway. Exposures through food may be
particularly important for compounds with low water solubility and
high lipid solubility. A draft report by Holton et. al., (1984) hints at
the potential significance of food chain effects, even for compounds of
much lower molecular weight and lower lipid solubility than are known to
occur among the combustion products. This relatively simple model esti-
mates that food would contribute 76% to 83% of the total dose of carbon
tetrachloride delivered to humans from atmospheric releases of this
compound. On the basis of the data utilized in the model, one would
predict a much higher contribution through the food route for compounds
such as highly chlorinated PCBs.
While it may be interesting to use the Holton model to evaluate the
possible human doses from combustion products of higher molecular weights,
the primary utility of such a model seems to be that of screening the
exposures which might result from incineration activities at a number of
sites. To date, the Agency has placed excessive reliance on such simu-
lations without validating predicted concentrations with actual ambient
concentrations, nor has it adequately addressed the effects of local
topography on the model. This becomes especially important in the case
of the multiple pathway model. Because of the very nature of a multiple
pathway problem, this model consists of a number of coupled simulations,
each of which contains many simplifying assumptions. Such assumptions
invariably introduce errors into the predictions made by the model and,
at this time, it is not possible to conclude how such errors propagate in
the model relative to the actual processes in the real world.
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In the current assessment of potential impacts of incineration
emissions, the concentrations projected by the simulations are compared
to existing standards or criteria for the protection of human health.
Such standards and criteria usually embody sizable margins of safety
to protect human health.
Effects on Terrestrial Ecosystems vs. Human Responses
The general public usually assumes that environmental standards
providing adequate protection to human populations also afford sufficient
protection to the ecosystem and wildlife populations. However, such
assumptions have no scientific rationale. The reproductive physiology of
birds and some groups of mammals (e.g., the family Mustelidae) appear to
be sufficiently different from the commonly tested laboratory animals and
humans so that safety evaluations for these groups of animals are often
inadequate. Also, many predators occupy much higher positions in food
webs than do humans and, consequently, the biomagnification of some
pollutants can be much more detrimental for top predators than that
predicted for humans. Protection of human health provides no assurance
that all plant communities will receive adequate protection, and yet humans
ultimately depend upon the productivity of ecosystems. The data required
to assure the protection of human health will not automatically provide
us with insights concerning the protection of terrestrial ecosystems.
Approaches to the Measurement of Effects
When seeking to evaluate the potential of emissions from incinerators
to produce adverse human and ecological effects, three approaches, each
of which has limitations, could be tried. These include:
1. The Agency could model the risks from exposure to mixtures on
the basis of qualitative and quantitative measurements of the components
of emissions, the known toxicities on their quantitative structure/activity
relationships, and the application of appropriate interaction models. At
the present time, however, the data do not exist to input to such a model.
In addition, existing models for evaluating potential risks from single
compounds are largely unverified. Modeling of the potential toxicity of
mixtures is still in its infancy, and modeling of potential effects on
ecosystems, outside the area of bioconcentration, needs even more work.
Thus, the prime utility of modeling for this problem is as a rough
screening tool to define degree of hazard.
2. EPA could test the toxicity of incineration emissions under
controlled laboratory conditions. This type of test is also unlikely to
provide definitive answers for a number of reasons. The testing usually
occurs with surrogate or representative species either as individuals or
in small groups. Also, such tests do not readily lead to examining
effects at the population or ecosystem levels. Each mixture requires
individual testing until one has developed a picture of the variability
in responses due to changes in the mixture. Finally, one must consider
the uncertainities of extrapolating test results using models that are
difficult to verify. However, carrying out laboratory tests in concert
with field studies can have some utility in assessing the potential for
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adverse effects. Detection of subtle effects can have significant
consequences to individuals and populations. Effects on behavior and on
physiological functions often occur at exposures that are significantly
lower than those producing acute observable effects. However, there
exist a multitude of possible subtle effects, and unless one is
sufficiently astute or lucky to design a specific experiment which can
detect these biological nuances, they are easily overlooked.
Acute effects are readily observed with relatively simple protocols. •
The ratio between exposure concentrations found in controlled laboratory
tests which produce acute effects, and those which produce no measured
effects, even after exposures lasting a life-time, is rarely greater 1000
fold (NAS, 1972; McNamara, 1976; Weil et al., 1969). Thus, if a study
reports no acute effects under exaggerated exposure conditions in the
various media of concern (e.g., water, soil, air, microlayer, etc.), and
the longer term exposure concentrations after initial dilution are much
less than 1/1000 of the concentration producing no acute effects, it
becomes much more likely that no environmental effects will occur or that
they will prove very subtle.
The procedures currently available for sampling incineration emissions
are likely to yield a different mix of compounds than those found at some
distance from the source. In spite of the shortcomings of this approach,
it holds promise in testing actual mixtures. Methodologies exist which
scientists have used to test diesel exhaust emissions in mammals (NAS,
1981) and outboard motor exhaust emissions in fish (Brenniman et al.,
1976). Studies of this type can give an indication of relative toxicity
when they are employed in a comparative mode. They have some, but limited,
utility in predicting actual ecosystem level effects.
3. The EPA could undertake to study the alterations of ecosystems
or their components directly. Such studies can be very complex, even for
measurements of relatively acute effects that might occur shortly after
the exposure took place. If scientists can study the responses of the
system over longer durations, for marine systems in particular, there is
an accompanying need to develop baseline information. Land based
incinerators present more manageable problems than sea based combustion
units because the terrestrial environment is more easily sampled and more
background information exists.
Presently, computer simulations exist of possible risks to humans
from inhaled emissions in addition to possible hazards from the food web.
However, the Committee has seen no field verifications of the computer
predictions or toxicity tests for emissions from large scale land
incinerators that are located in environments already heavily disturbed
by human activites- It may be impossible and/or irrelevant to look for
subtle ecological effects in such areas except for those related to
contamination of the human food supply especially via bioconcentrative
mechanisms.
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Conclusion;
The toxicities of emissions and effluents from land based incinerators
are largely unknown.
RECOMMENDATION;
THE TOXICITIES OF REPRESENTATIVE EMISSIONS AND EFFLUENTS FROM
INCINERATORS SHOULD BE TESTED, AT A MINIMUM, IN SENSITIVE LIFE STAGES OF
REPRESENTATIVE TERRESTRIAL VERTEBRATES, INVERTEBRATES, AND PLANTS OF
ECOLOGICAL IMPORTANCE.
Conclusion:
The Committee found no documentation that the operation of
liquid hazardous waste incinerators on land has produced significant
adverse ecological effects. However, monitoring programs were few and
narrow in scope.
RECOMMENDATION:
APPROPRIATELY AMBIENT AEROMETRIC AND EFFECTS MONITORING IS NEEDED TO
PROVIDE ASSURANCE THAT THE LONG-TERM OPERATION OF INCINERATORS DOES .NOT
PRODUCE SIGNIFICANT ADVERSE ECOLOGICAL EFFECTS.
Conclusion:
The Committee has received no documentation that any significant
health hazard exists as the result of exposures to the products of
incinerating toxic wastes. However, monitoring programs were few and
narrow in scope.
RECOMMENDATION:
THE POSSIBLE LONG-TERM CONSEQUENCES TO HUMAN HEALTH OF A CONTINUING
PROGRAM OF INCINERATION NEEDS EVALUATION.
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Neely, W. B. (1980). Chemicals in the Environment. Marcel Dekker, Inc.
New York.
O'Donnell, F. R., P. M. Mason, J. E. Pierce, G. A. Holton, E. Dixon (1982).
User's guide for the automated inhalation exposure methodology (IEM).
Oak Ridge National Laboratory, TN.
Patil, S. A. (1982). Pollution and the Biological Resources of the Ocean.
Butterworth Scientific.
Raynor, G. S., P. Michael, R. M. Brown, S. SethuRaman (1975). Studies of
atmospheric diffusion from a nearshore oceanic site. J. Appl.
Meteorol. 14(6):1080-1094.
Raynor, G. S., R. M. Brown, S. SethuRaman (1978). A comparison of diffusion
from a small island and an undisturbed ocean site. J. Appl.
Meteorol. 17:2.
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-------
Reinert, R. E. (1970). Pesticide concentrations in Great Lakes fish.
Pesticid. Monit. J. 3(4):233-240.
Stumm, W. and J. J. Morgan (1981). Aquatic Chemistry. J. Wiley & Sons;
New York.
Smith, M. E. (1984). Review of the attributes and performance of 10 rural
diffusion models. Bull. Amer. Meteorol. Soc. 65(6):554-558.
Travis, C. , E. Etnier, G. Holton, F. O'Donnell, D. Hetrick, E. Dixon,
E. Harrington (1984). Inhalation Pathway Risk Assessment of
Hazardous Waste Incineration Facilities. Oak Ridge National
Laboratory/TM-9096. October 1984.
Trenholm, A., P. Gorman, G. Jungclaus, (1984). Performance Evaluation
of Full-Scale Hazardous Waste Incinerators. 5 Vols. EPA 600/2-
84-181a,b,c,d,e. November 1984. Available NTIS only. PB 85
129500,-18,-28,-34,-42.
Trenholm, A., R. Hattaway, D. Oberacker, (1984). Products of Incomplete
Combustion From Hazardous Waste Incinerators, in Proceedings of
10th Annual Research Symposion on Incineration and Treatment of
Hazardous Waste. EPA 600/9-84-022 September 1984.
Van Vleet, E. S. and P. M. Williams (1980). Sampling sea surface films:
a laboratory evaluation of techniques and collecting methods.
Liranol. Oceanogr. 25:764-770.
Van Vleet, E. S. and P. M. Williams (1982). Surface potential and film
pressure measurements in sea water systems. Lirnnol. Oceanogr.
28:401-414.
Veith, G. D., D. W. Kuehl, F. A. Puglisi, G. E. Glass, J. G. Eaton
(1977). Residues of PCB's and DDT in the western Lake Superior
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Weil, C. S., M. D. Woodside, J. R. Bernard, and C. P. Carpenter (1969).
Relationship between single-peroral, one week, and ninety day rat
feeding studies. Toxicol. & Appl. Pharnacol. 14:426-431.
Wiebe, P. H. , S. H. Boyd, C. Wiget (1976). Participate matter sinking.
Deep-Sea Res. 5:205-208.
Zaitsev, Y. P. (1971). Marine Neustonology. Israeli Prog. Sci. Transl.;
Jerusalem.
Zannetti, P., D. Wilbur, R. Baxter, (1981). Southern California Offshore
Air Quality Model Valldaton Study, Vol. II - Synthesis of Findings.
Bureau of Land Management, Contract // AA851-CTO-56. Prepared by
AeroVironment, Inc. Monrovia, CA. November 1981.
- 3 -
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APPENDIX I
ENVIRONMENTAL EFFECTS, TRANSPORT & FATE COMMITTEE
SCIENCE ADVISORY BOARD
U. S. ENVIRONMENTAL PROTECTION AGENCY
Dr. Rolf B. Hartung, Chairman
Professor, Environmental
and Industrial Health
University of Michigan
Ann Arbor, MI A8109
Dr. Terry F. Yosie, Director
Science Advisory Board
U.S. Environmental Protection
Agency
Washington, D.C. 20460
Dr. Douglas B. Seba
Executive Secretary
Environmental Effects, Transport
and Fate Committee
Science Advisory Board
U.S. Environmental Protection
Agency
Washington, D.C. 20460
Members/Consultants
Dr. Martin Alexander
Professor
Department of Agronomy
Cornell University
Ithaca, NY 14853
Dr. Walter Dabberdt
SRI International
333 Ravenswood Avenue
Menlo Park, CA 94025
Mr. Italo Carcich
Bureau of Water Research
New York Department of
Environmental Conservation
Albany, New York 12233
Dr. Melbourne R. Carriker
Professor of Marine Science
College of Marine Studies
University of Delaware
Lewes, DE 19958
Dr. Kenneth Dickson
North Texas State University
Institute of Applied Sciences
Denton, TX 76203-3078
Dr. Wilford R. Gardner
Head, Department of Soils,
Water and Engineering
University of Arizona
Tucson, AZ 85721
Mr. Allen Cywin*
1126 Arcturus Lane
Alexandria, VA 22308
Mr. George Green*
Public Service Company of
Colorado
Post Office Box 840, Room 820
Denver, CO 80202
Representative of SAR Environmental Engineering Committee
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Dr. Leonard Greenfield
1221 Columbus Boulevard
Coral Gables, FL 33134
Dr. John 1,1
Envlronmen^'
3660 Gentll
New Or lean*
Dr. George Hidy*
Desert Research Institute
7010 Dandine Boulevard
Reno, NV 89512
Dr. John Nt
Department}
College of
Utah State1
Logan, Utal
Dr. Charles Hosier
Penn. State University
Professor of Meterology
College of Earth & Mineral
Sciences
University Park, PA 16802
Dr. Charlet
4958 Escot*
Woodland HJ
Dr. Robert Huggett
College of William and Mary
Chairman, Department of
Chemical Oceanography
Virginia Institute of
Marine Science
Gloucester Point, VA 23062
Dr. Bernarj
Professor t
Department
University
Athens, GA
Dr. Kenneth Jenkins
Professor of Biology
California State University
at Long Beach
Long Beach, CA 90804
Dr. Tony P;
Department
Ohio State.
Columbus, t
Dr. Elizabeth Kay
Department: of Zoology
University of Hawaii
Honolulu, Hawaii 96822
Dr. James Kittredge
University of Southern California
Marine and Freshwater Biomedical
Center
Terminal Island, CA 90731
Dr. James ',
C/0 E31 ;
Post Offic1
East Cambi
* Representative of SAB Environmental Engineering Comnittei
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APPENDIX II
Charge to Che Environmental Effects^ Transport and Fate Committee
on Incineration of Hazardous Wastes
At the October 13, 1983 meeting of the Executive Committee of
the Science Advisory Board the Administrator formally requested
that the Board assist the Agency in the scientific assessment of
environmental impacts associated with the incineration of hazardous
wastes at sea. The Executive Committee accepted this request and
assigned the responsibility for carrying out this review to its
Environmental Effects, Transport and Fate Committee.
At the Executive Committee meeting on April 12, 1984, the Deputy
Administrator asked the Committee to also examine the environmental
impacts associated with land based incineration of liquid hazardous
wastes, and to make a generic comparison of scientific issues between
land based and ocean based incineration. The Committee accepted this
additional request. The Environmental Effects, Transport & Fate
Committee will expand its review and will address the six issues
listed below.
The following have been identified as issues the Committee
should consider in evaluating incineration of hazardous wastes at
sea. The Committee should advise if the Agency has considered and
interpreted in a scientifically adequate manner the appropriate
data for each area.
1) Transfer of wastes.
What are the various handling, loading, transportation, and routing
problems? What potentials exist for collisions, explosions, and spills?
Should the Agency develop worst-case scenarios to evaluate the potential
impacts of accidental discharges?
2) Combustion and Incineration Processes.
Is the efficiency of destruction properly addressed? Are the
quantitative and qualitative characteristics of the combustion products
released into the environment appropriately evaluated?
3) Stack and Plume Sampling.
What specialized sampling protocols are needed to adequately
characterize representative emissions from the stack exhaust and plume?
4) Environmental Transport and Fate Processes.
How should known and modeled atmospheric and oceanic circulations
at the barn sites be considered? Are potential food web Influences
adequately assessed?
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5) Biological Effects.
Do data on incineration efficiency, composition of emission products,
and environmental transport and fate processes provide an adequate basis
for evaluating biological effects? Have other issues, such as the
bioavailability and toxicity of emitted compounds, been adequately
addressed?
6) Research Needs.
What key scientific issues should the Agency address in its
incineration research strategy?
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APPENDIX II[
These documents were received and reviewed by the Environmental
Effects, Transport, and Fate Committee during the preparation of
this report. All documents are available for public review
in the offices of the Science Advisory Board.
Abkowitz, Mark, Amir Eiger, Suresh Srinivasan. Final Report
on Assessing the Releases and Costs Associated with Truck
Transport of Hazardous Wastes, January 1984.
Ackerraan, D. G., to Donald Oberacker, EPA, Incineration
Research Branch, regarding the research burn of PCBs by the
Vulcanus, July 2, 1982.
Ackerman, D. G., R. G. Beimer, and J. F. McGaughey. Report
on Incineration of Volatile Organic Compounds on the M/T
Vulcanus II. TRW Energy and Environmental Division,
April 1983.
Apollo incinerator ship construction diagrams. -At Sea
Incineration, Inc., July 7, 1984.
Arent, Fox, Kintner, Plotkin and Kahn. Letter to Jack Ravan,
regarding Comments of the Central States, Southeast and
Southwest Areas Pension Fund on the tentative decision to
issue Permit Nos. HQ83-001-3. January 31, 1984.
Barnard, Bill. Letter to the Director of Research, regarding
OTA's Assessment of Technologies for Disposing of Waste in
the Ocean, July 19, 1984.
Barrett, Kris et. al. A Users Manual, Uncontrolled Hazardous
Waste Site Ranking System, MITRE Corporation., August 1982.
Bond, Desmond. Letter to Patrick Tobin, EPA, Office of Water
Regulations and Standards, January 30, 1984, Testimony of
Desmond H. Bond: Proposed Incineration-At-Sea Permits,
HQ 83001-3.
Bond, Desmond, 1984. At Sea Incineration of Hazardous Wastes,
Environmental Science and Technology, Vol., 18, No. 5.
Chapman, 0., et. al., 1982. Chemical Waste Incinerator Ships:
The Interagency program to Develop a Capability in the
United States. Marine Technology, Vol. 19, pp. 325-340.
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Chemical and Engineering News. Ultrasound Speeds Electrolysis
of PCBs, 1984 Annual Meeting, September 10, 1984, p. 39.
Chemical Waste Management, Inc. Transportation Department,
Oak Brook, Illinois, Transportation Plan for the Highway
Movement of Liquid Halogenated Organic Wastes From Emelle,
Alabama to Chickasaw, Alabama to Support Vulcanus Ocean
Incineration Program, November, 1983.
Chemical Waste Management, Inc. Statement of the Basis for
Issuance of Ocean Incineration Permits for the M/T Vulcanus
I and M/T Vulcanus II, Oak Brook, Illinois, January 31,
1984.
Chemical Waste Management, Inc. Insurance Policies in Effect
for the M/T Vulcanus I and M/T Vulcanue II as of January
31, 1984, Oak Brook, Illinois.
Chemical Waste Management, Inc. Response to Public Comments
on Draft Ocean Incineration Permists for the M/T Vulcanus I
and M/T Vulcanus II, January 3l, 1984.
Chemical Waste Management, Inc., and Ocean Combustion Service,
(1984). Contingency Plan for The Ocean Incineration
Operations of the Vulcanus I and Vulcanus II.
Conpaan, H., 1982. Monitoring of Combustion Efficiency,
Destruction Efficiency and Safety During the Test Incineration
of PCB Waste, sponsored by Ocean Combustion Service.
Davies, Tudor. Memorandum to EPA Personnel Office regarding
Participation in the Development of a Comprehensive Research
Plan on Ocean Incineration, July 3, 1984.
Edwards, Robert J. Letter to Alan Rubin regarding monitoring
results and environmental impact on the Gulf of Mexico
incineration site from the incineration of PCB's under
research permit HQ 81002. April 1983, June 9, 1983.
Environmental Protection Agency, 1975. Disposal of Organochlorlne
Wastes by Incineration At Sea (EPA-430/9-75-014).
Environmental Protection Agency. Environmental Impact Statement,
Designation of a Site in the Oulf of Mexico for Incineration
of Chemical Wastes, July 1976.
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Environmental Protection Agency. Federal Register Notice,
Ocean Dumping, Final Revision of Regulations and Criteria,
January 11, 1977, Part VI.
Environnental Protection Agency. Proposed Revisions to Ocean
Dumping Criteria, Final Environmental Impact Statement,
Volume II, January 31, 1977.
Environmental Protection Agency, 1977.
of Organochlorine Wastes Onboard the
(EPA-600/2-77-196).
At Sea Incineration
M/T Vulcanus
Environmental Protection Agency. At Sea Incineration of
Herbicide Agent Orange Onboard the M/T Vulcanus, Industrial
Environmental Research Laboratory, April 1978.
Environmental Protection Agency, Department of Transportation
and Department of Commerce. Report of the Interagency
Ad Hoc Work Croup for the Chemical Waste Incinerator Ship
Program, September 1980.
Environmental Protection Agency. Incineration of PCBs Summary
of Approval Actions. Energy Systems Company (ENSCO) El
Dorado, Arkansas, February 6, 1981.
Environmental Protection Agency. Incineration of P-CEs Summary
of Approval Actions, Rollins Environmental Services, Deer
Park, Texas, February 6, 1981.
Environmental Protection Agency. Report on Evaluation of PCB
Destruction Efficiency in an Industrial Boiler, April
1981, Industrial Environmental Research Laboratory, Research
Triangle Park, North Carolina.
Environmental Protection Agency. Environmental Impact Statement
(EIS) for North Atlantic Incineration Site Designation,
December 1981.
Environmental Protection Agency. Report on At Sea Incineration
of PCB-Containing Wastes Onboard the M/T Vulcanus, Industrial
Environmental Research Laboratory. April 1983.
Environmental Protection Agency. Project Summary on User's
Guide for the Automated Inhalation Exposure Methodology
(IEM), Industrial Environmental Research Laboratory, June
1983,
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Environmental Protection Agency. Monitoring Plan for the
North Atlantic Incineration Site, September 14, 1983.
Environmental Protection Agency. Gulf of Mexico Incineration
Site Baseline Survey, September 15, 1983.
Environmental Protection Agency. Project Summary: Fates and
Biological Effects of Polycyclic Aromatic Hydrocarbons
In Aquatic Systems, Environmental Research Laboratory,
Athens, GA, November 1983.
Environmental Protection Agency. Fugitive Emissions Sampling
at Four Hazardous Waste Incinerators, December 12, 1983.
Environmental Protection Agency, 1983. At Sea Incineration of
PCBContaining Wastes Onboard the M/T Vulcanus
(EPA-600/7-83-024).
Environmental Protection Agency, 1983. TCDD (Dioxin) Mass Release,
Total release for three year permit.
Environmental Protection Agency, 1984. Response to Public
Comments, on the Oct. 17, 1983 EPA tentative determination
to issue special and research permits to Chemical Waste
Management, Inc., Oak Brook, Illinois, and Ocean Combustion
Services, N. V. Rotterdam, the Netherlands (the Applicants)
for the M/T Vulcanus I and M/T Vulcanus II to Incinerate nixed
liquid organic compounds and liquid DDT wastes at the Gulf
Incineration Site as authorized by the Marine Protection,
Research, and Sanctuaries Act of 1972 (MPRSA), as amended.
Environmental Protection Agency. Protocol for the Collection
and Analysis of Volatile POHCs Using VOST [Volatile Organic
Sampling Train], Industrial Environmental Research Laboratory,
Research Triangle Park, North Carolina, March, 1984.
Environmental Protection Agency. EPA Makes Public Recommendations
on Ocean Incineration Permits, Environmental Hews, April
23, 1984.
Environmental Protection Agency. Decision on application
by Chemical Waste Management and Ocean Combustion Services,
N.V. , for the M/T Vulcanus I and M/T Vulcanus II to Incinerate
nixed liquid organic compounds and liquid DDT wastes at
the Gulf of Mexico Site, May 1984.
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Environmental Protection Agency. Draft report on EPA's Regulatory
Approach for Incineration, Office of Management Systems
Evaluation, Program Evaluation,
June 22, 1984.
and
Environmental Protection Agency.
Research Plan, August 1984.
Draft report on Ocean Incineration
Environmental Protection Agency, 1984. MRI Performance Evaluation
of Full-Scale Hazardous Waste Incinerators, Volume II and IV,
Appendices C Through J.
Environmental Protection Agency. Appendix A, The Monitoring Plan
for the Research Burns of the Vulcanus I and Vulcanus II at
the Gulf of Mexico Incineration Site.
Environmental Protection Agency and the Department of State,
Statement: Financial Environmental Impact Statement to
Mr. William Mansfield III, Office of Environmental Affairs.
Environmental Protection Agency, 1984. Report on Proposed Ocean
Incineration Regulation.
Environmental Protection Agency, 1984. Ocean Incineration Research
Plan, Charge to the Scientific Working Group..
Environmental Protection Agency, 1984. Mobile Incinerator, A System
Designed for Destruction of Hazardous Waste.
Environmental Protection Agency. Monitoring Plan for the Gulf of
Mexico Incineration Site, draft #3, January 1984.
Environmental Protection Agency. Frank Freestone, Chief, Hazardous
Spills Staff, Oil f* Hazardous Materials Spills Branch to Henry
Thacker, Waste Management Division, Office of Environmental
Engineering and Technology, regarding Draft Research Plan for
EPA's Mobile Incineration System and Mobile Soils Washing System
dated February 21, 1984.
Freestone, Frank. Letter to Henry Thacker regarding Draft Research
Plan for EPA's Mobile Incineration System and Mobile Soils
Washing System, Febraury 21, 1984.
Fortuna, Richard C. Same Wastes, New Solutions.
Treatment Council. January 31,. 1984.
Hazardous Waste
Cielen, J. W. J. and H. Compaan. Monitoring of Combustion Efficiency
and Destruction Efficiency During the Certification Voyage of
the Incineration Vessel "Vulcanus II," January 1983.
Graddick, Charles A. Attorney General, State of Alabama, to
William Ruckleshaus, EPA Administrator, dated November 4,
1983, regarding Proposed EPA special and research permits for
the M/T Vulcanus I & II under the Marine Protection Research
and Sanctuaries Act.
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Graddick, Charles A., 1984. Letter to Mr. Willlara Ruckelshaus
regarding Notice of Violation and Intent to Commence Civil
Action related to M/T Vulcanus 1 & II Permits, November 15,
1983.
Graddick, Charles A. and R. Craig Kneisel. Letter to Steven
Sr.hatzow, regarding Inclusion of Documents and Comments in
the Hearing Record on Ocean Dumping Permits for the M/T
Vlucanus I & II, January 30, 1984.
Gregory, Robert. Vice President-Technical Director, Rollins
Environmental Services, Inc., to Dr. Douglas Seba, Science
Advisory Board staff, dated June 20, 1984 regarding data
on stack gas sampling and analysis in connection with
hazardous waste land-based incinerators.
Grey, Vincent. Letter to Patrick Tobin, Comments and
documents on Ocean Dumping' Permit Program listed in the
Federal Register, October 21, 1983; January 30, 1984.
Grey, Vincent. Letter to William Ruckelshaus, regarding
Proposal for a Shipboard Incineration R & D Program,
April 25, 1984.
Grey, Vincent. Letter 1984 to William Ruckelshaus, regarding
Proposal for a Shipboard Incineration R & D Program, June
18, 1984.
Groat, Charles G. Letter to Patrick Tobin, regarding Proposed
Permits, HO 83-001 - 3 Incineration-at-Sea. January 23, 1984.
Gulf Coast Coalition for Public Health, 1983. Toxic Waste
Incineration in the Gulf of Mexico Fact Sheet.
Guste, William J. Letter to Honorable William Ruckelshaus,
regarding permits for at sea incineration in two ships,
Vulcanus I & II, January 23, 1984.
Guttman, Michael A., Norman W. Flynn, and Robert F. Shokes.
Ambient Air Monitoring of the M/T Vulcanus PCB Incineration
at the Gulf of Mexico Designated Site, August 1982.
Hernandez, Emilio. Letter to Mr. Patrick M. Tobin, November
19, 1983.
Hunt, G. T., P. Wolf and P. Fennelly, 1983. Incineration of
Polychlorinated Biphenyls in High-Efficiency Boilers: A
Viable Disposal Option. Environmental Science and Technology
Vol 18, pp. 171-9.
Hustvedt, Kent C. Letter to Walter Barber regarding
the Chemical Waste Management's facility, June 8, 1984.
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ICF Incorporated. Report on The RCRA Risk-Cost Analysis
Model Phase III March 1, 1984.
Johnson, L., R. E. Adams, R. H. James, L. A. Burford, H. Miller.
1982. Analytical Methods for Determination of POHC in
Combustion Products, Draft.
Johnson, L., R. James, R. Adams, J. Finkel, H. Miller.
Evaluation of Analytical Methods for the Determination of
POHC in Combustion Products. Presented at the Eighth
Annual Research Symposium on Land Disposal, Incineration
and Treatment of Hazardous Waste, Ft. Mitchell, KY,
March, 1982.
Jackson, Merrill D., L. Johnson, and R. Merrill, Jr., M. Cooke,
A. DuRoos, and B. Rising. Report on Dioxin Collection
from Hot Stack Gas Using Source Assessment Sampling System
and Modified Method 5 Trains—An Evaluation. Presented at
Ninth Annual Research Symposium on Land Disposal, Incineration,
and Treatment of Hazardous Waste, Ft. Mitchell, Ky., March, 1983.
Johnson, L. Development of a Volatile Organic Sampling
Train (VOST). Presented at Ninth Annual Research Syraposuim
on Land Disposal, Incineration, and Treatment of Hazardous
Waste, Ft. Mitchell, Ky, March, 1983.
Johnson, L. and R. Merrill, 1983. Stack Sampling for Organic
Emissions, Toxic and Environment Chemical. Vol. 6:109-126.
Johnson, L. Development of the Volatile Organic
Sampling Train (VOST) for Use in Determining Incinerator
Efficiency. Presented at the Fourth ASTM Symposuim on
Hazardous and Industrial Solid Waste Testing, Arlington,
Va; May, 1984.
Josephson, Julian. Hazardous Waste Research, Environmental
Science and Technology, Vol 18, No. 7, 1984.
JRB Associates. Draft report on Ambient Air Monitoring
of the August 1982 M/T Vulcanus PCB Incineration at the
Gulf of Mexico Designated Site by Guttman, Flynn, and
Shokes, January 7, 1983.
JRB Associates. Final Report on Permissible Metal,
PCB, and TCDD (Dioxin) Concentrations in In-cineration
Waste Material September 26, 1983.
JRB Associates. Report on Worst Case Scenarios for
Spillage of PCB's At Sea, and Transport of Stack Gas Over
Land, October 12, 1983.
JRB Associates. pinal Report on Expanded Modeling of
Incineration at Sea Impacts: Gulf of Mexico, June 1, 1984,
Kleppinger, Edward W., Desmond H. Bond. Ocean Incineration
of Hazardous Waste: A Critique, EWK Consultants, Inc.,
April 14, 1983.
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Kleppinger, Edward W. Letter to Patrick M. Tobin, regarding
Comments on EPA Notice of Tentative Determination to Issue
Ocean Incineration Permits HQ 83-001-3. January 31, 1984.
Kramlich, C., M. P. Heap, J. H. Pohl, E Poncelet, G. S. Samuelsen,
W. P. Seeker, 1982. Laboratory Scale Flame-Mode Hazardous
Waste Thermal Destruction Research, Energy and Environmental
Research Corp.
Little, Arthur D. Sampling and Analysis Methods for
Hazardous Waste Combustion, First Edition, December, 1983.
Males, Eric., 1984. Letter to Raymond Loehr regarding outputs from
the EPA Risk-Cost Policy Model.
Metzger, J.F. and D.G. Ackerman. A Summary of Events,
Communications, and Technical Data Related to the At-Sea
Incineration of PCB-Containing Wastes Onboard the M/T
Vulcanus, Dec. 20, 1981 to Jan. 4, 1982, March, 1983.
Mollingsworth, B. F. Letter to Patrick M. Tobin, Comments on
Ocean Incineration Permit Program Notice, January 27, 1984
Midwest Research Institute. Trial Burn Protocol Verification,
Performance Evaluation, and Environmental Assessment of
the Cincinnati Metropolitan Sewer District (MSD) Hazardous
Waste Incinerator, March, 1982.
Midwest Research Institute. Report on Trial Burn
Protocol Verification at a Hazardous Waste Incinerator,
Final Report, August 2, 1982.
Midwest Research Institute. Summary of Results from Testing
at the Upjohn Incinerator, Draft Report, March 4, 1983.
Midwest Research Institute. Summary of Results from
Testing at The American Cyananid Incinerator, Draft Report,
April 5, 1983.
Midwest Research Institute. Summary of Results from
Testing at the Mitchell Systems Incinerator, April 15, 1983.
Midwest Research Institute. Summary of Results from
Testing at the Du Pont Incinerator, April 18, 1983.
Midwest Research Institute, 1983. Summary of Results from Testing
at the Zapata Incinerator, Draft Report.
Murphy, Richard. General Comments on Incineration, At Sea Baseline
Studies and the Biological Monitoring Program. May 7, 1984.
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National Research Council, 1983. Management of Ha:
Industrial Wastes, Research and Development Nee^ission
on Engineering and Technical Systems, National lig
Advisory Board.
Neighbors, M. L. Letter to Alan Rubin, regarding s.
Need to Dispose of Organochlorine Waste Materia^an
Incineration, May 6, 1983.
Oak Ridge National Laboratory. Inhalation Pathway
Assessment of Hazardous Waste Incineration Facil
Ja nua ry, 1984.
Oak Ridge National Laboratory* Multiple-Pathways Kg-
Level Assessment of A Hazardous Waste Incinerat$lity,
April, 1984.
Oberacker, Don, Ben Smith, Paul Gorman, and Andrew i,m. ,
Particulate and HC1 Emissions from Hazardous Wat
Incinerators in Proceedings of 10th Annual Reseaiposium
on Incineration of Hazardous Waste. EPA 600/9-i
Spetember 1984.
Pecuegnat, Willis E. Letter to Dr. Alan Rubin, EPAe
of Water, Criteria and Standards Division, regai'B
Incinerations at the Gulf of Mexico Incineration
September 12, 1983.
Quarles, John, et. al. Letter to Patrick Tobin, re
Comments of Rollins Environmental Services, Inc.
tentative determination by the EPA to issue spec
research permits for the incineration of chemicas
at sea, January 31, 1984.
Ravan, Jack. Memorandum to the Administrator of EPding
Research Plan for Incineration at Sea, June 22,
Roberts, Alan. Letter to Patrick Tobin, regarding rtation
Plan for the Highway Movement of Liquid Halogenaanic
Wastes from Emelle, Alabama to Chickasaw, Alabam
Support Vulcanus Ocean Incineration Program, Feb4,
1984.
Robertson, Charles L. Letter to Dr. Edward Kleppin
regarding incineration of DDT, November 15, 1983.
SCA Chemical Services, 1984. Brochure of the facilfhe
Chicago Incineration Facility.
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Schatzow, Steven. Letter to Frederic Eidsness, Jr.,
regarding Incineration of Hyde Park Boulevard Landfill
Leachate on Vulcanus I during Decemeber 1981, Chronology
and Summary, -January 1982.
Schatzow, Steven. Hearing Officers' Report on the
Tentative Determination to Issue Special Ocean Incineration
Permits and a Research Permit to Chemical Waste Management,
Inc. and Ocean Combustion Services, NV, April 23, 1984.
Schofield, W. R. , memorandum to Dr. Douglas Seba April 9,
1984, enclosing the following reports:
J. M. Huber PCS Destruction Process Trial Burn Report;
Huber Technology Fluid-Wall (HTFW) Reactor, Technical Bulletin;
Chemical Engineering, April 2, 1984, report on Mobile Reactor*
Destroys Toxic Wastes in "space."
Schofield, W. R. Letter to Dr. Douglas Seba, EPA,
regarding a TSCA permit to treat PCB contaminated soils
in their 12-inch Advanced Electric Reactor (AER) in Borger,
Texas, July, 1984.
Simone, Gary S. Letter Dr. Douglas Seba, regarding
At-Sea Incineration, Inc. (ASI), August 15, 1984.
Spaw, Steve. Report on Air Sampling for PCB's Along the Texas
Gulf Coast During Incineration Operations Conducted by the
M/T Vulcanus, May 12, 1983.
Spaw, Steve. Report: Texas Air Control Board Staff Position
Paper on At-Sea Incineration Operations in the Gulf of
Mexico, January 26,.1984.
Spigarelli, Janes L. Letter to Timothy Oppelt, regarding
characterizing organic emissions from a selected hazardous
waste incinerator, July 25, 1984.
Stephan, David. Letter to Patrick Tobin, regarding
Recommended Operating Parameters, Past Performance Reliability
Considerations, and Similarity Considerations for Vulcanus I
and II, August 10, 1983.
Stern, David et. al. Speciation of Halogen and Hydrogen
Halide Compounds in Gascons Eissions, presented at the
Ninth Annual EPA Hazardous Waste Research Symposuim,
Cincinnati, Ohio, May 2, 1983.
TERECO Corporation. Biological Monitoring of PCB
Incineration at the Designated Site in the Gulf of Mexico,
October, 1982.
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Tobin, Patrick, 1984. Draft Ocean Incineration Regulation,
September 7, 1984.
Velde, George Vander. Letter of May 12, 1983 to Dr. Alan
Rubin.
Velde, George Vander, Letter to Dr. Douglas Seba, dated
April 13, 1984. Including two documents: Incineration of
Volatile Organic Compounds on the M/T Vulcanus II,
April 1983. History of Environmental Testing of the
Chemical Waste Incinerator Ships M/T Vulcanus and I/V
Vulcanus II, June 1983.
Velde, George Vander, 1984. At-Sea Incineration of Wastes,
Environmental Science and Technology Vol. 18, p. 263A.
Versar, Inc. .Case Study Visit Report for Metropolitan
Sewer District of Greater Cincinnati, Liquid Fluid Incinerator,
May 18, 1984.
Westat, Inc. National Survey of Hazardous Waste Generators
and Treatment, Storage and Disposal Facilities Regulated
Under RCRA in 1981.
Whitney, Scott C. Letter to Steven Schatzow, regarding
Chemical Waste Management's pending applications for
ocean dumping permits, April 22, 1983.
Whitney, Scott C. Letter to Steven Schatzow, including
The Capability of Oceanic Incineration - A Critical Review
and Rebuttal of the Kleppinger Report, May, 1983.
Whitney, Scott C., 1983. Letter to Steven Schatzow, Comments
on Notice of Tentative Determination to Issue Special and
Research Permits for Incineration of Chemical Wastes at
Sea, Nov. 15, 1983.
Whittlesey, Dennis J. Letter to Patrick Tobin, regarding
Tentative Determination to Issue Special and Research
Permits to Chemical Waste Management, Inc., January 31, 1984.
Zaelke, Durwood J. Letter to Mr. William Ruckelshaus,
Notice of Violation of Marine Protection, Research and
Santuaries Act; Marine Protection, Research and Sanctuaries
Act Permits HQ 83-001 - 3, November 9, 1983.
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