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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                                   -i-
                                  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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                                   - 8 -
                                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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                                  - 9 -
     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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                                   - 10 -
     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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                                  -  11 -
                                 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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                                  - 12 -
     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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                                  -  13 -
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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                                  - 14 -
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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                                   -  15  -

                                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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                                   -  17  -
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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                                  - 18 -

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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                                  - 19 -
     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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                                  - 20 -
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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                                  -  21 -
     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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                                  - 22 -
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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                                  - 23 -


                                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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                                  -  24 -
     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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                                  - 25 -


                                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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                                  - 26 -
     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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                                  - 27 -
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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                                   -  28  -
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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                                  - 29 -
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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                                  - 30 -
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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                                  - 31 -

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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                                  - 32 -


                                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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                                    - 33 -
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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                                     - 34  -
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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                                    - 35 -

     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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                                    - 36 -

     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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                                    -  37 -
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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                                  -  38 -


                                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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                                  - 39 -
     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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                                   -  40  -
     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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                                   - 41 -


                                 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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                                   - 42 -
^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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                                   - A3 -
 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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                                  - 44 -


                                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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                                   - 45 -
     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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                                  - 46 -
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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                                  - 47 -
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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                                REFERENCES

Ackerman, D., H. Fisher, R. Johnson, R. Maddalone,  B. Matthews  (1978).
     At-Sea  Incineration of Herbicide Orange On-Board the M/T Vulcanus.
     EPA600/2-78-086.

Bernhard, M.  (1981).  Heavy metals  and chlorinated  hydrocarbons  in  the
     Mediterranean.  In:  Marine Environmental  Pollution.   R. A.  Geyer,  ed.
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Bidleman, T.  R. , C. P. Rice,  C. E.  Oleny  (1976).  High molecular weight
     hydrocarbons in the air  and sea:  rates and mechanisms  of  air/sea
     transfers.  In:  Marine  Pollutant Transfer.  H. L. Windom  and
     R. A. Duce, eds.  D. C.  Heath  & Co.

Brenniman, G., R. Hartung, W. J. Weber, Jr.  (1976).  A continuous flow
     bioassay method to evaluate the effects of outboard motor  exhausts
     and selected aromatic toxicants on fish.  Water Research 10(12):
     165-169.

Dabberdt, W.  F. , R. Brodzinsky, B.  C. Cantrell, R.  E. Ruff  (1982).
     Atmospheric dispersion over water and in the shoreline  transition
     zone, Vol. 1: analysis and results.  SRI Project 3450  for  American
     Petroluem Institute, Task Force on Outer Continental Shelf  Emissions.
     Washington, D.C.     . .

Dabberdt, W.  F. , W.'B. Johnson, R.  Brodzinsky, R. E. Ruff. (1984).   Central
     California coastal air quality model, validation study:  data  analysis
     and model evaluation.  SRI Project 3868 for: U.S.D.I.,  Minerals
     Mgmt. Service; Contract  14-12-0001-19114.  Los Angeles, CA.

Environmental Protection Agency (1976).   Environmental Impact Statement
     (EIS),  Designation of a  Site in the  Gulf of Mexico for  Incineration
     of Chemical Wastes, July 1976.

Environmental Protection Agency (1981).   Environmental Impact Statement
     (EIS),  for North Atlantic Incineration Site Designation, EPA
     440/5-82-025.

Fox, Dennis  L., John D. Isaacs, Eugene F. Corcoran  (1952).   Marine
     Leptopel, Its Recovery, Measurement  and Distribution. J. Mar.
     Res. 11:29-46.

Gorman, P.,  K. P. Ananth (1984).  Trail Burn Protocol Verification  at a
     Hazardous Waste Incinerator.   EPA 600/2-84-048.  February  1984.

Haile,  C. L., G. D. Veith, G. F. Lee, W.   C. Boyle (1975).  Chlorinated
     hydrocarbons in the Lake Ontario ecosystem.  U.S. EPA Report
     EPA-660/3-75-022.

Hamelink, J. L., R. C. Waybrant, R. C. Ball (1971).  A proposal:  exchange
     equilibria control the degree  chlorinated hydrocarbons  that  are
     biologically magnified in lentic environments. Trans Amer.  Fish.
     Soc. 100(2):207-214.

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Hanna, S. R., L. Schulman, R. Paine, J. Tleim  (1984).   Users  Guide  to  the
     Dispersion  (OCD) Model; Appendix A:   Survey  of  Over Water  and  Coastal
     Experiments and Models of Atmospheric Transport and Diffusion,  Minerals
     Management  Service Contract  # 41-08-0001-21138. Prepared by
     Environmental Research and Technology, Inc.,  Concord,  MA.
     September 1984.

Henrichs, S. M. and P. M. Williams (in press).  Dissolved and particulate
     araino acids and carbohydrates in the  sea  surface raicrolayer.
     Mar. Chera.

Hinga, K. R. , J. M. Sieburth, G.  R. Heath  (1979).  The  supply and use  of
     organic material at the deep sea floor.   J.  Mar. Res.  37:537-576.

Holton, G. A., C. C. Travis, E. L. Etnier, F.  R.  O'Donnell, D.  M. Hetrick,
     E. Dixon (1984).  Multiple-pathways screening-level assessment  of
     a hazardous waste incineration facility.  ORNL  Draft Report ORNL/TM-
     8652 under U.S. Dept. of Energy Contract  AC05-840R21400.

JRB Associates (1984).  Expanded  modeling  of incineration at  sea impacts:
     Gulf of Mexico.  U.S. EPA, Criteria and Standards  Div. ;  EPA Contract
     68-01-6338 WA 65.  Washington, D.C.

McNamara, B. P.-  (1976).  Concepts in health evaluation  of commercial and
     industrial  chemicals, Chapt. 4; in:  New  Concepts  in Safety Evaluation.
     M. Mehlmari et al. , eds. Hemisphere Publ. , Washington,  D.'C.

National Academy of Sciences (1972).  Water Quality  Criteria  1972.
     U.S. Gov't. Printing Office. (S.N. 5501-00520).

National Academy of Sciences (1981).  Health Effects of Exposure to Diesel
     Exhausts.  National Academy  Press.  Washington, D. C.

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.

                                  - 2 -

-------
 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
      ecosysten.   Arch.  Environ.  Contain.  & Toxicol.  5:487-499.

 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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                                     - 2 -
 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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                                - 2 -
     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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                            - r/2 -
 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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                            - r/3 -
 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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                            - r/4  -
 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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                              - r/5 -
 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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                           - r/6 -
 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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                            - r/7 -

 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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                            - r/8 -
 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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                             - r/9
 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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                            - r/10 -


 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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                            - r/11 -
 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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