United States Office of Policy, March 1985
Environmental Protection Planning and Evaluation
Agency Washington, DC 20460
PoNcy Planning and Evaluation
vvEPA Assessment of Incineration
As A Treatment Method for
Liquid Organic Hazardous
Wastes
Background Report IV:
Comparison of Risks from
Land-Based and Ocean-Based
Incineration
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COMPARISON OF RISKS FROM LAND-BASED
AND OCEAN-BASED INCINERATION
March 1985
x
A background report for the study by
EPA's Office of Policy, Planning and
Evaluation: "Assessment of Incineration
As A Treatment Method For Liquid Organic
Hazardous Waste."
Prepared by:
Industrial Economics, Inc.
2067 Massachusetts Avenue
Cambridge, Massachusetts 02140
in association with
Applied Science Associates, Inc.,
Arthur D. Little, Inc., and
Engineering Computer Optecnomics, Inc.
Prepared for:
Office of Policy Analysis
U.S. Environmental Protection Agency
Washington, D.C. 20460
EPA Project Officer: Dr. Jeff Kolb
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TABLE OF CONTENTS
INTRODUCTION AND SUMMARY CHAPTER 1
Introduction 1-1
Incineration Systems Considered 1-2
Summary of Results and Conclusions 1-5
Limitations 1-17
Organization of This Report 1-19
OVERVIEW OP ANALYTIC METHODS CHAPTER 2
Introduction 2-1
Incineration System Structure 2-1
Methods to Estimate Quantities Released 2-3
Human and Environmental Effects Analyzed 2-5
Uncertainty 2-7
Summary. 2-10
WASTE QUANTITIES RELEASED PROM LAND TRANSPORTATION CHAPTER 3
Data Sources 3-1
Assumptions 3-2
Releases from Vehicular Accidents 3-3
Releases from Container Failures 3-5
Caveats and Sensitivity Analysis 3-6
Comparable Hazards 3-8
Summary of Releases from Land Transportation 3-9
RELEASES FROM WASTE TRANSFER AND STORAGE CHAPTER 4
Data Sources 4-1
Assumptions 4-2
Transfers To and From Tank Trucks 4-2
Spills at Transfer and Storage Facilities 4-4
Fugitive Emissions from Transfer and Storage Facilities....4-6
Caveats and Sensitivity Analysis 4-6
Comparable Hazards 4-9
Summary of Storage and Transfer Releases 4-10
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WASTE RELEASES FROM OCEAN TRANSPORTATION CHAPTER 5
Data and Assumptions 5-1
Estimation of Releasing Vessel Casualty (Spill) Rates......5-2
Waste Quantities Released 5-4
Caveats and Sensitivity Analysis 5-6
Comparable Hazards 5-8
Summary of Releases from Ocean Transportation 5-10
RELEASES FROM INCINERATION CHAPTER 6
Introduction 6-1
Emissions of Undestroyed Wastes 6-2
PIC Emission Rates 6-3
Metals Emissions 6-7
Hydrochloric Acid Emissions 6-8
Scrubber Effluent 6-9
Caveats and Sensitivity Analysis 6-10
Summary 6-11
EFFECTS OF RELEASES FROM OCEAN TRANSPORTATION CHAPTER 7
Introduction 7-1
Methods and their Limitations 7-4
Marine Effects of a Release of PCBs in Mobile Bay 7-9
Marine Effects of a Release of PCBs over the
Continental Shelf 7-12
Marine Effects of a Release of PCBs in the Burn Zone 7-15
Marine Effects of Releases of EDC 7-17
Human Health Effects of Spills of PCB and EDC Waste 7-17
Summary 7-18
EFFECTS OF RELEASES FROM INCINERATION CHAPTER 8
Introduction 8-1
Human Health Effects 8-2
Environmental Effects 8-9
Summary 8-13
SELECTED BIBLIOGRAPHY
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INTRODUCTION AND SUMMARY CHAPTER 1
INTRODUCTION
The U.S. Environmental Protection Agency (EPA) currently is
evaluating ocean-based incineration as a method for disposal of
hazardous wastes. EPA'a Office of Policy Analysis (OPA) asked
Industrial Economics, Incorporated (lEc) to work with OPA staff
in developing a comparative assessment of the risks posed by
land-based and ocean-based incineration systems. This document
presents the results of our work.
Ocean- and land-based incineration systems have different
physical characteristics and affect different locations and
ecosystems. As a result, structuring a consistent comparison is
difficult. This report integrates existing information and adds
new analyses developed using existing methods and data. No new
primary research has been completed. We hope that our method of
structuring the analysis and the results developed will assist
efforts to evaluate incineration and other technologies for
hazardous waste management. However. li i& important £fi
understand that the results of this effort are not sufficient to
determine tne advisability of any specific |.and- or ocean-based
incineration proposal.
The remaining sections of this Chapter summarize:
o the ocean- and land-based incineration systems
considered,
o major results and conclusions,
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o the major limitations of our work, and
o the organization of this report.
All exhibits referenced in the text are included at the end of
the chapter.
INCINERATION SYSTEMS CONSIDERED
Incineration System Components
We separate land- and ocean-based incineration systems into
three and four separate physical components, respectively. Both
land- and ocean-based systems are defined to include:
o Land Transportation: transport of wastes by truck
from the generator site to the incinerator or
pierr
o Transfer and Storage: transfer and storage
operations at the land-based incinerator, pier, or
other storage facilities, and
o Incineration: incineration of the waste.
In addition to these steps, ocean-based incineration systems are
defined to include:
o Ocean Transportation: transport of the wastes by
ship from the pier facility to the burn zone.
At each of these stages, wastes and hazardous by-products (for
example, volatilized fractions or products of incomplete
combustion) can be released to the environment. The nature of
these releases varies from relatively unlikely releases of large
quantities of waste (such as spills from truck or ship accidents)
to very likely releases of smaller quantities of waste (such as
stack emissions, minor pump leaks, and so forth). He attempt to
quantify losses from all of these possible release points.
Our ocean-based system has a configuration similar to that
proposed by Chemical Waste Management, Inc. (CWM) to operate the
I/V Vulcanus II from Mobile, Alabama to the Gulf of Mexico burn
zone. However, we assume that an integrated storage and transfer
facility is located at the port. Our land-based system is not
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based on any single incinerator but combines characteristics of
several facilities. Exhibit 1-1 displays the important
characteristics assumed for each incineration system.
As Exhibit 1-1 shows, land transportation assumptions for
the ocean- and land-based systems are similar. We assume that
wastes are transported 250 miles from generator to land-based
incinerator or pier. Tank trucks are the assumed mode of land
transport in both cases; and weather, road, and other driving
conditions are assumed to be "average." While wastes destined for
land- or ocean-based systems might travel different distances,
changes in the 250 mile trip length do not alter our results
significantly.
Transfer and storage characteristics for each case are
assumed to be similar and are determined primarily by the
configuration of equipment used for handling and storing wastes.
Ocean-based incineration requires one extra loading step
pumping wastes from an onshore storage facility or from the
current fixed piping system at Chickasaw into the incinerator
ship. The type of storage tanks used also is critical, since the
emission characteristics of alternate tanks differ greatly. Our
analysis considers both accidental spills during transfer and
storage and continuous "fugitive" losses from storage tank vents,
pump seals, and so forth. We have not considered releases from
major accidents involving fire or explosion at storage
facilities. The probability of such events occurring is very low
and, because both land- and ocean-based systems require similar
storage facilities, the potential for events of this type would
be about the same for each system.
Ocean transportation characteristics are unique to the
ocean-based system, and have been drawn directly from CWM's
proposed plan for operations through Mobile Harbor from
Chickasaw, Alabama. These operations will require an 800
kilometer transit through Mobile Harbor, across the continental
shelf near the mouth of the Mississippi River, and on to the burn
zone.
Finally, Exhibit 1-1 shows the assumed characteristics of
the incinerators themselves. Both land-based and ocean-based
incinerators are assumed to be liquid injection units with
capacities up to 70,000 metric tons per year. This capacity was
selected based on the characteristics of the Vulcanus II.
Although this capacity is greater than any commercial land-based
facility, incinerators of this size are feasible and in operation
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at some on-site facilities. Consistent with current practice the
land-based unit is assumed to employ scrubbers, while the ocean-
based unit does not. We assume that these units achieve
destruction and removal efficiencies (DRE) of 99.99 to 99.9999
percent depending on the waste burned. In effect, we assume that
either system will meet current permit requirements concerning
DRE and other operating parameters.
Waste
The environmental transport of wastes and by-products and
their ultimate fate and effects depend strongly on the precise
composition of the mixture released. In general, adequate data do
not exist to predict the transport, fate and effects of mixtures
released to the environment. In view of this, we assume two
"simplified" waste streams with single hazardous constituents for
use in this analysis.
1. A waste containing 35 percent by weight of
polychlorinated biphenyls (PCBs) . Arochlor 1254 is
assumed to be the specific PCB, and the remaining
65 percent of the waste stream is assumed to be
non-hazardous. Each system is assumed to burn
56,000 metric tons of this waste stream each year.
2. A waste containing 50 percent by weight of
ethylene dichloride (EDO and 50 percent non-
hazardous substances. Each system is assumed to
burn 68,400 metric tons of this waste stream each
year.
In addition, each waste stream is assumed to include 100 ppm each
of arsenic, cadmium, chromium and nickel. These metals are among
those specifically regulated by the Agency's draft permit for
ocean-based incineration and each has been designated a human
carcinogen by EPA's Carcinogen Assessment Group. Although all
four have been found in a variety of actual waste streams, it is
likely that our assumption overstates the average concentration
of carcinogenic metals in liquid incinerable wastes.
Commercial incinerators handle many waste streams of
varying composition. Pour considerations caused us to assume
the simplified wastes described above. First, CWH has requested a
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permit to burn PCB-containing wastes and thus the possible
release, transport and effects of these compounds are of
particular interest to EPA. Second, EDC is a common component in
many hazardous waste streams currently incinerated and is typical
of a large volume of wastes generated by the organic chemicals
industry. Third, the physical characteristics and resulting
transport behavior of PCBs and EDC in the marine environment are
quite different, thus allowing us to illuminate how fundamentally
different waste components might behave. Fourth, human cancer
potency factors are available for both PCBs and EDC and
information is available on the toxic and bioaccumulative
effects of the materials in marine organisms.
SUMMARY OF RESULTS AND CONCLUSIONS
This section summarizes the quantities of waste released and
the possible human and environmental effects from these releases.
Quantities of Waste Released
Exhibits 1-2 and 1-3 present our estimates of the "expected"
annual average release quantities from ocean-based and land-based
incineration for the PCB and EDC wastes, respectively. For
releases due to accidents, spills and other infrequent events
these estimates represent the long-term average release, which
includes years with no release and years with one or more
releasing events. As a result, actual releases in any single year
for these events could range from zero to relatively large
quantities if, for example, a truck is involved in an accident
that results in a spill. Our calculation of expected quantities
released accounts for both the probability of a release and the
resulting magnitude of waste lost, and provides one means of
comparing average long-term releases from infrequent events with
continuous releases.
Each exhibit shows the expected quantity of release for
each component of the land- and ocean-based systems. All figures
have been rounded to the nearest 100 kilograms (0.1 metric tons).
For convenience, a subtotal is provided for releases from
transport and handling steps and for incinerator stack releases.
Metals included in scrubber effluent are also reported.
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Overall, comparison of the expected releases from the ocean-
based versus the land-based systems for these two wastes shows
that expected release quantities from the transportation and
handling components range to roughly 15 percent of the long-term
average release expected. The extra transport and handling steps
required by ocean-based systems do not add significantly to the
long-term expected release, but they do create the remote
possibility of a major accident and subsequent release of waste.
Incineration itself accounts for the major release of wastes
and hazardous by-products for both wastes and systems considered.
The quantities released by incineration are a function of
assumptions about metals content and the performance of the
incinerator and scrubber. Available estimates of PIC generation
are subject to very high levels of uncertainty. Releases from
each component are further discussed below.
Land Transportation
Exhibits 1-2 and 1-3 show that the expected release from
land transportation will average 2.1 and 2.7 metric tons (HT) per
year for the PCS and EDC wastes, respectively. Again, these
estimates represent long-term averages. Releases in any year
would vary from zero to larger quantities if a spill occurred.
The slightly greater release estimated for the EDC waste reflects
the larger quantity of this waste assumed to be handled by each
system. Because land transportation has the same configuration
in each system, there is no difference in the release quantities
expected for the land- versus ocean-based system.
Our analysis of releases from land transportation considers
two types of potential losses — spills from vehicular accidents
and spills from enroute container failures. We base our
estimates of the frequency of such events and of the size of the
resulting spills on data provided by the U.S. Department of
Transportation (DOT). These data pertain to all tank trucks
carrying hazardous materials. Use of the DOT data with our
assumptions regarding miles travelled results in an expected .18
and .26 releasing vehicle accidents per year for the PCS and EDC
wastes, respectively. The annual number of container failures is
estimated at .23 and .32 for the PCS and EDC wastes. The average
fraction of cargo released in vehicular accidents is about 40
percent. In contrast, spills from container failures typically
release only about 4 percent of the cargo in the container.
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Information supplied by hazardous waste services firms
indicates that the DOT accident rates are higher than those
experienced by these firms. This probably is due to management
practices undertaken by such firms to reduce the probability of
accidents and to their use of stainless steel tanks that are more
resistant to rupture than are aluminum tanks. Thus, we believe
that our estimates of releases from land transportation are
conservative. These estimates represent, on average, about 0.5
percent of the number of annual transportation-related releases
of hazardous substances in EPA Region IV.
Transfer and Storage
Our analysis of wastes released from transfer and storage
considers three types of releases: spills when unloading wastes
from tank trucks; spills from equipment at waste transfer and
storage facilities; and fugitive emissions from transfer and
storage. As shown in Exhibits 1-2 and 1-3, the expected quantity
released from transfer and storage activities is slightly over
one metric ton per year for both systems and waste streams
considered. These release estimates are based on information
developed by Arthur D. Little, Inc. and DOT.
Spills from the transfer and storage component are fairly
infrequent events. They are estimated to occur at a rate of
about 0.04 to 0.05 per year for the transfer of wastes from tank
trucks and at a rate of about 0.03 to 0.04 per year for
equipment"and storage tanks. The ocean incineration system has
one additional component — the loading hose to transfer wastes
to the ship. We estimate the rate of spills from the hose at
about 0.002 to 0.003 per year, with the average spill size about
6 to 7 MT. It is likely that spills of this type would be
contained either on the deck of the Vulcanus or by booms placed
around the vessel during loading. Spills from truck unloading or
from equipment or storage tanks are also likely to be contained
in the facility. Fugitive emissions would account for about 0.6
to 0.7 MT per year of this amount. The number of spills expected
from this component of land- or ocean-based incinerators would
represent, on average, less than 0.1 percent of the number of
spills of hazardous material likely from fixed facilities in EPA
Region IV.
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Ocean Transportation
The ocean transportation component of ocean-based
incineration is the only major component of the system that has
no parallel in a land-based operation. Therefore, potential
releases from ocean transportation are of special interest when
comparing the relative risks of land- and ocean-based
incineration systems.
Incineration ships have operated o£f the coast of Europe in
the North Sea since 1972. About 320 voyages have been made and
about 650,000 metric tons of hazardous waste have been
incinerated. No casualties such as collisions, groundings,
rammings, or fires have occurred, nor have there been any spills
from loading these ships in port. Although a very good safety
record has been established, the number of voyages completed is
too small to be used directly in estimating statistically the
probability of spills.
In view of this, EPA asked Engineering Computer Optecnomics,
Inc. (ECO) to develop estimates of spill rates based on the
worldwide historical record of tank ships of a similar size
class. Spill rates were developed for three impact type
accidents (collisions, groundings, and rammings) and for non-
impact type accidents (fires, explosions, structural failures,
and capsizings). Spill rates were developed for four locations
of interest — pier and harbor. Mobile Bay, coastal area, and
burn zone. Estimates were also developed of the percentage of
spills likely to involve one, two, or three or more tanks — 80
percent, 15 percent, and 5 percent, respectively.
The historical spill rates were adjusted to take into
consideration the design of the Vulcanus (double hull, double
bottom construction and the use of a controllable pitch propeller
and bow thruster), operating restrictions to be imposed by the
Coast Guard (escorts by tug boats and a Coast Guard vessel,
imposition of a 300 foot moving safety zone, and limitation of
transits to daylight hours and in conditions of above average
visibility), and the soft bottom conditions in the Gulf. The
precise effect that these factors may have in reducing spill
rates is difficult to determine. ECO's adjustments were based on
published studies, observed differences in spill rates, kinetic
energy levels likely for accidents in different locations, and
professional judgment.
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The expected annual releases of 0.6 MT foe PCBs and of 0.8
MT for EDC shown in Exhibits 1-2 and 1-3 are relatively small and
represent average releases expected over a very long time.
Spills from the vessel would be very infrequent events. We
estimate that the frequency of all spills for the Vulcanus is
about one per 1,200 operating years. However, the frequency of
spills estimated for any particular location is less. For
example, the overall spill rates for the pier and harbor area,
Mobile Bay, Coastal area, and the burn zone are about one per
3,000, 10,000, 4,000 and 6,000 operating years, respectively.
These estimated spill rates are for all sizes of spills. Spills
involving two or three or more tanks would be extremely unlikely
events. For example, the estimated rates for spills involving
two and three or more tanks in Mobile Bay are about one per
67,000 and 200,000 operating years, respectively.
The preceding estimates of releases are conservative, in
that we assume that any tank involved in a spill releases its
entire contents and that the entire ship's cargo is released in
accidents involving three or more tanks. In addition, the
estimates do not reflect the effects that remedial actions may
have in removing wastes from the marine environment. As a
condition of their permit, hazardous waste operators are
required to develop a contingency plan for handling spills.
Efforts to contain and recover spills are most likely to be
successful in enclosed areas or in shallow waters, such as the
pier and harbor area and Mobile Bay. However, estimating the
effectiveness of remedial actions was beyond the scope of this
study.
The tonnage carried by the Vulcanus is small in comparison
to commercial shipments of petroleum and hazardous substances in
the Gulf area. For example, the cargo carried by the Vulcanus
would be only about 0.01 percent of petroleum and hazardous
substances transported annually in the Gulf area. Since the
Vulcanus has a lower spill rate than other vessels, the expected
volume of releases from the Vulcanus, in a statistical sense, is
only about 0.002 percent of expected releases from ongoing
shipments of petroleum and hazardous substances in the Gulf area.
Incineration
Incineration itself is the major release point in both
systems. Metals account for the largest releases when burning the
PCB waste, with undestroyed wastes providing a minor
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contribution.!/ Our estimates of undestroyed wastes for both
systems assume 99.9999 percent destruction of the PCB waste
stream. Our estimates of metals emissions result from our
assumptions about metals concentrations in the waste. Metals are
transferred to scrubber effluent in the land-based case by use of
a scrubber which is assumed to remove from 50 to 90 percent of
the four metals considered. Thus, stack emissions of organics and
metals in the land case are about 20 percent of those predicted
for the ocean-based case.
Exhibits 1-2 and 1-3 present the expected annual average
release quantities for the incineration component of both
systems. Total organics and metals released from incineration of
the PCB wastes is 22.5 metric tons per year for both systems if
one includes both stack releases and scrubber effluent. Total
organics and metals released by the ocean-based incinerator for
the EDC waste is more than 50 percent greater than that expected
for the land-based case (54.8 MT compared to 34.8 HT). This
difference is due primarily to the higher level of PIC release
estimated for the ocean case.
Products of incomplete combustion (PICs) are not expected in
significant quantities for the PCB waste based on EPA's trial
burn data. However, the results of these trial burns are subject
to large uncertainty and considerable debate because of the
procedures used and the limited number of PIC compounds that were
considered. Thus, our estimates of PIC emissions for the PCB
waste (.000000006 metric ton per year and .00002 metric ton per
year for the ocean and land cases, respectively) could be in
error by many orders of magnitude. In addition, we do not know
of any complete explanation for the lower level of PIC generation
found for ocean-based PCB incineration and the higher level found
for ocean incineration of general organic waste relative to
incineration on land. Alternate estimates of PIC generation and
the resulting human health effects are analyzed in later chapters
and appendices of this report.
JL/Note that if incinerated waste streams contain significantly
less carcinogenic metals than we have assumed, the total quantity
of stack emissions released from each system would drop
dramatically. Further, releases from the transportation and
transfer/storage components would become the major contributors
to total release.
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In addition to the compounds reported in these exhibits, we
also analyzed the release of chlorine at incinerators in both
systems and the disposition of the chlorine to the atmosphere
and, for the land-based system, to scrubber effluent and sludge.
Our results show that 10,505 and 25,034 metric tons of
hydrochloric acid (BCD will be released from the incineration of
the PCS and EDO wastes, respectively. In the ocean case all HC1
is released to the atmosphere. In the land-based case the
scrubber captures 99 percent of the HC1 and neutralizes it. Thus,
most chlorine in the land case is disposed as scrubber sludge or
effluent.
Effects From Incinerator Releases
He estimated and compared possible human health effects due
to releases from the incinerator and due to fugitive releases
from transfer/storage equipment located at the land-based
incinerator or the pier. We also considered possible
environmental effects of these releases.
Human Health Effects
Our analysis of human health risks estimates the incremental
risk of developing cancer for a hypothetical "most exposed
individual" (HEI) who resides at the location of the highest
overall risk due to air concentrations resulting from incinerator
stack and transfer/storage fugitive releases. For the land-based
system, the location of the HEI is based on Census data; whereas
for the ocean-based system the MEI is assumed to reside at that
point on the coast where modelled concentrations are highest
averaged over a year. These risk estimates assume 70 years of
continuous exposure. In the ocean case different areas are
affected by stack emissions (the coastline downwind from the burn
zone) and transfer/storage fugitive releases (the area around the
port), while for the land-based case the same area is affected.
Our calculations of risk for the land-based system consider two
alternative sites for the incinerator, in Texas and Arkansas.
We chose to estimate risks to the most exposed individual in
order to estimate the largest risks likely to be suffered by any
person due to the releases considered. While we could have
considered the average incremental risk across the entire human
population affected by each system, this metric requires
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estimation of the total exposed population and all levels of
exposure — a difficult and controversial task given the long
distances and persistence of some compounds considered here. In
general, other risk analyses have found that average population
risks range from one to four orders of magnitude lower than the
risk to the MEI.
Exhibit 1-4 presents the incremental risk of developing
cancer for the most exposed individual due to releases from land-
and ocean-based fugitive (transfer/storage) and stack releases.
As shown, the incremental risks from land-based incineration
releases are about three chances in one-hundred thousand for the
locations and wastes considered. Virtually all of the incremental
risk to the MEI is due to stack releases, with fugitive releases
resulting in increased risks of less than one in a million.
Incremental risks to the most exposed individual at the coastline
for the ocean-based system range from one in one million to 6 in
ten million. As shown, the risks from fugitives to the MEI near
the port facility are less than two per hundred million.
The data and methods used to generate these incremental risk
estimates are highly uncertain and tend to overestimate expected
human health effects. Thus, the absolute risk levels indicated by
these figures must be interpreted with caution. EPA has completed
studies of incremental risks from other hazardous pollutant
releases using similar methods with similar uncertainties and
biases. For example, a recent study on toxic air pollutants found
that, on average, individuals in the U.S. face incremental cancer
risks of about 4 to 6 chances in ten thousand.2/ Using this
estimate as the base for comparison, incremental risks to the
persons most exposed by the incineration systems considered here
would be one to three orders of magnitude lower.
Exhibit 1-5 presents more detailed information concerning
the sources of the incremental cancer risks for the incineration
systems considered. This exhibit reports the contribution of
principal organic hazardous constituents (POHCs), PIC and metals
emissions to the total incremental risks suffered by the MEI. For
2/EPA, The Magnitude and Haiiitfi s£. thfi Alt Toxics Problem in thfi
United States. Draft Report. Office of Air and Radiation and
Office of Policy, Planning and Evaluation, 1984.
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convenience, risks due to fugitive emissions from transfer and
storage operations are not included in the figures in Exhibit 1-
5.
The estimates in Exhibit 1-5 show the relative magnitudes of
incremental risk caused by each stack component for both wastes
and systems considered. As shown, POHC and PIC releases cause
risks that are from one to five orders of magnitude less than
risks from metals. Thus, metals account for from 90 percent to
virtually all of the incremental risks calculated for stack
emissions. However, as noted earlier, it is likely that our
assumptions overstate the average concentrations of carcinogenic
metals in liquid incinerable wastes. Risks from POHC releases
are less than 1 per billion for the ocean system and less than 2
per 10 million for the land system. Risks from PIC releases are
less than 4 in one billion for the ocean system and less than 2
in 1 million for the land-based system. Thus, risks from both
PICs and POHCs in each system are low.
Exhibit 1-6 presents the ratio of the incremental risks from
land-based versus the ocean-based stack releases. The figures in
this exhibit were calculated by dividing the land-based risk
estimates in Exhibit 1-5 by those shown for the ocean-based
system. Thus, the figures in Exhibit 1-6 indicate the relative
size of risks estimated for the land-based versus the ocean-based
system considered. For example, Exhibit 1-6 indicates that, for
the PCB waste, land-based emissions create about 40 times more
incremental risk to the HEI than do ocean-based emissions. For
the EDC waste, the ratio of land to ocean risk is about 30.
Exhibits 1-5 and 1-6 show that, given our assumptions, there
is roughly 30 to 40 times more incremental risk from metal
released from land systems. Changes in the type and concentration
of metals in the waste could reduce these risk estimates by
several orders of magnitude but would not change the relative
performance of the land and ocean systems. Different assumptions
about the performance of the land-based scrubber in removing
metals, or about the atmospheric transport of metals over the
ocean could affect the relative performance of the two systems
considered. While different assumptions could broaden or narrow
the differences in metals risk, it is unlikely that ocean-based
systems would generate more incremental risk than land-based
systems.
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These exhibits also show that the land-based system
generates about 300 times more incremental risk from POHC
emissions. The transport behavior of PICs is similar to that of
POHCs and thus, for similar quantities and toxicities of release,
PIC risks should show the same ratios. However, our analysis of
trial burn data indicates that land- and ocean-based systems can
generate very different quantities of PICs.
EPA's trial burn data indicate wide variation in PICs
generated by different incinerators from different waste streams.
The results of these burns are subject to great uncertainty and
considerable debate. For the PCS waste, our analysis uses a PIC
generation rate for the ocean-based system that is 10,000 tiroes
lower than that used for land since this rate is derived from
trial burn data. When combined with the additional advantage of
the ocean-based system in being further from human populations,
the land-based unit generates over 1 million times the risk of
the ocean system for PICs. Thus, our relative estimates of PIC
generation from the PCB waste would have to be in error by a
factor of one million for the land and ocean systems to present
equivalent risks from PICs. Again, note that the absolute risks
estimated for PICs from both systems are very low.
Our assumption regarding the amount of PICs from EDC wastes
is quite different. For this waste, trial burn data suggest that
the ocean-based unit will generate about 30 times more PICs than
the land system. Despite the ocean system's exposure advantage,
this lowers its ratio of risk compared to the land system to a
factor of 8. While changes in relative PIC generation that are
greater than an order of magnitude could make PIC risks from land
and ocean systems equivalent or show land systems to be safer, we
believe that such changes are unlikely.
Although the absolute numbers reported in Exhibits 1-4 and
1-5 are uncertain and biased to overestimate incremental risks,
the relative differences shown in Exhibit 1-6 are more certain
and would be altered only by changes in the relative performance
of the ocean- and land-based systems. Overall these results
generally indicate that the human health risks posed by either
system are relatively low, with the risk from the ocean-based
system about one to two orders of magnitude less than from the
land-based system. This general result was expected, since the
burn zone is about 200 kilometers distant from the coast,
allowing residual emissions to disperse and to partly settle out
before reaching land, and since the plume emitted during trial
burns has never been detected at the shoreline.
1-14
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Along with incremental risks due to inhalation of hazardous
compounds, we also considered incremental risks due to ingestion
of foods contaminated by wastes or hazardous by-products from
ocean- and land-based stack emissions. Although data and methods
in this area are extremely limited, we found insignificant
incremental risks from this ingestion route of exposure.
Environmental Effects
In addition to the human health effects summarized above, we
considered the possible environmental effects that might result
from incinerator stack releases. For the ocean-based case, we
asked Applied Science Associates, Inc. (ASA) to estimate the
deposition of stack releases to the ocean surface, the transport
of these materials in the water column and sediments and
resulting effects on the marine ecosystem. ASA's analyses
indicate that no measurable effect on the marine ecosystem is
expected due to stack releases from the EDC waste. The analysis
of the PCB waste is complicated by the persistence of the
compound and by scientific uncertainty about the role of the
ocean's surface (the "microlayer") in capturing and concentrating
atmospheric pollutants and providing these materials to the
marine ecosystem. Notwithstanding these uncertainties, ASA's
analyses indicate that long-term continuous burning of the PCB
waste at the levels assumed here would not result in a measurable
effect on the marine ecosystem. Information developed on the
background atmospheric flux of PCBs into the Gulf waters
indicates that it would be about two to three orders of
magnitude greater than that from incineration of PCBs.
We were unable to complete a similar analysis of the effects
on terrestrial ecosystems caused by land-based stack releases.
However we did consider the possible environmental effects from
the release of scrubber effluent and sludges from the land-based
system. Because discharge of scrubber effluent and sludge is
regulated by the Clean Water Act and the Resource Conservation
and Recovery Act, respectively, disposal of these materials would
have to be carried out in a manner approved by environmental
permitting authorities. Thus, we assume environmental damage
from these discharges is minor.
1-15
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Effects From Ocean Transportation Releases
In addition to the effects from incinerator stack and
fugitive releases, we also characterized possible human and
environmental effects resulting from spills in the marine
environment. Although the probability of a spill is very low,
the magnitude of the resulting effects is of interest in public
deliberations about ocean- versus land-based incineration
systems. We considered the likely effects of release of cargo
from the vessel at sites within Mobile Harbor, over the
continental shelf on the path to the burn zone, and in the burn
zone itself.
Human Health Effects
Exhibit 1-7 presents information about the potential for
human health consequences from loss of the entire vessel cargo.
Volatilization of such a spill could expose human populations to
high concentrations of hazardous constituents for short periods
of time. Because of the acute nature of these exposures, we
compared the estimated dosage received by human populations in
the first 24 hours after a spill to the Threshold Limit Value
(TLV) for PCBs and EDC. The TLV represents the dosage to which a
worker can be exposed with no adverse health effects such as
coughing, dizziness, and longer-term health damage. We adjusted
the TLVs to account for continuous exposure rather than exposure
for only eight hours per day. In all calculations we assume
that the human population is directly downwind from the spill
site and that the entire cargo of the vessel is released.
As shown in Exhibit 1-7, we estimated the ratio of 24 hour
dosages to adjusted TLV's for spills in Mobile Harbor at one and
15 kilometers from the city of Mobile, for spills over the
continental shelf near the mouth of the Mississippi River, and
for spills in the burn zone. The results show that spills of the
entire cargo of either waste one kilometer from the city of
Mobile could cause human health problems. Spills at the other
locations are not expected to cause acute human health problems.
Environmental Effects
Exhibit 1-8 presents a summary of the potential effects to
the marine ecosystem from spills of half a tank in the three
locations described previously. The ecosystem effects are
1-16
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summarized by changes in biomass levels and in bioconcentration
levels for PCBs and EDC. For PQBs we consider both floating and
sinking cases, since this compound, although heavier than water,
might float if entrained in lighter-than-water materials. For
EDC, we consider only a sinking case, which results in rapid
diffusion since this compound is soluble in water. We also
modelled the effects of larger spills of 2 tanks and 8 tanks. As
noted earlier, for modelling purposes we assumed no actions were
undertaken to contain and remove the spill.
Exhibit 1-8 indicates that EDC spills would have relatively
minor effects on the marine ecosystem. These small impacts are
the result of this compound's rapid diffusion to low
concentration levels and its relatively low toxicity to marine
species. In addition, bioconcentration of EDC is not a
significant phenomenon. The same results hold for larger size
spills.
In contrast, spills of PCBs are modelled to have major
effects on the marine ecosystem. These effects range from being
quite severe in the Bay (substantial reduction in benthic species
and large bioconcentration effects on fish and shrimp) to less
severe in the burn zone area. Since PCBs are a persistent com-
pound such effects are expected to last a long time.
Bioconcentration effects in commercial and recreational species
would be of most concern in the Bay and contaminated shelf areas.
In the event of larger or smaller size spills, the magnitude of
bioconcentration effects is approximately linear with regard to
quantity released.
Estimating the effects of spills of persistent compounds
such as PCBs in the marine environment is an imprecise science at
best. Because of substantial uncertainties regarding the long
term fate of PCBs in the marine environment and the biological
mechanisms involved in the food web/ the results of the modelling
effort should be viewed as a general indication of potential
effects rather than as a precise measure of those effects.
LIMITATIONS
All of bur analyses are subject to many limitations and
caveats due to uncertainties in the data and methods that we use.
These limitations and caveats are explained fully in the chapters
and appendices of this report. All of our results should b_e_
interpreted with cautionf and with a. complete understanding of
1-17
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all ££ .these, limitations. Some of the general limitations of the
analyses are described below.
1. By design this analysis is limited to considering
only incineration systems. It does not consider
potential environmental or economic risks or
benefits from use of other methods of hazardous
waste treatment, storage or disposal.
2. The analyses reported here are applicable only to
the specific land- and ocean-based cases examined.
Results for other locations, wastes and
technologies could vary substantially from the
information reported here.
3. We have attempted to structure incineration
systems and wastes typical of actual or likely
practice so as to generate an expected rather than
a best or worst case analysis. However, data
limitations have required use of many conservative
assumptions in our estimates of release
quantities, and the methods for estimating effects
of releases generally err on the side of
overestimation. Thus, our overall results
overestimate releases and resulting effects from
the incineration systems considered.
4. He have not considered a number of effects which
might result from releases from the ocean- and
land-based systems. In particular, we have not
analyzed the possible effects of releases on
terrestrial ecosystems.
5. Our analysis of the quantity of and effects from
stack releases for both systems is based on
assumptions about incinerator and scrubber
performance and waste composition, and on results
from EPA-sponsored trial burns. The data on PIC
generation developed from the trial burns is
extremely uncertain and subject to debate.
6. The estimates of the effects of spills into the
marine environment assume that no mitigating
activities are completed.
1-18
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In view of the above, the absolute release and effects
estimates for land- and ocean-based systems are less meaningful
than the relative differences shown between the two systems. Our
results are particularly sensitive to factors (such as PIC
emissions, scrubber efficiency, and so forth) that alter the
relative performance of the two systems considered.
ORGANIZATION OF THIS REPORT
All of the methods, data and results for our comparison of
the risks of land- and ocean-based incineration are detailed in
the remaining chapters and appendices of this report. These
materials are organized as follows.
Chapter 2
Chapter 3
Chapter 4
Chapter 5
Chapter 6
Chapter 7
Chapter 8
Appendix A
provides an overview of the methods used
in the comparison of ocean-based versus
land-based incineration systems.
presents estimates of the waste
quantities released from the land
transportation component of each system.
presents estimates of the waste
quantities released from the transfer
and storage component of each system.
presents estimates of the waste
quantities released from the ocean
transportation component.
presents estimates of the wastes and
hazardous by-products released from
incineration itself in both systems.
describes the human health and
environmental effects of releases from
ocean transportation.
describes the human health and
environmental effects of releases from
land- and ocean-based incinerators.
describes the voyage plan for the
Vulcanus II and the resulting waste
throughput.
1-19
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Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix
Appendix
All exhibits
referenced.
H
presents detailed estimates of releases
from the transfer and storage component.
presents detailed estimates of releases
from ocean transportation.
describes the human health effects due
to releases from land-based incinera-
tors.
•
presents estimates of the generation and
composition of products of incomplete
combustion (PICs).
describes the generation, composition
and disposition of scrubber effluent at
land-based incinerators.
describes the human health effects due
to releases from ocean-based incinera-
tors.
describes the human health effects
to ocean transportation releases.
due
I describes the marine ecosystem effects
resulting from ocean transportation
releases.
follow the chapter or appendix where they are first
1-20
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Exhibit 1-1
SUMMARY OP INCINERATION SYSTEM COMPONENTS
Component
Land Transportation
Ocean-based
System
Tank trucks
(5000 gallons)
250 miles
"Average"
weather, roads/
etc.
Land-based
System
Tank trucks
(5000 gallons)
250 miles
"Average"
weather,roads,
etc.
Transfer and Stroage
Storage at
pier in
two floating-
roof tanks.
Storage at
incinerator in
two floating-
roof tanks.
One truck
unload
One load to
vessel
One truck
unload
Ocean Transportation
800 km (500 miles)
to burn zone
Specific path from
Mobile to zone
Vessel specifications
and operations plan as
per CWM for Vulcanus II
None
-------
Exhibit 1-1
(continued)
SUMMARY OF INCINERATION SYSTEM COMPONENTS
Component
Incineration
Ocean-based
System
Liquid In-
jection, no
scrubber
DRE-99.99 or
99.9999
Throughput to
70,000 MT/year
Land-based
System
Liquid In-
jection,with
scrubber
DRE«99.99 or
99.9999
Throughput to
70,000 MT/year
-------
Exhibit 1-2
SUMMARY OF EXPECTED QUANTITIES RELEASED PER YEAR *
PCB Waste
(metric tons per year)
Ocean-based Land-based
Release Point System System
Land Transportation 2.1 2.1
Transfer and Storage 1.2 1.1
Ocean Transportation 0.6
Subtotal 3.9 3.2
Incineration
Undestroyed Wastes 0.1 0.1
PICs 0.0 0.0
Metals 22.4 4.5
Subtotal (Stack) 22.5 4.6
Scrubber Effluent
Metals — 17.9
Total Organics and Metals 26.4 25.7
For releases due to accidents, spills and other uncertain
events these estimates represent the long-term average
release which includes years with no release and years with
one or more releasing events.
Source: lEc Analysis
-------
Exhibit 1-3
SUMMARY OF EXPECTED QUANTITIES RELEASED PER YEAR *
EDC Waste
(metric tons per year)
Ocean-based Land-based
Release Point System System
Land Transportation 2.7 2.7
Transfer and Storage 1.2 1.1
Ocean Transportation 0.8 —
Subtotal 4.7 3.8
Incineration
Undestroyed Wastes 6.8 6.8
PICs 20.6 0.6
Metals 27.4 5.5
Subtotal (Stack) 54.8 12.9
Scrubber Effluent
Metals — 21.9
Total Organics and Metals 59.5 38.6
For releases due to accidents, spills and other uncertain
events these estimates represent the long-term average
release which includes years with no release and years with
one or more releasing events.
Source: IEC Analysis
-------
Exhibit 1-4
SUMMARY OF INCREMENTAL CANCER RISK TO HOST EXPOSED INDIVIDUAL
PROM INCINERATOR RELEASES
PCB Waste EDC Waste
Ocean-based System
Stack (coastline) 6.37E-7 1.06E-6
Fugitives (port) 2.02E-8 4.97E-10
Land-based System (average of two sites)
Stack 2.74E-5 3.14E-5
Fugitives 7.05E-7 1.69E-8
Total 2.81E-5 3.14E-5
Source: Exhibits 8-4, 8-5
-------
Exhibit 1-5
INCREMENTAL CANCER RISK TO MOST EXPOSED INDIVIDUAL
BY TYPE OF STACK RELEASE
Ocean-based System
POHCs
PICs
Metals
Total Stack
PCB Waste
1.45E-10
1.68E-12
6.37E-7
6.37E-7
EDC Waste
5.51E-10
3.36E-9
1.06E-6
1.06E-6
Land-based System (average of two sites)
PORCs
PICs
Metals
Total Stack
5.13E-8
1.79E-6
2.56E-5
2.74B-5
1.43E-7
2.59E-8
3.12E-5
3.14E-5
Source: Exhibits 8-3, 8-4
-------
Exhibit 1-6
RATIO OF INCREMENTAL CANCER RISK
FOR LAND- VERSUS OCEAN-BASED INCINERATORS
BY TYPE OF STACK RELEASE
PCB Waste EDC Waste
POHCs 354 260
PICs 1,070,000 8
Metals 40 29
Total 43 29
Source: Exhibit 1-5, lEc Analysis
-------
Exhibit 1-7
SUMMARY OF HUMAN HEALTH EFFECTS FROM
LOSS OF ENTIRE VESSEL *
(ratio of 24 hour dosage to adjusted TLV)
Release Location
Mobile Harbor
1 Kilometer
15 Kilometers
Continental Shelf
Burn Zone
PCB Waste
1.3
0.06
0.019
0.0019
EDC Waste
1.9
0.12
0.002
0.0004
The probability of a spill involving three or more
tanks of the vessel in any location is about one in
24,000 per year, and in the pier, harbor, and bay area
is about one in 50,000 per year.
Source: Exhibit 7-18
-------
Exhibit 1-8
SUMMARY OP MARINE ECOSYSTEM EFFECTS FROM SPILLS OF HALF A TANK
Release Location
PCB Waste
Effect Bioconcen-
on tration
Biomass Levels
EDC Waste
Effect Bioconcen-
on tration
Biomass Levels
Mobile Bay
Floating Case
Sinking Case
Small overall,
severe reduc-
tion for
benthos
Uncertain
3 to 5 orders
of magnitude
Uncertain
Not
Considered
Minor
Not
Considered
Minor
Continental Shelf
Floating Case
Sinking Case
Uncertain
Small overall,
substantial
for benthos
Uncertain
2-3 orders
of magni-
tude
Not
Considered
Minor
Not
Considered
Minor
Burn Zone
Floating Case
Sinking Case
Uncertain
Minor overallr
substantial
for benthos
Uncertain
1-2 orders
of magni-
tude for
benthos and
demersal fish
Not
Considered
Minor
Not
Considered
Minor
Source: lEc Analysis
-------
OVERVIEW OF ANALYTIC METHODS CHAPTER 2
INTRODUCTION
This chapter introduces the analytic methods used to
estimate releases of waste and hazardous by-products from ocean-
and land-based systems and to characterize the effects of these
releases. In addition, the chapter presents the sources of data
and the important assumptions used in this study. The sections
below review our rationale for structuring the ocean- and land-
based systems as we have, the methods and data used to estimate
releases from each component of these systems, and the metrics
and methods selected to characterize the effects of these
releases. The final section provides some thoughts on the types
and magnitudes of uncertainty in our results.
INCINERATION SYSTEM STRUCTURE
As indicated in Chapter 1, the analysis of the ocean-based
incineration system is based on Chemical Waste Management,
Inc.'s (CWM) proposal to operate the Vulcanus II from Chickasaw,
Alabama through Mobile Bay to the Gulf of Mexico burn zone.
CWM's proposal envisions delivery of wastes to Chickasaw in tank
trucks; transfer, storage and loading of wastes at an integrated
port facility; and transport to the Gulf burn zone and
incineration aboard the Vulcanus II. Because CWM has not yet
developed waste storage capacity at Chickasaw, we also analyze an
operation in which wastes are delivered from generators to
intermediate storage at CWM's existing Emelle, Alabama storage
2-1
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facility—150 miles inland from Chickasaw—and are trucked from
there to the port to be loaded directly onto the Vulcanus. This
operation increases the total distance that the wastes are
shipped and the number of transfer operations involved in
delivering the wastes to port.I/
The analysis of land-based incineration is based on a
hypothetical incineration system, the characteristics of which
reflect (1) data on several existing incinerators and (2) our
assumptions about similarities and differences between a typical
land-based system and CWM's proposed operation. We employ a
hypothetical land-based system for two reasons. First/ because
numerous land-based incinerators may offer an alternative to
incineration aboard the Vulcanus, we did not wish to tie our
analysis to the configuration or location of a single facility.
Second, the throughput of PCB wastes for the Vulcanus exceeds the
capacity of each of the three land-based incinerators currently
permitted to burn PCBs. Since comparison of the risks from land-
and ocean-based systems requires identical waste throughputs, the
use of a hypothetical land-based unit is necessary.
Our comparison of risks from land- and ocean-based
facilities is based on annual throughput of 56,000 metric tons of
the PCB waste or 68,400 metric tons of the EDC waste defined in
Chapter 1. These throughputs are achievable if CWM does not
develop waste storage capacity at Chickasaw. If waste storage
capacity is installed at the port, our calculations show that
maximum throughput for the ocean-based system could increase by
35 to 55 percent (see Appendix A). We have used the lesser
throughputs as the basis for our analysis for two reasons:
I/We have not examined potential releases resulting from systems
like those proposed by Seaburn, Inc. and Oceanic Environmental
Services, Inc. Both companies propose to use Class 1 intermodal
containers to transport wastes. Seaburn plans to use a barge
with two horizontally mounted incinerators as the incineration
vessel. The barge would carry approximately 144 5,000 gallon
containers of wastes above deck. Oceanic Environmental proposes
to use a conventional offshore supply vessel outfitted with one
horizontally mounted incinerator. The vessel would carry
approximately 80,000 gallons of wastes in 16 containers stored
above deck. Each company proposes to use sea water scrubbers to
cool incinerator off-gases and direct them into the ocean.
2-2
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(1) CWM anticipates that demand for ocean incineration
services in the Gulf area, if permitted, would be
approximately 60,000 metric tons per year (even
with an improved port facility); and
(2) Use of the throughput estimate for the existing
facility allowed us to perform a sensitivity
analysis examining the risks associated with use
of intermediate waste storage at Emelle.
For both the land- and ocean-based systems, we have
organized our analysis of release quantities by three or four
components, respectively. As described in Chapter 1, these
components include:
o Land Transportation: transport of wastes by truck
from the generator site to the incinerator or .
pier;
o Transfer and Storage: transfer and storage
operations at the land-based incinerator, pier or
other storage facilities;
o Ocean Transportation: for the ocean-based system,
transport of wastes by ship from the pier to the
burn zone; and
o Incineration: incineration of the waste.
METHODS TO ESTIMATE QUANTITIES RELEASED
The releases from different system components vary from
relatively unlikely releases of large quantities of waste (such
as spills due to accidents involving tank trucks) to very likely
releases of small quantities of waste (such as stack emissions,
minor pump leaks, and so forth). In view of the stochastic nature
of releases from many of these release points, the quantity of
hazardous material released to the environment is likely to vary
from year to year. Estimation of release quantities must take
these variations into account.
2-3
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Ideally, one would determine the probability of release for
all possible release quantities at each release point. A
probability distribution of potential releases could be developed
for each release point and for the system as a whole. This
distribution would indicate the likelihood of releases for all
possible release quantities. Such distributions can be developed
for only a few components of the land- and ocean-based systems.
Thus, we develop estimates of the "expected value" of release —
the product of the probability of release and the average
quantity released for each release point. In addition, for each
point we estimate the probability that releasing events occur,
the total quantity at risk (i.e., the maximum spill possible),
and the average fraction of the quantity at risk released when an
event occurs. For convenience, we use the following abbreviations
and definitions throughout this report:
EN is the number of releasing events expected over a
one year period, and is calculated from underlying
probabilities of events multiplied by the level of
activity projected over the year,
Q is the quantity at risk, for example the contents
of one truck or one ship,
ERF is the expected release fraction if a releasing
event occurs,
QR is the average quantity released if a releasing
event occurs, and is the product of Q and ERF, and
EV is the expected value of release over a year, and
is the product of EN and QR.
None of these single metrics is adequate to describe the
underlying probability distribution of releases, but taken
together they provide a more complete picture of the
probabilities of release and quantities of hazardous material
involved in the ocean- and land-based systems.
Releases from the incineration component of each system are
continuous and certain to occur, although the magnitude of these
releases is uncertain. We estimate both stack and fugitive
losses of undestroyed wastes, products of incomplete combustion,
metals included in the waste stream, and chlorine (in a variety
of chemical forms). Our estimates of these quantities are based
on our assumptions about waste composition and incinerator
2-4
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performance and on our analysis of trial burn data for land- and
ocean-based incinerators.
To develop information on the probability and quantity of
releases, we rely on many sources of information including past
EPA and other studies, trade and academic literature, government
datasets, and judgments from various experts. All specific
sources are cited in the following chapters and appendices of
this report. EPA contracted with Engineering Computer
Optecnomics, Inc. (ECO) to provide information on vessel casualty
rates and spill quantities; and with Arthur D. Little, Inc. (ADD
to provide information and analyses on releases from transfer and
storage operations, and on the generation, composition and
disposition of scrubber effluent at land-based incinerators. Dr.
Jeff Kolb of EPA18 Office of Policy Analysis developed
information on comparable hazards as well as other data and
insights useful in the study.
HUMAN AND ENVIRONMENTAL EFFECTS ANALYZED
The release of hazardous wastes and combustion by-products
into the environment can cause a wide variety of effects. For
purposes of discussion, we group the effects of major concern
into four categories:
1. acute human health effects: effects caused by
short-term exposure to hazardous releases or by
explosions, fires and other accidental events;
2. chronic human health effects: effects caused by
long-term exposure to hazardous releases;
3. acute environmental effects: damages to
terrestrial and marine ecosystems due to short-
term exposures to hazardous releases; and
4. chronic environmental effects: damages to
terrestrial and marine ecosystems due to long-term
exposures to hazardous releases.
Hazardous releases from land- and ocean-based incineration
can be brought into contact with human and environmental
populations through a number of pathways, many of which involve
complex dispersion phenomena. The estimation of movement along
2-5
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these pathways and eventual human and environmental exposure is
extremely difficult, particularly at long distances and for
materials that are persistent and that bioconcentrate. Given
current scientific knowledge it is not possible to fully and
accurately predict the movement of hazardous materials once they
are released from incineration systems. Further, data to allow
accurate prediction of human health or environmental damage as a
function of exposure to acute and chronic levels of hazardous
materials are limited.
In view of these difficulties, we focus our efforts on those
release points, environmental pathways and human and
environmental effects we judge most important to the overall
comparison of land- versus ocean-based incineration. Exhibit 2-1
illustrates all possible combinations of the four release points
defined for incineration systems and the four types of human and
environmental effects outlined above. As the exhibit shows, our
major efforts concern the ocean transport and land- and ocean-
based incineration release points.
As Exhibit 2-1 shows, we have not evaluated the effects
resulting from land transportation releases. Since we have
assumed land transportation release quantities would be the same
for the land- and ocean-based systems, the resulting effects
would be equivalent, on average, for the two systems.
We evaluate acute human health effects for the ocean
transport release point, since inhalation of hazardous materials
volatilized from spills could affect human health. Acute human
health effects would not be expected from the other releases and
resulting environmental concentrations, with the possible
exception of land transportation accidents. However, acute
effects such as injury or death could occur as a result of land
or ocean transportation accidents, explosions or fires during
transfer or storage operations, and so forth. We have not
estimated the magnitude of these accidental injuries or deaths;
in view of the low probabilities assigned to these events the
expected effects would be very small. In addition, similar
accidents would be expected (except for those involving ocean
transportation) in both systems.
Our major efforts in transport and effects estimation
concern the ocean transportation and land and ocean incineration
release points. The dispersion of ocean transport spills and the
resulting effects on the marine ecosystem are estimated for
several spill locations and quantities. In addition, the
2-6
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bioconcentration of persistent compounds is estimated to provide
information on contamination levels and as a proxy for marine
chronic effects.
The releases from incineration itself occur continuously and
with certainty rather than only in the (unlikely) event of an
accident. We analyze the chronic human health effects expected
due to inhalation from stack emissions and to ingestion of food
contaminated by fallout from the stack plume. Further, we
consider possible effects on the marine ecosystem from deposition
of organic chemicals, metals and chlorine from the plume, and
effects on the land ecosystem from the final disposal of scrubber
effluent and sludge. We have not been able to consider the
effects of land-based stack emissions on the terrestrial
ecosystem due to limited time and resources. In addition to
these major efforts, we evaluate the chronic human health effects
expected from inhalation of fugitive releases from transfer and
storage.
lEc used several methods to estimate pollutant transport and
effects from ocean transportation releases and incinerator
releases for both land- and ocean-based systems. First, we used
EPA-developed air dispersion models and human health effects data
to estimate the human health risks due to inhalation of hazardous
materials released from land-based incinerators. In addition, we
used recent EPA studies to estimate additional human health risks
from ingestion of foodstuffs contaminated from incinerator stack
emissions. Further, lEc subcontracted with Applied Science
Associates, Inc. (ASA) to provide air dispersion analyses for the
ocean-based incinerator; lEc used these estimates with EPA human
health effects data to estimate human health risks from.
inhalation of ocean stack emissions.
For effects for ocean transportation releases, lEc
subcontracted with ASA to provide ocean transport and ecosystem
modeling for hypothetical spills at three sites: Mobile Harbor,
over the continental shelf on the ship's path to the burn zone,
and in the burn zone itself. Along with ASA's results, lEc
calculated the possible human health effects from marine spills
due to spill volatilization and subsequent human inhalation.
UNCERTAINTY
Our estimates of release from land- and ocean-based
incineration systems and the resulting human and environmental
2-7
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effects are highly uncertain. In view of this uncertainty, it is
useful to consider how these results should be interpreted and
whether they represent typical or "worst-case" outcomes. These
issues are discussed in the paragraphs below.
In conducting this analysis, we have structured system
components and waste streams which are roughly typical of ocean-
and land-based incineration. We have not located or configured
either system in a manner which would yield worst or best case
releases or effects. In addition, we have not assumed the worst
or best possible waste compositions. In short, the systems and
wastes analyzed are typical or average representations.
In estimating release probabilities and quantities, we often
were forced to use data not directly applicable to the
incineration system as structured. For example, in considering
land transportation releases we assumed a vehicle accident rate
similar to those experienced by tank trucks, and for ocean
transport our accident rates are estimated by adjusting
historical rates for tank ships to account for the design and
operating characteristics of the Vulcanus, rather than by relying
on the operating record of incinerator ships. Use of such data
was necessary since adequate information for incinerator systems
does not yet exist.
When specific information for transportation and handling
was not available, we selected other data conservatively. As a
result, we err on the side of overestimating release quantities
and probabilities. With the exception of releases from ocean
transport, this overestimation error is the same for both systems
and thus does not effect the evaluation of comparative risk. The
likely overestimate of ocean transport releases could bias the
analysis against the ocean-based system; however, these estimated
releases are a small portion of the expected long-term release
from the incineration systems.
Our estimates of the releases from incineration itself are
driven by our assumption about waste composition and incinerator
performance (undestroyed waste, metals, chlorine) and by our
analysis of trial burn data (PICs). Our estimates of PIC
emissions are extremely uncertain and could well be biased to the
low side. It is not possible to judge whether the extent of this
bias, as well as the overall uncertainty, are similar for the two
systems considered, and thus our PIC estimates could strongly
affect the comparative risk assessment.
2-8
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Available methods to estimate the dispersion of and effects
from releases of hazardous substances generally use conservative
methods. For example, both atmospheric and ocean dispersion
models rely on simplified representations of winds, currents and
other physical phenomena. This results in overestimation of
concentrations, especially at longer distances. Further,
coefficients developed to predict human or environmental damage
as a function of exposure or dose are often calculated at the 95
percent confidence interval and assume all of the compound is
biologically active. As a result, these dose-response factors
overestimate the actual effects likely from a given level of
exposure.
It is very difficult to consider all dispersion pathways and
effects for compounds that persist in the environment and which
bioaccumulate. For these compounds, available methods may
overestimate the effects considered while ignoring other effects
that occur at longer times and distances. If these latter
effects are important, our analysis may underestimate the total
eventual effects of such compounds.
In general, we have tried to use equally conservative data
and methods to estimate effects from land- and ocean-based
systems in order to generate comparable estimates. However,
precise data on the likely uncertainty in these estimates are not
available. Further, as explained previously, we were not able to
look at all possible effects for both systems. In particular,
limited time and resources precluded consideration of possible
effects of releases from either incineration system on the
terrestrial ecosystem.
As a result of these factors, we believe that while the
incineration systems considered are structured to be "average",
our estimates of release quantities and resulting effects are
biased to the high side. We have tried to be consistent in our
choice of methods and assumptions used to analyze each system,
and thus the differences shown between systems are less uncertain
and less biased. The purpose of this study is comparative
assessment of ocean- versus land-based incineration systems. The
validity of this comparison will be most strongly affected by
methods or assumptions (such as PIC rates, scrubber efficiency)
that change the relative performance of the systems.
2-9
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SUMMARY
This chapter has reviewed the measures, analytic methods and
general sources of data used in the study. In addition, the text
above provides further information on the assumed structure of
the incineration systems and on the sources, directions and
magnitudes of uncertainty in our results.
2-10
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Exhibit 2-1
POSSIBLE EFFECTS EVALUATED IN THE ANALYSIS
—.............. -Human effects——————— —————Environmental Effects——-—--—-
Release Point Acute Chronic Acute Chronic
•»««B
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WASTE QUANTITIES
RELEASED FROM LAND TRANSPORTATION CHAPTER 3
The analysis of releases from land transportation considers
two types of potential losses — vehicular accidents and enroute
container failures from causes such as loose fittings, corrosion
or internal pressure. Both of these events are probabilistic in
nature. We base our estimates of potential releases from such
events on existing studies of accident and failure rates and
available information on the size distribution of the resulting
spills. Using these data, we calculate the expected number of
annual releases, the average quantity of waste released given a
spill, and the expected annual release quantity. Below we
discuss our sources of data/ our assumptions, and characterize
the resulting releases. Final sections of the chapter review the
limitations of our estimates and compare our results with likely
releases from general commerce.
DATA SOURCES
The analysis of releases from land transportation is based
on several sources of information. Data concerning the frequency
of vehicular accidents and container failures were provided by
the U.S. Department of Transportation (DOT). Information on the
size of release (the percentage of total truck cargo discharged
in the event of an accident) was developed using DOT'S Hazardous
Materials Incident File (HAZMAT). Using this information we
estimate annual releases for trucks transporting hazardous wastes
from waste generators to CWM's, proposed Chickasaw, Alabama port
facility or to a land-based hazardous waste incinerator.
3-1
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ASSUMPTIONS
The analysis of releases from transporting wastes on land is
based on the following assumptions:
o Wastes are transported in 5000 gallon tank trucks;
o In the ocean-based case, the trucks carry wastes
an average of 250 miles from the generator to
CWM's proposed Chickasaw port facility; in the
land-based case, the trucks travel 250 miles from
the generator to a commercial land-based
incinerator;
o All other conditions (for example, speed, highway
composition, road surface, weather, traffic
volume, share of day and night travel) are
average.
It is important to emphasize that we assume equal trip
distances for the land- and ocean-based systems. Although the
average distance from generators to the transfer stations serving
land- and ocean-based incineration may differ, analysis of
typical trip distances is beyond the scope of the present study.
A study of trip distances would require information on the
location of generators, land-based incinerators, and future
ocean-based facilities, as well as data on the capacity of each
facility and the demand for incineration services.
To examine the effect of differing trip distances, we
perform a sensitivity analysis assuming waste storage capacity
does not exist at the port. In this case, we assume wastes
would be trucked 250 miles to CWM's existing storage facility in
Emelle, Alabama, stored there, and later transported 150 miles to
Chickasaw for immediate loading onto the Vulcanus. This scenario
increases the total trip distance in the ocean-based case from
250 to 400 miles.I/
I/CWM currently plans to construct storage tanks at Chickasaw.
The company may be prohibited from doing so, however, if the
tanks would be located in a floodplain. If the Vulcanus is
permitted before storage tanks are constructed, CWM plans to use
its Emelle facility as an intermediate storage site.
3-2
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RELEASES PROM VEHICULAR ACCIDENTS
According to DOT'S Bureau of Motor Carrier Safety, trucks
are involved in enroute vehicular accidents at a rate of about
1.2 accidents per million miles traveled. About 29 percent of
accidents involving tank trucks result in a release of cargo.2/
Therefore, we estimate the rate of releasing vehicular accidents
for tank trucks to be 0.35 per million miles traveled (0.29
releases per accident x 1.2 accidents per million miles).
We base our analysis of releases from vehicular accidents on
this accident rate, assuming that trucks that transport hazardous
wastes at worst experience the same release rate from vehicular
accidents as estimated for tank trucks. This assumption and
alternative estimates of releasing vehicular accident rates are
discussed later in this chapter.
Frequency of Vehicular Accidents
Given a releasing accident rate of 0.35 per million miles
traveled, the expected number of releasing accidents is a
function of the total number of miles traveled to deliver wastes
from the generator to Chickasaw or to the land-based incinerator.
In turn, this is a function of route length and the number of
shipments required to deliver the annual quantity of waste
incinerated.
Exhibit 3-1 summarizes the calculations used to estimate
the number of shipments required to transport 56,000 metric tons
of PCB wastes or 68,400 metric tons of EDC wastes. As the
exhibit shows, 151 shipments of PCB wastes would be required for
each voyage of the Vulcanus. Assuming 14 voyages per year for
the PCB waste (see Appendix A), 2,114 truckloads are required to
deliver the 56,000 MT annual throughput. More shipments (2,934)
are required to deliver the EDC waste each year, due to the
larger annual throughput and the lower density of the waste.
2/Derived from a memorandum from J. Nalevanko, Materials
Transportation Bureau, Research and Special Programs
Administration, Department of Transportation, to Dr. Jeff Kolb,
EPA, 30 January 1985.
3-3
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Exhibit 3-2 uses the above estimates to calculate the
expected number of vehicular accidents per year for the PCB and
EDC cases, assuming each shipment travels 250 miles. In the PCB
case, the total distance traveled is 528,500 miles annually. At
a releasing accident rate of 0.35 per million miles, the
expected number of releasing vehicular accidents is 0.18 per
year. The expected number of vehicular accidents in the EDC case
is about 0.26 per year, higher than the PCB case due to the
greater number of shipments and greater total distance traveled.
Waste Quantities
Released from Vehicular Accidents
Using HAZMAT data on the quantity of truck cargo lost in
releasing vehicular accidents, we estimate the fraction of total
cargo expected to be spilled if a releasing accident occurs. The
HAZMAT data give the following distribution of release fractions.
Table 3-1
Quantity Released in a Releasing Truck Accident
Percent of Capacity
Released Percent of Releases
0-10% 31.6%
10-30% 18.7
30-50% 13.3
50-70% 9.8
70-90% 11.9
90-100% 14.7
Source: HAZHAT
These data indicate that over 30 percent of releasing vehicular
accidents involve less than 10 percent of the total cargo.
However, 14.7 percent of releasing vehicular accidents involve
over 90 percent of the total cargo. The bimodal nature of the
distribution indicates that accidents tend to be either minor or
severe enough to cause a substantial loss of cargo. The average
(or expected) release is approximately 39.5 percent of total
cargo.
3-4
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Exhibit 3-3 shows the calculation of the expected annual
release from vehicular accidents for both the PCS and EDC cases.
These calculations are based on the quantity of cargo at risk,
the expected release fraction, and the expected number of annual
releasing accidents. The average release quantity for PCB wastes
is 10.5 metric tons, while the average release quantity for EDC
wastes is 9.2 metric tons. The expected annual release is 1.9
metric tons and 2.4 metric tons in the PCB case and EDC case,
respectively.
RELEASES FROM CONTAINER FAILURES
Frequency of Container Failures
The DOT data indicate that tank trucks transporting
hazardous wastes will experience enroute container failures from
causes other than vehicular accidents at a rate of about 0.43 per
million miles traveled. Again, the expected number of container
failures per year experienced by trucks carrying wastes is a
function of the total number of miles traveled to deliver the
waste from the generator to Chickasaw or to a land-based incine-
rator. Exhibit 3-4 shows the expected number of enroute
container failures is 0.23 per year in the PCB case and 0.32 in
the EDC case. The rate of release for EDC is greater than for
PCBs due to the greater number of miles driven.
Haste Quantities
Released from Container Failures
As with vehicular accidents, we use the HAZMAT data on the
quantity of truck cargo lost in the event of a container failure
to estimate the fraction of total cargo spilled. The data
indicate the following distribution.
3-5
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Table 3-2
Quantity Released from Container Failure
Percent of Capacity
Released Percent of Releases
0-10% 92.6%
10-20% 3.3
20-50% 2.0
50-100% 2.1
Source: HAZMAT
These data indicate that over 90 percent of enroute container
failures release less than 10 percent of the cargo. The average
release is approximately 4 percent of total cargo.
Exhibit 3-5 shows the calculation of the expected annual
release from enroute container failures for the PCB and EDC
cases. The expected annual release in the PCB case is
approximately 0.25 metric tons; and the expected annual release
in the EDC case is 0.29 metric tons.
CAVEATS AND SENSITIVITY ANALYSIS
Vehicular Accident Rate
The accident rate for trucks transporting hazardous wastes
could be lower than the rates estimated from DOT data for several
reasons.
1. The DOT data include trucks with aluminum tanks.
Trucks carrying wastes to Chickasaw or to a land-
based incinerator will have stainless steel tanks,
making them more resistant to puncture or rupture.
2. CWM plans to hire only experienced drivers,
provide special safety training, and take other
precautions to avoid accidents. These measures
should help reduce the likelihood that CWM trucks
will be involved in vehicular accidents.
3-6
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3. Data from several commercial waste management
firms indicate an average accident rate
(releasing and non-releasing) for all cargo
vehicles operated by these companies of about 0.8
per million miles. This estimate is based on
about 24 million vehicle miles of travel.
Additionally, no releases of hazardous wastes from
tank trucks due to accidents or container failures
were experienced in approximately 9 million miles
of travel. These accident and release rates are
significantly lower, at the 95 percent confidence
level, than the rates used in our analysis. We
infer from this that trucks transporting hazardous
wastes are less likely than other trucks to be
involved in releasing accidents.I/
In light of these considerations, we believe our estimates of
vehicular accident rates are higher than the actual accident
rate for tank trucks that carry hazardous wastes. Any change in
the assumed accident rate will have a proportional effect on the
the estimated release quantities.
Trip Distance and the Potential Effect
of intermediate Waste Storage at Emelle
A second factor affecting the analysis of releases from land
transport is the assumption that each shipment travels 250 miles.
The accident and container failure rates are expressed on an
incidents-per-mile basis. Therefore, estimates of both the
expected number of releases and the expected annual release
quantity are linearly related to the trip length assumed. Given
this relationshipr alternative trip distances would pro-
portionally affect expected annual release estimates.
To illustrate this effect, we recalculate the expected
number of releasing accidents and container failures per year and
the annual expected release quantity for the land transportation
component of the ocean-based incineration system, assuming that
wastes are stored at CWM's Emelle storage facility rather than at
I/Memorandum from Dr. Jeff Kolb (EPA) to Michael Huguenin (lEc),
"Transportation Data from Companies in the Hazardous Waste
Business," 24 September 1984.
3-7
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a newly-built storage facility in Chickasaw. As noted
previously, we assume that this arrangement adds 150 miles to the
average trip distance for each shipment of waste, raising the
total trip distance from 250 to 400 miles. The results are shown
in Exhibit 3-6.
As this exhibit shows, the total distance traveled increases
to 845,600 miles and over one million miles for the PCB case and
the EDC case, respectively. The expected number of releasing
accidents per year is about 0.30 in the PCB case and 0.41 in the
EDC case, with expected annual releases of 3.14 MT of PCB waste
and 3.79 MT of EDC waste. The expected number of enroute
container failures per year is about 0.36 in the PCB case and
0.50 in the EDC case, with expected annual releases of 0.38 NT of
PCB waste and 0.47 MT of EDC waste. These figures are about 60
percent greater than the expected releases in our baseline
analysis, reflecting the increase in miles traveled.
Effect of Remedial Action
As a final point, we note that most commercial hazardous
waste management firms maintain spill response teams trained to
control and remove wastes released in vehicular accidents or as
the result of container failures. Remedial action will reduce
the quantity of waste ultimately released to the environment, and
help to control the hazards presented by spills.
COMPARABLE HAZARDS
To compare the magnitude of possible releases from
transporting hazardous wastes to releases from the transport of
hazardous materials in daily commerce, we examined data on
releases of hazardous substances maintained by the U.S. EPA's
National Response Center (NRC).A/ According to the NRC, there
were 67 transportation-related hazardous substance releases in
EPA Region IV (an eight-state area of the southeastern U.S. that
includes Alabama) in the last seven months of 1982.
A/The NRC data were reported in ICF, Inc. , Release oJL
Production Volume Substances. April 1983. These data are
adjusted to remove petroleum and petroleum product spills, and
include only CERCLA-designated hazardous substances.
3-8
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Extrapolating these data to a full year suggests 115
transportation-related hazardous substance releases would occur.
The expected number of vehicular accidents and enroute container
failures involving trucks serving a land- or ocean-based
incineration system (0.41 per year in the PCB case and 0.58 per
year in the EDC case) would represent about 0.5 percent of the
estimated number of transportation-related releases of hazardous
substances reported to the NRC for Region IV.
SUMMARY OF RELEASES
FROM LAND TRANSPORTATION
Exhibit 3-7 summarizes the total expected annual release
quantities from the land transportation component of a land-based
and ocean-based incineration system. If hazardous waste
generators are on average equidistant from the waste transfer
stations serving land- and ocean-based incinerators, the expected
releases from the land transportation components of the two
systems are equal. As shown in this exhibit, the expected annual
releases are 2.1 MT for the PCB waste and 2.7 MT for the EDC
waste. The expected annual release from vehicular accidents is
about eight times the expected annual release from container
failures, despite the projection that slightly more releasing
container failures are likely to occur. The larger expected
release from vehicular accidents reflects the greater probability
that these events release a significant fraction of total truck
cargo.
Releases from the land transportation component of a land-
based or ocean-based incineration system can occur relatively
frequently. In the PCB case, an average of about 0.18 releasing
accidents and 0.23 container failures are expected per year. In
the EDC case, an annual average of about 0.26 releasing accidents
and 0.32 container failures are expected. However, many of these
releases would involve only a small quantity of waste. Almost 93
percent of enroute container failures are expected to release
less than ten percent of the total cargo. The release quantities
associated with vehicular accidents are larger, but 32 percent of
such incidents are expected to release less than ten percent of a
waste shipment.
Despite the expectation that the total release from trucks
transporting wastes will be small, there is still a possibility
that a significant release will occur. For example, we estimate
that there is about a 0.09 probability that a truck transporting
3-9
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EDC wastes will be involved in a vehicular accident that releases
more than 50 percent of its 23.4 metric ton cargo during any
particular year. Thus, it is important to bear in mind that
releases during any single year could be significantly greater
than the expected annual release quantity.
If transportation distances for the land- and ocean-based
systems differ, expected annual releases from land transportation
will also differ. This effect is illustrated by the analysis of
releases should CWM store wastes in Emelle rather than Chickasaw.
The 60 percent increase in transport distances associated with
this arrangement would increase expected'annual releases for the
land transportation component of the ocean-based system by a
corresponding percentage. Even in this case, however, the
expected number of releasing incidents involving tank trucks
serving an incineration system represents less than one percent
of the transportation-related releases of hazardous substances
currently reported for EPA Region IV.
Finally, available data for the hazardous waste management
industry indicate a relatively low frequency of releasing
accidents. These data suggest that our calculation of expected
releases is conservative and probably overstates the quantity of
waste released from land transportation.
3-10
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Exhibit 3-1
CALCULATION OF NUMBER OP SHIPMENTS REQUIRED
FOR TANK TRUCKS DELIVERING PCB OR EDC WASTES
Assumptions:
PCB Waste EDC Waste
Truck capacity (gallons) 5,000 5,000
Specific gravity 1.4000 1.2351
Ship capacity (metric tons, MT) 4,000 3,800
Voyages per year 14 18
Calculations: PCB Case
Cargo weight (MT) = 5,000 gallons x 3.785 liters/gallon *
1.4 kilograms/liter * 10E-3 MT/kilogram
= 26.5
Truckloads per
voyage = 4,000 MT per voyage/26.5 MT per truckload
= 151
Truckloads per
year = 151 truckloads per voyage * 14 voyages
per year
= 2,114
Calculations: EDC Case
Cargo weight (MT) = 5,000 gallons * 3.785 liters/gallon *
1.2351 kilograms/liter * 10E-3 MT/kilogram
= 23.4
Truckloads per
voyage = 3,800 MT per voyage/23.4 MT per truckload
= 163
Truckloads per
year = 163 truckloads per voyage * 18 voyages per
year
= 2,934
Source: lEc Analysis
-------
Exhibit 3-2
CALCULATION OF EXPECTED NUMBER (EN) OF RELEASING VEHICULAR
ACCIDENTS PER YEAR FOR TANK TRUCKS SERVING
LAND- OR OCEAN-BASED INCINERATION SYSTEMS
Assumptions:
PCB Waste EDC Waste
Truckloads per year 2,114 2,934
Trip length (miles) 250 250
Incident rate (IR)
(releasing accidents/mile) 3.5E-7 3.5E-7
Calculations: PCB Case
Annual
Involvement (AI) - 2,114 truckloads/year * 250 miles/truckload
= 528,500 miles/year
EN - AI * IR
= 528,500 miles/year * 3.5E-7 releasing
accidents/mile
= 0.18 releasing accidents/year
Calculations: EDC Case
AI = 2,934 truckloads/year * 250 miles/truckload
= 733,500 miles/year
EN - 733,500 miles/year * 3.5E-7 releasing
accidents/mile
= 0.26 releasing accidents/year
Source: lEc Analysis
-------
Exhibit 3-3
CALCULATION OF EXPECTED ANNUAL RELEASE (EV) FROM
VEHICULAR ACCIDENTS FOR TRUCKS SERVING
LAND- OR OCEAN-BASED INCINERATION SYSTEMS
PCB Waste
Assumptions:
Expected release fraction (ERF) = 0.395
Quantity at risk (Q) = 26.5 MT
Expected number of releases per year (EN) = 0.18
Calculations:
Average quantity
released (QR) = Q * ERF EV = QR * EN
= 26.5 MT * 0.395 = 10.5 MT * 0.18
= 10.4675 MT - 1.89 MT
EDC Waste
Assumptions:
ERF = 0.395
Q = 23.4 MT
EN =0.26
Calculations:
QR = Q * ERF EV = QR * EN
= 23.4 * 0.395 = 9.2 MT * 0.26
= 9.243 MT = 2.39 MT
Source: lEc Analysis
-------
Exhibit 3-4
CALCULATION OP EXPECTED NUMBER (EN) OF ENROUTE CONTAINER
FAILURES PER YEAR FOR TANK TRUCKS SERVING
LAND- OR OCEAN-BASED INCINERATION SYSTEMS
PCS Waste
Assumptions:
Annual involvement (AI) - 528,500 miles/year
Incident rate (IR) = 4.3E-7 container failures/mile
Calculation:
EN = AI * IR
» 528,500 miles/year * 4.3E-7 container failures/mile
» 0.23 container failures/year
EDC Waste
Assumptions:
AI = 733,500 miles/year
IR * 4.3E-7 container failures/mile
Calculation:
EN - AI * IR
« 733,500 miles/year * 4.3E-7 container failures/mile
= 0.32 container failures per year
Source: lEc Analysis
-------
Exhibit 3-5
CALCULATION OF EXPECTED ANNUAL RELEASE (EV) FROM
ENROUTE CONTAINER FAILURES FOR TRUCKS SERVING
LAND- OR OCEAN-BASED INCINERATION SYSTEMS
PCB Waste
Assumptions:
Expected release fraction (ERF) = 0.04
Quantity at risk (Q) = 26.5 MT
Expected number of releases per year (EN) = 0.23
Calculations:
Average quantity released (QR) = Q * ERF
= 26.5 MT * 0.04
, = 1.06 MT
EV = QR * EN
= 1.1 MT * 0.23
= 0.25 MT
EDC Waste
Assumptions:
ERF = 0.04
Q = 23.4
EN = 0.32
Calculations:
QR = Q * ERF
= 23.4 MT * 0.04
= 0.936 MT
EV = QR * EN
= 0 .9 MT * 0.32
= 0.29 MT
Source: lEc Analysis
-------
Exhibit 3-6
EFFECT OF STORAGE AT EMELLE, ALABAMA
ON EXPECTED RELEASE QUANTITIES
IN THE OCEAN-BASED INCINERATION SYSTEM
Assumptions
PCB Waste EDC Waste
Truckloads per year 2,114 2,934
Trip length (miles) 400 400
Quantity at risk (MT) 26.5 23.4
Releasing accident rate 3.5E-7 3.5E-7
Container failure rate 4.3E-7 4.3E-7
Fraction released
in event of accident 0.395 0.395
Fraction released
in event of container failure 0.04 0.04
Calculations
Total miles traveled 845,600 1,173,600
Expected number
of releasing accidents per year 0.30 0.41
Expected number
of container failures per year 0.36 0.50
Annual expected release
from accident (MT) 3.14 3.79
Annual expected release
from container failure (MT) 0.38 0.47
Source: lEc Analysis
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Exhibit 3-7
SUMMARY OF EXPECTED RELEASES FROM LAND TRANSPORTATION
Expected Number of Releasing Incidents
Vehicular Accidents
Container Failures
PCB Waste
0.18
0.23
EDC Haste
0.26
0.32
Annual Quantity Released (MT):
Vehicular Accidents
Container Failures
Total Release
1.89
0.25
2.14
2.39
0.29
2.68
Source: lEc Analysis
-------
RELEASES FROM
WASTE TRANSFER AND STORAGE CHAPTER 4
This chapter describes our analysis of releases during
transfer and storage of wastes for both ocean- and land-based
incineration systems. The analysis considers three sources of
releases —spills when transferring wastes to and from tank
trucks, spills from equipment at waste transfer and storage
facilities, and fugitive emissions from transfer and storage.
Fugitive emissions are slow leaks from pump fittings, sampling
connections, flanges, storage tanks and other equipment. Some
of these releases are probabilistic, while others are relatively
certain.
The following discussion describes our data sources and
assumptions and the resulting estimates of waste release
quantities for these three sources. This chapter also includes a
sensitivity analysis examining releases from transfer and storage
should CWM not build storage tanks at its port facility.
DATA SOURCES
The analysis of storage and transfer releases is based on
several sources. Data on release rates during truck loading and
unloading operations are based on data supplied by DOT, as cited
in Chapter 3. Information on the quantity of waste likely to be
released in the event of such spills was obtained from the HAZMAT
file, also described in Chapter 3. Arthur D. Little, Inc. (ADD
analyzed spills and fugitive emissions at storage and transfer
4-1
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sites. Appendix B summarizes the AOL analysis of these
releases.I/
ASSUMPTIONS
The analysis of waste releases during transfer and storage
is based on operation of the facility that CWM proposes to build
at its port in Chickasaw. We assume that similar transfer and
storage equipment is located at the land-based incinerator.
Appendix B gives a full description of the probable configuration
of this facility.
We also consider storage of waste at Emelle, rather than at
Chickasaw. This analysis considers the following sources of
releases:
o Spills when unloading and loading tank trucks at
Emelle and when unloading at Chickasaw;
o Spills from transfer and storage equipment at
Emelle and for transfer equipment at Chickasaw;
and
o Fugitive emissions from all equipment at both
Emelle and Chickasaw.
As this list suggests, intermediate waste storage at Emelle adds
several potential release points to the ocean-based incineration
system.
TRANSFERS TO AND FROM TANK TRUCKS
Frequency of Loading/Unloading Spills
The DOT data provide information on the rate at which.spills
at transportation terminals occur. The data indicate that
releases involving the loading and unloading of tank trucks occur
I/We used the DOT and HAZMAT data rather than the ADL analysis to
describe releases from loading and unloading tank trucks because
the ADL analysis is limited to releases from loading/unloading
arm failures, and does not consider other potential causes of
loading/unloading spills.
4-2
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at a rate of 1.7 per hundred thousand handlings. Thus, the
number of handlings involved in delivering waste to Chickasaw or
to a land-based incinerator will determine the probability of a
transfer release in a given year.
The assumptions for land transport given in Exhibit 3-1 of
Chapter 3 yield the following estimates of the number of
shipments required to deliver annual throughput quantities to
Chickasaw or to a land-based incinerator.
o PCB wastes: 2,114 shipments of approximately 26.5
NT each;
o EDC wastes: 2,934 shipments of approximately 23.4
NT each.
Each shipment must be unloaded at the termination of the trip.
(The original loading of the tank truck is excluded in our
analysis since this step occurs at the generator site.)
Based on these estimates. Exhibit 4-1 shows calculation of
the expected number of transfer spills in the PCB and EDC cases
for both ocean- and land-based incinerators. In the PCB case,
the expected number of spills is 0.04 per year. In the EDC case,
the expected number of transfer spills is 0.05 per year. The
slightly higher chance of a spill in the EDC case is a result of
the greater number of handlings required.
Waste Quantities Released
from Truck Dnloading Spills
HAZMAT data on the fraction of cargo lost in the event of a
transfer release suggest the following distribution of release
fractions.
Table 4-1
Quantity Released from Tranfer Operations
Percent of Capacity
Released Percent of Releases
0-10% 94.4%
10-20% 2.9
20-50% 2.0
50-100% 0.7
Source: HAZMAT
4-3
-------
These data indicate that over 94 percent of transfer spills
release less than 10 percent of the cargo. Less than one percent
involve 50 to 100 percent of the total load. The HAZHAT data
show that the average fraction released is approximately 3
percent.
Exhibit 4-2 illustrates the calculation of the expected
quantity of waste released while loading and unloading tank
trucks. The expected release quantity in the event PCB wastes
are spilled is 0.8 metric tons. In the EDC case, the expected
release quantity is 0.7 metric tons. Over a year the expected
release is approximately 0.03 metric tons in both the PCB and EDC
cases.
SPILLS AT TRANSFER AND STORAGE FACILITIES
Appendix B describes CWM's "improved" Chickasaw waste
storage and transfer facility and the storage and transfer
facility assumed for the land-based incinerator. The analysis of
the potential for spills at each site based on available failure
rate data for valves, pipes, loading hoses, and liquid storage
tanks also is provided in Appendix B. The results of this
analysis are summarized below.
Frequency of Spills at
Transfer and Storage Facilities
Exhibit 4-3 summarizes the expected number of releases per
year for the storage and transfer facilities at ocean-based and
land-based systems (exclusive of spills from unloading trucks).
As the exhibit indicates, the total expected number of releases
from all storage and transfer components of the ocean-based
system is 0.03 per year in the PCB case and 0.04 per year in the
EDC case. The total expected number of releases from the land-
based storage and transfer facility is approximately 0.04 for
both the PCB and EDC cases. The frequency of failures is
slightly higher for the land-based system since we assume the
pumps and pipelines at the land-based facility constantly contain
wastes, whereas approximately half of the pumps and pipelines for
the sea-based system (those required for vessel loading) are
assumed to carry wastes only during the 36-hour period required
to load the incinerator ship.
4-4
-------
As shown, the ocean-based system has one additional
component — the loading hose used to transfer wastes to the
ship. We estimate the probability of a spill from the hose to
be roughly two to three in one-thousand per year.
Pump failures are the single most likely cause of a release
at both Chickasaw and the land-based incinerator, with the total
expected number of releases from such failures ranging from .02
to .03 per year. In contrast, the- least likely sources of a
release are the two 800 thousand gallon waste storage tanks at
each site. For each system, the expected number of spills from
these tanks is 2.0E-4 per year, a long-term average of one spill
every 5,000 years.
Waste Quantities Released from
Spills at Transfer and Storage Facilities
Exhibits 4-4 and 4-5 present the average spill quantities
for each component of the storage and transfer networks for PCB
and EDC wastes, respectively. The exhibits also show the
expected annual release quantity for each component using the
frequency of spills from Exhibit 4-3. The exhibits indicate that
the expected annual release at storage and transfer facilities
for either ocean- or land-based incineration systems is
approximately 0.5 metric tons in both the PCB and EDC cases. In
each case, releases from storage tanks account for roughly 80
percent of the expected annual release. While a storage tank
failure is expected to occur only once in 5,000 years, the
expected release in the event of a failure is so large (1,870 to
2,115 metric tons) that this low probability, high release event
dominates the total expected annual release for both systems.2/
Again, the expected annual release from the land-based system is
slightly larger than the expected annual release for the ocean-
based system because of the greater likelihood of releases from
valves and pipelines at the land-based operation.
2/According to Appendix B, ADL's estimates of the probability of
a storage tank failure and the quantity of waste released in the
event of a failure apply to "catastrophic" releases. Minor
releases are not significant and are ignored.
4-5
-------
FUGITIVE EMISSIONS FROM
TRANSFER AND STORAGE FACILITIES
In addition to hazardous waste spills, storage and transfer
facilities are sources of airborne fugitive emissions. As
described in Appendix B, intermittent fugitive emissions at
Chickasaw or the land-based incinerator are associated with
occasional small leaks from pumps and valves in the waste storage
and transfer network. Relatively continuous sources of fugitive
emissions include ordinary breathing losses from storage tanks,
working losses that occur in filling and emptying tanks, and
activities such as manual gaging of tank truck cargo levels.
Exhibit 4-6 summarizes expected annual fugitive emissions
for the improved Chickasaw facility and for the land-based
incineration site. As the exhibit shows, expected fugitive
emissions for the ocean-based system are approximately 0.7 metric
tons per year in both the PCB and EDC cases. In comparison,
expected fugitive emissions for the land-based system are 0.6
metric tons per year for both wastes. Fugitive releases are
slightly higher for the ocean-based system due to the emissions
associated with loading the incinerator ship's cargo tanks.
Otherwise, fugitive emissions from the transfer and storage
facilities are identical. Emissions from storage tanks dominate
total fugitive emissions in both cases, accounting for
approximately two-thirds of total releases for the ocean-based
system and 80 percent of total releases for the land-based
operation.
CAVEATS AND SENSITIVITY ANALYSIS
Releases from an Ocean-Based System
Assuming Intermediate Storage at Emelle
As described in Chapter 3, CWM would store wastes at its
Emelle, Alabama storage facility if development of waste storage
capacity at Chickasaw is not feasible. This arrangement requires
I/Note that the ADL analysis contained in Appendix B assumes the
same vapor pressure for the PCB and EDC wastes, and therefore
does not consider the effect that different volatilization rates
could have on emissions from storage tanks.
4-6
-------
tank trucks to unload wastes at Emelle, reload to deliver wastes
to the Vulcanus, and unload again at the port. Tripling the
number of truck loading/unloading steps in this manner triples
the expected number and annual quantity of loading/unloading
spills, as shown in Exhibit 4-7. The expected number of
loading/unloading spills annually is 0.11 and 0.15 for the PCB
and EDC wastes, respectively. The expected release quantity is
0.09 HT of PCB waste and 0.11 NT of EDC waste.
Intermediate waste storage at Emelle also would affect
expected releases from storage and transfer equipment. Under
this arrangement, the existing storage and transfer equipment at
both Emelle and Chickasaw would be potential release sources.
The expected number of releases from the various components of
the two facilities is summarized in Exhibit 4-3. The exhibit
indicates that the total number of releases expected for the two
facilities is 0.07 per year in the PCB case and 0.08 per year in
the EDC case, slightly more than double the expected number of
releases in the baseline analysis of the ocean-based system. The
higher number of releases is primarily due to a greater number of
pump failures, since the combined Emelle/Chickasaw system
requires more than twice as many pumps as an integrated port
facility.
Exhibits 4-9 and 4-10 summarize expected release quantities
for the Emelle/Chickasaw transfer and storage system for the PCB
and EDC wastes, respectively. The expected quantity released,
excluding storage tanks, is about 0.16 and 0.18 metric tons for
the PCB and EDC wastes, respectively. These figures are about
double those estimated for the improved Chickasaw facility.
However, as the exhibits show, the expected total annual release
in both cases is approximately 0.4 metric tons, 0.1 metric tons
less than the release expected for the improved Chickasaw
facility. The lower total release for the non-integrated
facility is due to the assumption that wastes would be stored at
Emelle in four 200 thousand gallon storage tanks rather than the
two 800 thousand gallon tanks assumed for the integrated
Chickasaw operation. This assumption reduces by half the total
quantity of waste "at risk" in storage tanks at any point in time
— 800 thousand gallons at Emelle versus 1.6 million gallons at
4-7
-------
an integrated Chickasaw facility — and therefore reduces by half
the expected annual release from this source.!/
Exhibit 4-11 illustrates expected annual fugitive emissions
for the ocean-based incineration system, assuming that wastes are
stored at Emelle. The exhibit indicates that fugitive emissions
would total 4.9 metric tons per year in the PCB case and 5.5
metric tons per year in the EDC case. These estimates are more
than seven times higher than the fugitive emission estimates made
for an integrated Chickasaw facility. Fugitive emissions are
considerably higher for storage at Emelle since ADL assumed the
storage tanks at Emelle would have fixed roofs, as opposed to the
tanks with floating internal covers assumed for the new Chickasaw
operation. As explained in Appendix B, the use of floating
covers minimizes vapor spaces and significantly reduces fugitive
emissions.
Total expected annual releases for the Emelle/Chickasaw
storage and transfer system are summarized below.
Table 4-2
Summary of Storage and Transfer Releases for
Emelle/Chickasaw Configuration
PCB Haste EDC Waste
(MT per year) (MT per year)
Truck loading/
unloading spills 0.1 0.1
Spills at transfer/
storage facilities 0.4 0.4
Fugitive emissions 4.9 5.5
Total releases 5.4 6.0
Source: lEc Analysis
4/This assumption by ADL introduces a minor inconsistency in our
analysis. Assuming that the improved port facility has twice the
storage capacity implies that the wastes are held in storage for
a longer period of time or that the tanks are only filled to half
capacity compared to the Emelle storage facility.
4-8
-------
The net effect of intermediate waste storage at Emelle rather
than development of an integrated storage and port facility at
Chickasaw is an increase in the expected annual releases for the
storage and transfer component of an ocean-based incineration
system from 1.2 metric tons to 5.4 metric tons in the PCB case
and to 6.0 metric tons in the EDC case. Both cases present about
a fivefold increase in releases from storage and transfer
operations, and yield total releases about five times greater
than that estimated for the land-based incineration system.
Effect of Remedial Action
It is important to note that hazardous waste transfer and
storage facilities typically are equipped to contain most waste
spills. For example, the existing storage tanks at Emelle are
located in spill containment areas, and the existing waste
transfer station in Chickasaw has a spill containment area.
Spill containment equipment is also likely to be present at most
land-based incineration facilities. These precautions limit the
health and environmental effects from hazardous waste releases.
COMPARABLE HAZARDS
During the last seven months of 1982, 132 releases of
hazardous substances occurred at "fixed facilities" (i.e., not
vehicles) in EPA Region IV and were reported to the U.S. EPA's
National Response Center.i/ Extrapolating over a full year, we
estimate that 226 hazardous materials spills of this type would
occur in Region IV. In contrast, the expected number of spills
from the waste storage and transfer systems at Chickasaw or a
land-based incinerator (including truck loading/unloading spills
and spills from transfer and storage equipment) is approximately
0.1 in both the PCB and EDC cases. Thus, the expected number of
spills from ocean- or land-based incinerator waste storage and
transfer operations represents less than 0.1 percent of the
region's reported fixed facility hazardous materials spills.
5/ICF, Inc., Releases £f flicjh. Production Volume Substances. April
1983. As explained previously, these are CERCLA-designated
hazardous substances.
4-9
-------
Data to compare the total quantity of fugitive emissions
from the ocean- and land-based incineration systems are
unavailable. However, thirty waterfront facilities in the Port
of Mobile currently are authorized to handle and/or store
federally-designated hazardous materials.fi/ The number of these
facilities near Mobile suggests that other sources of hazardous
fugitive emissions exist in the area.
SUMMARY OF STORAGE
AND TRANSFER RELEASES
The estimated releases associated with the storage and
transfer component of ocean- and land-based incineration systems
are summarized in Exhibit 4-12. The summary does not distinguish
between the PCB and EDC wastes since the expected release
quantities (rounded to the nearest 100 kilograms) are identical.
As this table indicates, expected annual releases from the ocean-
and land-based systems differ only slightly, due to the higher
level of fugitive emissions for the ocean-based alternative. The
table also shows that spills and fugitive emissions are
approximately equal sources of storage and transfer releases,
each accounting for roughly half the expected annual storage and
transfer losses in both the ocean- and land-based case.
As shown in our sensitivity analysis, these release
estimates are very sensitive to the configuration of the
storage/transfer facilities. If CWM stored wastes at Emelle
rather than Chickasaw, the release quantities would be greatly
increased, primarily due to fugitive emissions resulting from the
use of fixed rather than floating roof storage tanks at the
Emelle facility. Also, the expected number and quantity of truck
loading/unloading spills would triple, as a result of tripling
the number of handlings required.
Again, it is important to bear in mind that waste spills
during any single year could be significantly greater than the
expected annual release quantity. For example, a single storage
tank failure could release approximately 2,000 metric tons of
hazardous waste. However, the probability of such an event is
extremely low — about one in 5,000 per year.
^./Personal communication with Captain W.J. Ecker, U.S. Coast
Guard, Captain of the Port, Mobile, Alabama.
4-10
-------
Exhibit 4-1
CALCULATION OF EXPECTED NUMBER (EN) OP LOADING/UNLOADING
SPILLS PER YEAR FOR TANK TRUCKS SERVING
LAND- AND OCEAN-BASED INCINERATION SYSTEMS
PCS Waste
Assumptions:
Annual involvement (AI) =• 2,114 transfers/year
Incident rate (IR) = 1.7E-5 spills/transfer
Calculation:
EN = AI * IR
= 2,114 transfers/year * 1.7E-5 spills/transfer
= 0.04 spills/year
/
EDC Waste
Assumptions:
AI = 2,934 transfers/year
IR = l*7E-5 spills/transfer
Calculation:
EN = AI * IR
= 2,934 transfers/year * 1.7E-5 spills/transfer
= 0.05 spills/year
Source: lEc Analysis
-------
Exhibit 4-2
CALCULATION OF EXPECTED ANNUAL RELEASE (EV) FROM
UNLOADING SPILLS FOR TRUCKS SERVING
LAND- OR OCEAN-BASED INCINERATION SYSTEMS
PCB Waste
Assumptions:
Expected release fraction (ERF) - 0.03
Quantity at risk (Q) - 26.5 MT
Expected number of releases per year (EN) = 0.04
Calculation:
Average quantity released (QR) = Q * ERF
= 26.5 MT * 0.03
= 0.795 MT
EV - QR * EN
= 0.8 MT * 0.04
- 0.032 MT
EDC Waste
Assumptions:
ERF =0.03
Q « 23.4 MT
EN = 0.05
Calculation:
QR = Q * ERF EV = QR * EN
= 23.4 MT * 0.03 = 0.7 MT * 0.05
«= 0.702 MT » 0.035 MT
Source: lEc Analysis
-------
Exhibit 4-3
EXPECTED NUMBER OF SPILLS (EN) PER YEAR
FOR WASTE TRANSFER AND STORAGE FACILITIES
SERVING LAND- AND OCEAN-BASED INCINERATION SYSTEMS
Ocean-Based System-Improved Chickasaw Facility
Component
Valves
Pipelines
Pumps
Loading Hose (ship)
Storage Tanks
Total
Frequency for
PCB Waste
4.8E-3
4.2E-3
2.1E-2
2.0E-3
2.0E-4
Frequency for
EDC Waste
4.8E-3
4.3E-3
2.7E-2
2.6E-3
2.0E-4
3.22E-2
3.98E-2
Land-Based System:
Component
Valves
Pipelines
Pumps
Storage Tanks
Total
Frequency for
PCB Waste
8.9E-3
6.7E-3
2.1E-2
2.0E-4
Frequency for
EDC Waste
8.9E-3
6.7E-3
2.7E-2
2.0E-4
3.7E-2
4.3E-2
Source: ADL Analysis, Appendix B.
-------
Exhibit 4-4
EXPECTED RELEASE QUANTITIES FOR SPILLS AT WASTE TRANSFER
AND STORAGE FACILITIES:
PCB WASTE
Ocean-Based System — Improved Chickasaw Facility:
Component
Valves
Pipelines
Pumps
Loading Hose (ship)
Storage Tanks
Total
Spill Size
(MT)
3.4
6.9
1.1
6.9
2,114.6
Expected Annual
Release
(MT)
1.63E-2
2.90E-2
2.31E-2
1.38E-2
4.23E-1
5.05E-1
Land-Based System:
Component
Valves
Pipelines
Pumps
Storage Tanks
Total
Spill Size
(MT)
3.4
6.9
1.1
2,114.6
Expected Annual
Release
(MT)
3.03E-2
4.62E-2
2.31E-2
4.23E-1
5.23E-1
Source: ADL Analysis, Appendix B
-------
Exhibit 4-5
EXPECTED RELEASE QUANTITIES FOR SPILLS AT WASTE TRANSFER
AND STORAGE FACILITIES:
EDC WASTE
Ocean-Based System — Improved Chickasaw Facility:
Component
Valves
Pipelines
Pumps
Loading Hose (ship)
Storage Tanks
Total
Spill Size
(MT)
3.0
6.1
1.0
6.1
1,869.8
Expected Annual
Release
(MT)
1.44E-2
2.62E-2
2.70E-2
1.59E-2
3.74E-1
4.58E-1
Land-Based System:
Component
Valves
Pipelines
Pumps
Storage Tanks
Total
Spill Size
(MT)
3.0
6.1
1.0
1,869.8
Expected Annual
Release
(MT)
2.67E-2
4.09E-2
2.70E-2
3.74E-1
4.69E-1
Source: ADL Analysis, Appendix B.
-------
Exhibit 4-6
EXPECTED ANNUAL FUGITIVE EMISSIONS FROM TRANSFER
AND STORAGE FACILITIES
Ocean-Based System — Improved Chickasaw Facility:
Source
Truck gaging
Pumps
Valves
Storage tanks
Ship cargo tanks
Total
PCB Waste EDC Waste
Expected Percent of Expected Percent of
Emissions Total Emissions Total
(MT/yr) Emissions (MT/yr) Emissions
3.2E-2
3.0E-2
4.2E-2
4.6E-1
1.1E-1
6.7E-1
4.8%
4.5
6.3
68.7
16.4
4.4E-2
3.0E-2
4.3E-2
4.7E-1
1.4E-1
100.0%
7.2E-1
6.1%
4.2
6.0
65.3
19.4
100.0%
Land-Based System:
Source
Truck gaging
Pumps
Valves
Storage tanks
Total
PCB Waste
Expected Percent of
Emissions Total
(MT/yr) Emissions
3.2E-2
3.0E-2
4.2E-2
4.6E-1
5.6E-1
5.7%
5.3
7.4
81.6
100.0%
EDC Waste
Expected Percent of
Emissions Total
(MT/yr) Emissions
4.4E-2
3.0E-2
4.3E-2
4.7E-1
5.8E-1
7.5%
5.1
7.4
80.0
100.0%
Note: Totals may not sum due to rounding.
Source: ADL Analysis, Appendix B.
-------
Exhibit 4-7
EFFECT OF STORAGE FACILITY AT EMELLE
ON TRUCK LOADING/UNLOADING RELEASES
IN OCEAN-BASED INCINERATOR SYSTEM
Annual Involvement
(transfers/year)
Incident Rate
Expected Number of
Releases
Quantity at Risk (MT)
Expected Release
Fraction
Expected Quantity
Released (MT)
PCB Waste
6,342
1.7E-5
0.11
26.5
0.03
0.09
EDC Waste
8,802
1.7E-5
0.15
23.4
0.03
0.11
Source: lEc Analysis
-------
Exhibit 4-8
EXPECTED NUMBER OF SPILLS PER YEAR
FROM UNIMPROVED WASTE TRANSFER AND STORAGE FACILITIES
AT EMELLE AND CHICKASAW
Component
Frequency for
PCB Waste
Frequency for
EDC Waste
Emelle:
Valves
Pumps
Storage Tanks
7.9E-3
3.0E-2
4.0E-4
7.9E-3
3.9E-2
4.0E-4
Subtotal
3.83E-2
4.73E-2
Chickasaw;
Valves
Pumps
Pipelines
Loading Hose
1.4E-3
1.5E-2
1.2E-3
l.OE-2
1.7E-3
1.9E-2
1.5E-3
1.3E-2
Subtotal
2.76E-2
3.52E-2
Total:
Valves
Pumps
Pipelines
Loading Hose
Storage Tanks
9.3E-3
4.5E-2
1.2E-3
l.OE-2
4.0E-4
9.6E-3
5.8E-2
1.5E-3
1.3E-2
4.0E-4
TOTAL
6.59E-2
8.25E-2
Source: ADL Analysis, Appendix B.
-------
Exhibit 4-9
EXPECTED RELEASE QUANTITIES FOR SPILLS
FROM UNIMPROVED WASTE TRANSFER AND STORAGE FACILITIES
AT EMELLE AND CHICKASAW:
PCB WASTE
Emelle:
Component
Valves
Pumps
Storage Tanks
Subtotal
Spill Size
(MT)
3.4
1.1
529.9
Expected Annual
Release
(MT)
2.69E-2
3.30E-2
2.12E-1
2.72E-1
Chickasaw:
Valves
Pumps
Pipelines
Loading Hose
Subtotal
3.4
1.1
6.9
6.9
4.76E-3
1.65E-2
8.28E-3
6.90E-2
9.85E-2
Total:
Valves
Pumps
Pipelines
Loading Hose
Subtotal
Storage Tanks
TOTAL
3.4
1.1
6.9
6.9
529.9
3.16E-2
4.95E-2
8.28E-3
6.90E-2
1.59E-1
2.12E-1
3.70E-1
Source: ADL Analysis, Appendix B.
-------
Exhibit 4-10
EXPECTED RELEASE QUANTITIES FOR SPILLS
FROM UNIMPROVED WASTE TRANSFER AND STORAGE FACILITIES
AT EMELLE AND CHICKASAW:
EDC WASTE
Emelle:
Component
Valves
Pumps
Storage Tanks
Subtotal
Spill Size
(MT)
3.0
1.0
467.4
Expected Annual
Release
(MT)
2.37E-2
3.90E-2
1.87E-1
2.50E-1
Chickasaw:
Valves
Pumps
Pipelines
Loading Hose
Subtotal
3.0
1.0
6.1
6.1
5.10E-3
1.90E-2
9.15E-3
7.93E-2
1.13E-1
Total:
Valves
Pumps
Pipelines
Loading Hose
Subtotal
Storage Tanks
TOTAL
3.0
1.0
6.1
6.1
467.4
2.88E-2
5.80E-2
9.15E-3
7.93E-2
1.75E-1
1.87E-1
3.62E-1
Source: ADL Analysis, Appendix B,
-------
Exhibit 4-11
EXPECTED ANNUAL FUGITIVE EMISSIONS FROM UNIMPROVED WASTE TRANSFER
AND STORAGE FACILITIES AT EMELLE AND CHICKASAW
Emelle:
Source
Chickasaw;
Truck gaging
Pumps
Valves
Storage tanks
Truck loading
Subtotal
Truck gaging
Pumps
Valves
Ship cargo tanks
Subtotal
PCB Waste
Expected Percent
Emissions of Total
(MT/yr) Emissions
TOTAL
3.2E-2
1.5E-2
8.0E-2
4.0E+0
5.7E-1
4.7E+0
3.2E-2
1.5E-2
1.1E-2
1.1E-1
1.7E-1
4.9E+0
96.6
0.7
0.3
0.2
2.2
IT?
100.0%
6UV, *
Expected
Emissions
(MT/yr)
4.4E-2
1.5E-2
8.0E-2
4.4E+0
7.3E-1
5.3E+0
4.4E-2
1.5E-2
1.5E-2
1.4E-1
2.1E-1
5.5E+0
Percent
of Total
Emissions
0.8%
0.3
1.5
80.0
13.3
96.2
0.8
0.3
0.3
2.5
3.8
100.0%
Note: Totals may not sum due to rounding.
Source: ADL analysis, Appendix B.
-------
Exhibit 4-12
EXPECTED RELEASES (EV) FROM STORAGE AND TRANSFER COMPONENT OF
LAND-BASED AND OCEAN-BASED INCINERATOR SYSTEMS
Source Ocean-Based Land-Based
* Less than 0.05 MT
Source: lEc Analysis
Truck Unloading/Loading
Spills ~ * — *
Spills at Transfer/Storage
Facilities 0.5 0.5
Fugitive Emissions 0.7 0.6
Total Quantity Released (MT) 1.2 1.1
-------
WASTE RELEASES
PROM OCEAN TRANSPORTATION CHAPTER 5
The ocean transportation component of ocean-based
incineration is the only major component of the system that has
no parallel in a land-based operation. Therefore, potential
releases from ocean transportation are of special interest when
comparing the relative risks of land- and ocean-based
incineration systems. These potential releases are discussed in
this chapter.
DATA AND ASSUMPTIONS
The analysis of spills from the Vulcanus as a result of a
vessel casualty is based on an analysis of vessel casualty rates
and expected release quantities prepared by Engineering Computer
Optecnomics, Inc. (ECO). This analysis, contained in Appendix C,
groups vessel casualties into three impact categories
(collisions, groundings and rammings) and one non-impact category
(fires, explosions, structural failures, and capsizings). The
analysis provides estimates of vessel casualties and resulting
spills at four different locations:
o Mobile Harbor and the Vulcanus1 pier in Chickasaw;
o Mobile Bay;
o The Gulf coastal area; and
o The burn zone.
5-1
-------
All estimates are based on a proprietary, worldwide tank ship
accident and spill database (entitled ECOTANK) that is maintained
by ECO. This database presently contains information about
10,000 worldwide tank ship accidents and over 1/000 tank ship
spill events that occurred from 1969 to 1982. As described in
Appendix C and later in this chapter, ECO has adjusted these
spill rate estimates to account for the design and operation of
the Vulcanus.
Incinerator ships have operated off the European coast in
the North Sea since 1972. They have made about 320 voyages and
have incinerated about 650,000 metric tons of hazardous wastes to
date. No casualties such as collisions, groundings, rammings, or
fires have occurred, nor have there been any spills from loading
incinerator ships in port. Although incinerator ship operations
have established a good safety record, the number of voyages
completed is too small to be used in estimating spill rates.
Thus, we rely on accident data for tankers to estimate spills for
the Vulcanus.
ESTIMATION OF RELEASING VESSEL
CASUALTY (SPILL) RATES
ECO selected from its database accidents and spill events
for tank ships of a size similar to the Vulcanus — from 2,000 to
10,000 deadweight long tons. These data were used to estimate
releasing vessel casualty or "spill" rates for four types of
accidents and for areas corresponding to the locations of
interest for the proposed operation of the Vulcanus. These spill
rates were then adjusted for the design, location, and operating
features for the Vulcanus that are expected to reduce the
frequency of spills below that experienced worldwide by tank
ships of similar size.
The design features adjusted for include the double hull,
double bottom construction of the Vulcanus and the ship's
controllable pitch (CP) propeller with bow thruster. The double
hull, double bottom construction is expected to reduce the
probability that cargo is released in the event of an accident,
and the CP propeller with bow thruster is expected to reduce the
probability of impact-type accidents, especially at low speeds,
by improving the maneuverability of the vessel. With regard to
location, the generally soft-bottom conditions in the Gulf are
expected to reduce the rate of spills due to groundings below the
5-2
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rate experienced worldwide. Finally, operating restrictions that
the Coast Guard plans to impose also are expected to reduce spill
rates.
As an example of the operating restrictions noted above, the
Coast Guard will require all movements of the Vulcanus in the
Port of Mobile, both inbound and outbound, to be under the
direction of the Captain of the Port, and a 24 hour advance
notice will be required prior to the ship entering Mobile Bay.I/
This notice will include a report on the condition of the
vessel's propulsion, steering, navigation and cargo systems. The
Coast Guard will allow the Vulcanus to transit the harbor only
during daylight hours, with a minimum of two miles visibility.
In addition, the Captain of the Port will issue a local Notice To
Mariners establishing a moving safety zone of 300 feet in all
directions around the ship. Vessels will be prohibited from
entering this zone without specific approval. The effect of the
safety zone is to prohibit oncoming vessels from the Mobile
Harbor ship channel while the Vulcanus is in the harbor, and to
keep vessels traveling in the same direction as the Vulcanus at
least 300 feet away. The Coast Guard will escort the Vulcanus to
enforce the safety zone. The Coast Guard also will require the
ship to be escorted by two tugs while it is in the harbor. While
the ship is in transit in the Gulf or in the Gulf burn zone, the
USCG will broadcast a Notice To Mariners notifying them of the
ship's position and advising them to steer clear of the vessel.2/
I/The discussion of USCG provisions governing the Vulcanus is
based on the statement of Rear Admiral Clyde T. Lusk, Jr., Chief,
Office of Merchant Marine Safety, United States Coast Guard,
before the House Subcommittee on Fisheries and Wildlife
Conservation and the Environment, Subcommittee on Oceanography,
December 7, 1983.
2/In addition to these operating precautions, USCG inspection
requirements for incineration vessels include annual inspection
of navigational and fire-fighting equipment, biennial inspection
of the exterior of the hull and interior of the cargo tanks, and
ultrasonic testing of hull thickness every five years. These
steps should ensure the maintenance of the ship's navigational
and structural integrity as long as it is permitted to incinerate
hazardous wastes, and reduce the probability of non-impact
related casualties.
5-3
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The precise effect that these factors may have in reducing
the rate of spills is difficult to determine. The adjustments
made are based on published studies, observed differences in
spill rates, kinetic energy levels likely for accidents in
different locations, and professional judgment. No downward
adjustments were made to the spill rate for non-impact type
accidents because of insufficient information. The calculations
of spill rates and the adjustments made to them are fully
discussed in Appendix C.
The results of ECO's calculations are summarized in Exhibit
5-1. These data give spill rates (any size spill) for each
location and type of casualty on a per voyage basis. The overall
spill rate is quite low — about 6 per 100,000 voyages. The data
in Exhibit 5-2 show the relative frequency of spills by location
and type of casualty, i.e., which locations and types of
casualties have greater or lesser probability of occurence.
These data indicate that the pier and coastal areas have the
highest expected spill rates — about 70 percent of spills would
be expected to occur in those areas.I/
WASTE QUANTITIES RELEASED
ECO also estimated the probability that accidents resulting
in a spill involve one, two, and three or more tanks. Their
estimates for impact type casualties (collisions, groundings, or
rammings) are as follows:
o one tank - 80 percent
o two tanks - 15 percent
o three or more tanks - 5 percent
There is little information on which to base such estimates for
non-impact type casualties. Accordingly, the same distribution
is assumed, but there obviously is some amount of uncertainty
regarding this assumption.
I/Most of the risk of spill in the "pier and harbor" area is from
non-impact type accidents during loading at the pier. These
rates were not adjusted downward, as explained in the text, so
they are conservative upper-bound estimates.
5-4
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The data in Exhibit 5-1, along with the data above on the
percentage of spills involving one, two, or more tanks, may be
used to calculate the spill rates by location and number of
tanks involved. Exhibit 5-3 expresses these spill rates on a per
voyage basis, while Exhibit 5-4 gives estimated spill rates (for
the PCB case) in terms of operating years. These data indicate
that spills in any location are very unlikely. The overall
average spill rate is 6 per 100,000 voyages, or about 1 spill per
1,200 operating years. The rate of spill events where two or
three or more tanks are involved is even lower — 9 and 3 spills
per million voyages, respectively. These rates equal an average
of one two-tank spill per 8,000 operating years, and one spill of
three or more tanks per 24,000 operating years. Spill rates for
particular locations are, of course, less than the overall spill
rate. For example, the spill rates for Mobile Bay when one, two,
or three or more tanks are involved are 1 per 13,000, 67,000, and
200,000 operating years, respectively, with an overall spill rate
of 1 per 10,000 operating years.
The amount of cargo likely to be released from a tank
affected by an accident depends on many factors, such as the
nature of the accident (the location and extent of damage to the
tank), the specific gravity of the waste, sea conditions, and the
length of time before some action is taken to lessen cargo
outflow. For example, in many collisions the impact is severe
enough to put the cargo in free communication with the sea. In
such accidents virtually the entire cargo of a tank could be lost
in a relatively short period of time. Groundings, on the other
hand, usually crack or puncture the hull far below the water
line. The pressure from cargo in the tank that resides above the
water line usually will force a portion of the cargo out of the
tank. The amount of additional cargo loss and the time over
which it will occur depends on the extent of the damage and the
density of the waste relative to sea water. Wastes with
densities greater than sea water will tend to flow out as sea
water flows in and floats to the top of the tank. Outflow of
waste of lesser density probably would not be as extensive.
Finally, rammings tend to create punctures at or near the water
line. Cargo above the water line would be lost rather quickly.
Cargo below the water line could also be lost if the density of
the waste were less than sea water and the sea water was able to
circulate into the tank, allowing the lighter waste to float out.
5-5
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We have not developed spill size distributions or expected
spill sizes for accidents involving various numbers of tanks,
since data are not available to make such estimates. Rather, we
have made the conservative assumption that the entire contents of
tanks affected by accidents are released.
The "expected" amount of waste released on an annual basis
is calculated for PCS and EDC wastes in Exhibit 5-5. We
emphasize that the expected values represent an annual average
used only as an index to compare releases from the various
components of incineration systems and do not suggest that spills
would occur each year. Expected annual releases are estimated to
be about 0.63 MT for PCB wastes and 0.77 MT for EDC wastes.
These calculations are conservative, in that we assume that any
tank involved in a spill releases its entire contents, and that
the entire ship's cargo is released in accidents involving three
or more tanks. The expected values reflect the large quantity of
waste that could be released in a spill and the extremely low
probability that a spill would occur. As noted above, the
estimated spill rate for the Vulcanus is 6 per 100,000 voyages,
or (in the PCB case) 1 per 1,200 operating years. Given these
estimates, it is unlikely that a spill will occur within the
ship's operating life.
CAVEATS AMD SENSITIVITY ANALYSIS
Vessel Casualty Rates
The vessel casualty rates employed to analyze potential
releases from the Vulcanus are based on historic ship casualty
data, with consideration of the specific conditions under which
the Vulcanus would operate. The casualty estimates account for
such factors as U.S. Coast Guard (USCG) requirements, the double-
hulled, double-bottomed design, the use of a CP propeller with
bow thruster, the bottom conditions in the Gulf, and the size of
the vessel. As a result, the estimated spill rates for the
Vulcanus are lower than for a typical tanker.
For purposes of comparison, Exhibit 5-6 shows the spill rate
estimated for the Vulcanus as a percent of the historical spill
rates for typical tank ships operating in similar areas as the
Vulcanus. The data indicate that the likely spill rate for the
Vulcanus is substantially less than that experienced by tankers
world wide. This is especially the case for impact type
accidents in the bay and pier/harbor areas. No adjustments were
made for non-impact type casualties, so the data reflect only the
5-6
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fact that small size vessels have lower non-impact casualty rates
than the average for the world fleet of tank ships. Overall, the
Vulcanus is expected to have a spill rate of about 10 percent of
that for typical tank ships.
Fugitive Emissions from the Vulcanus
While our analysis of marine transportation releases focuses
on vessel casualties, we also considered potential fugitive
emissions from the Vulcanus while the ship is underway.
According to an ADL analysis, the ship may release fugitive
emissions if an accidental discharge of waste liquid into the
pumproom bilge occurs and a portion of the release volatilizes,
or if a build-up of pressure in the cargo tanks necessitates use
of pressure relief valves. Fugitive emissions of this type are
difficult to estimate accurately. A rough estimate made by ADL
suggests that these sources are likely to release less than about
4 kilograms of fugitive emissions per voyage. Annual fugitive
emissions would be about 50 kilograms and 70 kilograms of waste
in the PCB and EDO cases, respectively» Since these emissions
are small, would consist mainly of the more volatile portions of
the waste, and would be released and dispersed, on average, all
along the ship's path of transit, their environmental and human
health effects would be neglibible.A/ Further, any material that
did not volatilize when accidentally discharged to the bilge
would be retained in tanks on board and eventually would be
pumped to an onshore facility for storage or subsequent
incineration.
Remedial Action
The preceding analysis does not consider remedial action to
remove waste materials released to the environment as a result of
spills, as this was beyond the scope of this study. Hazardous
waste operators are required to develop a contingency plan for
handling spills as a condition of the permit. The effectiveness
of remedial actions would depend on many factors, such as the
location and type of accident, sea conditions, weather
conditions, currents, properties of the material, and response
time. We think that efforts to contain and recover spills are
1/IEc copy of memorandum from J. Hagopian (ADL) to J. Ehrenfeld
(ADL), "Fugitive Emissions from Incinerator Ships," 19 September
1984.
5-7
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most likely to be successful in enclosed areas or in shallow
waters, such as the pier and harbor area and Mobile Bay. To the
extent that such mitigating activities are effective, the amount
of waste remaining in the marine environment after a spill will
be less than the releases we estimate.
COMPARABLE HAZARDS
To characterize the relative effect that operation of the
Vulcanus would have on expected releases of hazardous substances
in the Gulf of Mexico or Mobile Harbor, we examined data on the
shipments of petroleum and hazardous materials in Mobile Harbor
and the Gulf. These data show that there is a substantial volume
of shipments of petroleum and hazardous substances in both Mobile
Harbor and the Gulf of Mexico.
The table below provides data on the average volume of crude
petroleum, petroleum derivatives, and chemicals shipped in and
out of Mobile Bay over the period 1977 to 1981.5_/
Table 5-1
AVERAGE ANNUAL PETROLEUM AND CHEMICAL SHIPMENTS
IN MOBILE BAY
Imports, Exports Internal
& Coastwise & Local
(Tankers) (Barges)
Commodity
(000 MT)
Crude Petroleum 1,445 2,203
Gasoline, Jet Fuel, Kerosene,
Fuel Oil & Solvents 386 3,632
Benzene, Toluene, &
Basic Chemicals 42 113
Total 1,873 5,948
Ji/Derived from Water borne Commerce of the United States, Part 2_t
Waterways and Harbors — Gulf Coast. Mississippi River System .and
Antilles, Calendar Years 1977-1981, Department of the Army, Corps
of Engineers.
5-8
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The expected volume of wastes to be carried by the Vulcanus
(56,000 to 68,400 HT) is less than 4 percent of the volumes of
the above commodities carried by tankers and is less than 1
percent of the volumes carried by both tankers and barges. Since
the relative frequency of spills from the Vulcanus is less than
from tank ships generally (and assuming spill rates for barges
are similar), the expected volume of releases from the Vulcanus
in the pier and harbor areas and Mobile Bay, in a statistical
sense, is only about 0.1 percent of expected releases from
ongoing shipments of these commodities.
Data on shipments of petroleum and hazardous substances in
the Gulf area in FY 1983 are shown in the table below.£/
Table 5-2
SHIPMENTS OF PETROLEUM AMD HAZARDOUS SUBSTANCES
IN THE GULF OF MEXICO, FY 1983
Hazardous
Petroleum Substances
Volume of shipments (MM MT) 270 274
Number of shipments
Tankers 8,290 1,947
Barges 36,627 13,031
The number of voyages by the Vulcanus per year would be about 0.2
percent of total tanker shipments (about 0.03 percent of tanker
and barge shipments) and the volume of waste carried by the
Vulcanus would be about 0.01 percent of the volume of petroleum
and hazardous substances shipped by both tankers and barges in
the Gulf area. Given the lower expected spill rate for the
Vulcanus, the expected volume of releases from the Vulcanus is
less than 0.002 percent of expected releases from ongoing
shipments of petroleum and hazardous substances in the Gulf area.
I/Information from U.S. Coast Guard, Port and Environmental
Safety Division.
5-9
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SUMMARY OF RELEASES
FROM OCEAN TRANSPORTATION
Our analysis indicates that the overall spill rate for the
Vulcanus (all locations combined) is very low — 6 per 100,000
voyages or, in the PCB case, about 1 per 1,200 operating years.
Spill rates estimated for particular locations are even lower, as
are spill rates for accidents involving two or three or more
tanks. For example, the overall spill rate for Mobile Bay is
about 1 per 10,000 operating years, with the spill rate for
accidents involving one, two, or three or more tanks being about
1 per 13,000, 67,000, and 200,000 operating years, respectively.
The overall spill rate for the coastal area is about 1 per 4,000
operating years, with the spill rate for accidents involving one,
two, or three or more tanks being about 1 per 5,000, 25,000, and
75,000 operating years, respectively.
The overall spill rate estimated for the Vulcanus is about
one order of magnitude less than the historical spill rate for
tank ships worldwide. This is due to the adjustments made to
historical spill rates to reflect the likely effects of the
design and operating characteristics of the Vulcanus. However,
no downward adjustments, other than for the size of the vessel,
were made to spill rates from non-impact casualties, because of
insufficient information.
The amount of expected annual releases of PCB and EDC wastes
are also low, about 0.63 MT and 0.77 MT, respectively. These
numbers represent long-term averages, rather than the releases
likely to occur in any year. They are also conservative
estimates, as we assumed complete loss of the cargo of tanks
affected by an accident.
The Vulcanus would operate in a region of the country having
substantial commerce in petroleum and hazardous materials. The
volume of material transported by the Vulcanus would be a small
fraction of shipments of such commodities in the Gulf — about
0.01 percent. Further, because the spill rate for the Vulcanus
is less than for other vessels, the potential releases from the
Vulcanus would be less than 0.002 percent of those from ongoing
shipments of petroleum and hazardous materials in the Gulf.
5-10
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Location
Pier & Harbor
Mobile Bay
Coastal
Burn Zone
All Locations
Exhibit 5-1
ESTIMATED SPILL RATES PER VOYAGE FOR THE VULCANUS
BY TYPE OP CASUALTY AND LOCATION
Type of Casualty
Collisions Groundings Hammings
All
Non-impact Casualties
4.312-6
1.9E-6
6.4E-6
4.5E-6
1.7E-S
2.2E-7
3.4E-6
6.7E-6
-
l.OE-5
1.6E-7
1.4E-6
2.4E-6
-
4.0E-6
1.8E-5
3.6E-7
3.6E-6
7.1E-6
2.9E-5
2.3E-5
7.1E-6
1.9E-5
1.2E-5
6.0E-5
Source: Appendix C, Table 7
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Exhibit 5-2
DISTRIBUTION OP EXPECTED SPILLS BY TYPE
OF CASUALTY AND LOCATION
Location
Pier & Harbor
Mobile Bay
Coastal
Burn Zone
All Locations
Collisions
0.071
0.032
0.106
0.074
0.284
-ryi
Groundings
0.004
0.056
0.111
-
0.171
pe oz ^asuaxi
Hammings
0.003
0.024
0.040
-
0.066
-y
No n- impact
0.297
0.006
0.059
0.118
0.479
All
Casualties
0.375
0.118
0.315
0.192
1.000
Note: This table indicates the relative frequency of spills by casualty and
location. The data are calculated from Exhibit 5-1 by dividing the
estimated spill rate for a given casualty type and location by the
overall spill rate. For example, relative fequency for collisions in
pier and harbor area of 0.071 is calculated by dividing the spill rate
of 4.3E-6 by the overall spill rate of 6.0E-5.
Source:
Exhibit 5-1
-------
Exhibit 5-3
ESTIMATED SPILL RATES PER VOYAGE FOR THE VULCANUS BY LOCATION
AND NUMBER OF TANKS AFFECTED
Location
Pier & harbor
Mobile Bay
Coastal
Burn Zone
One
1.8E-5
5.7E-6
1.5E-5
9.3E-6
Number of Tanks Affected
Two Three or More
3.4E-6
1.1E-6
2.9E-6
1.7E-6
1.1E-6
3.6E-7
9.5E-7
5.8E-7
Any Number
2.3E-5
7.1E-6
1.9E-5
1.2E-5
Total
4.8E-5
9.0E-6
3.0E-6
6.0E-5
Source: Appendix C, Table 7 and lEc Analysis
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Exhibit 5-4
SPILL RATES IN TERMS OF
NUMBER OF OPERATING YEARS *
Location
Pier & harboc
Mobile Bay
Coastal
Burn Zone
One
- Number of Tanks Affected
Two Three or More Any Number
4,000
13,000
5,000
8,000
21,000
67,000
25,000
41,000
63,000
200,000
75,000
120,000
3,000
10,000
4,000
6,000
Total
1,500
8,000
24,000
1,200
* The spill rate is one per the number of operating years shown above
and is calculated assuming 14 voyages per operating year.
Source: Derived from Appendix C, Table 7
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Exhibit 5-5
CALCULATION OF EXPECTED ANNUAL RELEASES (EV)
FROM VESSEL CASUALTIES
PCS CASE
Expected release fraction (ERF) = 0.1875
Quantity at risk (Q) = 4,000 MT
Average quantity released (QR) = ERF * Q = 750 MT
Expected number of releases per year (EN) = 8.4E-4
Expected annual release (EV) = QR * EN = 0.63 MT
EDC CASE
Expected release fraction (ERF) = 0.1875
Quantity at risk (Q) = 3,800 MT
Average quantity released (QR) = ERF * Q = 712 MT
Expected number of releases per year (EN) = 1.1E-3
Expected annual release (EV) = QR * EN = 0.77 MT
Source: Appendix C, lEc Analysis
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Exhibit 5-6
ESTIMATED SPILL RATE OF THE VULCANUS AS A PERCENT
OF THE HISTORICAL SPILL RATES FOR TANK SHIPS
BY TYPE OF CASUALTY AND LOCATION *
Location
Pier and Harbor
Mobile Bay
Coastal
Burn Zone
All Locations
Impact
3.6%
4.5
10.3
68.8
7.2
Type of Casualty
Non-Impact ** All Casualties
75.5%
13.7
13.5
5.8
16.3
14.6%
4.7
10.8
8.9
9.8
**
We compute these percentages by comparing the estimated
spill rates for the Vulcanus to the spill rates obtained
from ECOTANK for tank ships between 2,000 and 10,000
deadweight tons. ECOTANK has five location categories:
pier; harbor; entranceway to a harbor; coastal (within 50
nautical miles of land); and at sea. For purposes of this
analysis we compare ECOTANK pier and harbor data to the
estimated spill rates for the Vulcanus in Mobile pier and
harbor, ECOTANK entranceway data to our estimated spill
rates for Mobile Bay, ECOTANK coastal data to our estimated
spill rates for coastal waters, and ECOTANK at sea data to
estimated spill rates for the Vulcanus in the burn zone.
The only adjustment affecting the spill rate of the Vulcanus
from non-impact casualties is for vessel size.
Source: Derived from Tables 7 and 8, Appendix C
-------
RELEASES FROM INCINERATION CHAPTER 6
INTRODUCTION
Unlike some releases from other components of ocean- or
land-based incineration systems, stack emissions are expected as
part of normal operations. This chapter presents our analysis of
expected stack emissions, addressing four classes of pollutants:
o Undestroyed constituents of the waste stream;
o Products of Incomplete Combustion (PICs);
o Heavy metals; and
o Hydrochloric acid (HC1).
We use existing or proposed EPA permit requirements and available
test burn data to estimate annual releases of each of these
materials.
In addition to stack emissions, the analysis of releases
from land-based incinerators includes estimates of the quantity
and content of scrubber effluent generated annually. Land-based
incinerators typically are equipped with scrubbers to control
emissions of HC1, metals, and particulates. The analysis of
incineration aboard the Vulcanus does not consider releases of
scrubber water because the Vulcanus has no scrubber.
6-1
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The analysis ignores releases of ash from both the Vulcanus
and land-based incinerators. CWM does not expect the Vulcanus1
liquid injection incinerators to generate ash residues. If any
ash is generated, EPA's draft permit for the Vulcanus prohibits
the ship from dumping it at sea and requires CWM to dispose the
ash on land in accordance with applicable EPA regulations.
Similarly, we assume that any ash generated by a land-based
incinerator would be properly disposed in an EPA-permitted
hazardous waste landfill.
EMISSIONS OF UNDESTROYED WASTES
Exhibit 6-1 illustrates our calculation of emission rates
for undestroyed wastes for both the PCB and EDC wastes. The
calculation assumes that the Vulcanus meets EPA's proposed
performance standards for ocean-based incineration, and that the
land-based incinerator meets existing EPA standards for hazardous
waste incinerators. The two standards are identical, requiring
both ocean- and land-based incinerators to achieve a destruction
and removal efficiency (DRE) of 99.99 percent.I/ The only
exception to this requirement is for incinerators burning PCBs,
dioxins, and dibenzofurans, which EPA requires to achieve a DRE
of 99.9999 percent. Based on these requirements and the total
annual throughput for the PCB and EDC wastes, we calculated the
following emissions of undestroyed wastes for the Vulcanus and
the land-based incinerator:
o Emissions for incineration of the PCB waste -
.056 metric tons per year;
o Emissions for incineration of the EDC waste -
6.84 metric tons per year.
Annual emissions of undestroyed wastes are significantly higher
in the EDC case since the DRE required for EDC wastes is two
orders of magnitude lower than that for PCB wastes.
As described previously, we assume that the PCB waste
contains 35 percent by weight of PCBs and EDC waste contains 50
I/The standard for ocean incineration is in terms of destruction
efficiency, rather than destruction and removal efficiency,
because scrubbers are not used. We use the term DRE for both
systems to simplify the discussion.
6-2
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percent by weight of ethylene dichloride. The remainder of each
waste stream is assumed to be non-hazardous. Thus, each of these
wastes contains a single "primary organic hazardous constituent"
(POHC) as defined in EPA's current regulations for land-based
incinerators. In the calculations above, we assume both the POHC
and the non-hazardous constituents are destroyed equally.
As shown on Exhibit 6-1, the resulting annual release of POHCs
only is 0.02 metric tons for the PCB waste and 3.42 metric tons
for the EDC waste. These POHC releases are used in our analysis
of human health and environmental effects from stack releases
presented in Chapters 7 and 8.
PIC EMISSION RATES
The formation of products of incomplete combustion (PICs) by
hazardous waste incinerators is a poorly understood phenomenon,
and the topic of considerable debate. By strict definition,
PICs are organic compounds formed by chemical reactions during
the incineration process. Trial burn data, however, may identify
as PICs all organic compounds other than POHCs present in the
stack gases. These compounds may include not only those formed
during combustion, but also compounds from contaminated scrubber
water or non-combusted trace components of the waste feed itself.
We developed our estimates of PIC emissions based on the best
available trial burn data for ocean- and land-based facilities.
These data, however, are too limited to present a definitive
portrayal of PIC emissions. Specifically, the data are plagued
by the following uncertainties:
o The PIC emission data are based on differing
definitions of what constitutes a PIC. In some
trial burns PICs are defined as compounds not
found in the waste itself, while in others PICs
are compounds not detected in the waste in
concentrations greater than 100 ppm.
o The trial burn data are not based on consistent
sampling procedures. Further, the trial burns did
not sample for a consistent set of compounds, so
the results depend upon whether investigators
tested for the presence of a particular compound.
6-3
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o The trial burn data are not based on burns of a
consistent set of wastes, and none of the wastes
analyzed are identical to the PCS or EDC wastes
of concern in this study.
o The emission rates measured in trial burns are
based on several types of incinerators with
different operating parameters. PIC generation is
believed to be a function of incinerator type,
configuration, and operating conditions.
o Finally, there is disagreement over the validity
of the results of some test burns due to possible
contamination of samples.
With these uncertainties in mind, our estimates of PIC emission
rates should be viewed only as rough approximations. However, in
the absence of better data or an improved theoretical
understanding of PIC generation, we believe these estimates are
the best available.2/
PIC Emissions from the Vulcanus
We base our estimates of PIC emission rates for the Vulcanus
II on available trial burn data for the ship and for its sister
ship, the Vulcanus I. As explained in Appendix E, these data
yield the following estimates:
o For PCS wastes burned at 99.9999 percent DRE,
hazardous PICs are emitted at a rate no greater
than 1.13E-11 percent of total waste feed;
o For non-PCB wastes burned at 99.99 percent DRE,
PICs are emitted at a rate of 3.01E-2 percent of
total waste feed.
As these estimates show, ocean-based incineration is assumed
to generate significantly less PICs when burning the PCB waste
than when burning EDC waste. This large difference is partly the
result of two factors:
2/Appendix E reviews the test burn data and fully explains the
methodology employed to derive the PIC emission estimates.
6-4
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o Past trial burns of PCB-containing wastes on the
Vulcanus I and II tested for a single compound
onlyr while burns of other organic wastes were
tested for many compounds, and I/
o Some experts believe that the higher ORE required
for PCB wastes should result in lower generation
of PICs.
However, the large discrepancy between the two wastes raises
concern for the accuracy of the estimates. As shown below and in
Appendix E, additional cause for concern is a further discrepancy
in relative PIC generation rates for land- and ocean-based
incinerators. The test burn data for PCB wastes indicate that
land-based incinerators generate more PICs than ocean-based
incinerators, but the data for non-PCB wastes show that land-
based incinerators generate considerably fewer PICs. At present,
we know of no complete explanation for these apparent
inconsistencies.
We used these PIC emission rates and the throughput data
described above to calculate total annual releases of PICs for
both the PCB and EDC wastes. These calculations, summarized in
Exhibit 6-2, produce the following estimates:
o PIC emissions from PCB burns: 6.3E-9 metric tons
per year;
o PIC emissions from EDC burns: 20.6 metric tons per
year.
I/As described in Appendix E, ten PCB burns onboard the Vulcanus
revealed no detectable levels of tetrachlorodibenzo-p-dioxin
(TCDD), the PIC of interest in this analysis. The estimated PIC
emission rate given above is based on the maximum quantity of
TCDD that could have gone undetected. The trial burns did not
analyze other PICs.
6-5
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In light of the anomalies in the test burn data, and given
the highly carcinogenic nature of PICs that may be generated by
PCB incinerators, we include in Chapter 8 a sensitivity analysis
for at-sea incineration of PCB wastes which employs the higher
PIC generation rate given for land-based incinerators. As shown
in Exhibit 6-2, use of this higher rate increases the annual
quantity of PIC emissions in the PCB case by more than three
orders of magnitude (to 1.9E-5 metric tons per year) for the
ocean case.
PIC Emission Rates for Land-Based Incinerators
Like the estimates of PIC emissions from the Vulcanus, our
estimates of PIC emissions from land-based incineration are based
on the analysis of test burn data described in Appendix E, and
are subject to the same uncertainties. With these caveats in
mind, we calculated the following PIC emission rates for land-
based incineration:
o For PCB wastes burned at 99.9999 percent DRE,
hazardous PICs are emitted at a rate of 3.40E-8
percent of total waste feed; £/
o For non-PCB wastes burned at 99.99 percent DRE,
PICs are emitted at a rate of 8.94E-4 percent of
total waste feed.
Based on these emission rates, we calculated the following
estimates of total annual PIC emissions for the PCB and EDC
cases:
4/The PIC emission rate reported above is for TCDD only. As
described in Appendix E, the test burn data indicate that furans
and other dioxins also are generated as PICs at land-based
incinerators burning PCB wastes. We based our estimate of PIC
emission rates solely on TCDD emissions because EPA recommends
that risk analyses for emissions containing mixtures of furans
and dioxins be based on TCDD emissions and the unit risk factor
for TCDD. Since the PIC emission rate for PCB burns aboard the
Vulcanus also reflects only TCDD emissions, the estimates for the
two systems are directly comparable.
6-6
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o PIC emissions from PCB burns: 1.9E-5 metric tons;
and
o PIC emissions from EDC burns: 0.61 metric tons.
Exhibit 6-3 contains the calculations employed to develop these
estimates.
METALS EMISSIONS
Ocean-Based Incineration
Because the Vulcanus is not equipped with scrubbers, its
stack emissions include any metals contained in the waste feed.
To control metals emissions, EPA plans to issue metals
concentration limits for wastes burned at sea. Current proposals
include individual limits on a number of metals, with a maximum
limit for total metals on each manifested shipment of wastes of
500 ppm. For purposes of analysis, we assumed that both the PCB
and EDC wastes contain arsenic, cadmium, chromium, and nickel —
the four metals for which EPA's Carcinogen Assessment Group (CAG)
has developed cancer unit risk factors — at concentrations of
100 ppm each.5/ The concentration assumptions probably
overstate the average concentrations of carcinogenic metals in
liquid incinerable waste streams.
Based on this assumption, Exhibit 6-4 shows expected annual
metals emissions for the Vulcanus. As the exhibit indicates,
estimated metals emissions in the PCB case are 5.6 metric tons
per year for each metal, or a total of 22.4 metric tons.
Estimated annual emissions in the EDC case are 6.84 metric tons
of each metal, for a total of 27.36 metric tons per year.
Land-Based Incineration
Our analysis of metals emissions from land-based
incinerators assumes the same concentration of metals in the
waste feed as the ocean-based analysis, but considers the effect
of a scrubber in removing metals. As explained in Appendix D,
I/Appendix D gives a fuller explanation of the rationale employed
in selecting these metals.
6-7
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there is significant uncertainty associated with scrubber removal
efficiencies. Based on available trial burn data and discussions
with EPA experts, we assumed that scrubbers achieve 90 percent
removal of cadmium, chromium and nickel, and 50 percent removal
of arsenic. Removal of arsenic is lower because this metal is
more volatile. These assumptions yield the following estimates
of annual metals emissions for a land-based incinerator:
o PCS Case: 0.56 metric tons each of cadmium,
chromium and nickel, and 2.8 metric tons of
arsenic;
o EDC Case: 0.684 metric tons each of cadmium,
chromium and nickel, and 3.42 metric tons of
arsenic.
In the PCS case, metals emissions total 4.48 metric tons per
year. In the EDC case, annual metals emissions total 5.47 metric
tons. Exhibit 6-5 summarizes the calculations used to develop
these estimates.
HYDROCHLORIC ACID EMISSIONS
Ocean-Based Incineration
The lack of scrubbers on the Vulcanus implies that chlorine
contained in the waste feed will be emitted from the incinerator
stacks. Host chlorine is emitted as hydrochloric acid (HC1),
while the rest may be emitted as chloride salts or chlorinated
organic matter. We did not analyze the forms in which chlorine
may be emitted, but simply calculated the total quantity of
chlorine released and assumed that it would be released as HC1.
Based on a mass balance calculation, we estimated that in the PCB
case, 10,505 metric tons of chlorine per year are released. In
the EDC case, 25,034 metric tons of chlorine per year are
released. We base these estimates on the assumption that
Arochlor 1254 (53.6 percent chlorine) or EDC (73.2 percent
chlorine) is the only source of chlorine in the PCB or EDC waste
(that is, we assume that the balance of the waste is composed of
non-chlorinated organics).
6-8
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Land-pased Incineration
The presence of scrubbers on land-based incinerators greatly
reduces emissions of HC1 and other chlorinated compounds.
According to an ADL analysis (see Appendix F), scrubbers achieve
99 percent removal of hydrochloric acid emissions. Based on this
removal efficiency, ADL estimated annual emissions of 105 and 250
metric tons of chlorine, in the form of HC1, for the PCB and EDC
cases, respectively.
SCRUBBER EFFLUENT
Appendix F describes ADL's analysis of the generation,
composition, and disposition of scrubber effluent from land-based
incinerators. The analysis assumes the scrubber achieves 99
percent removal of hydrochloric acid emissions, as EPA requires.
Based on these and other assumptions explained in Appendix F, ADL
estimated that an incinerator burning 56,000 metric tons of PCB
wastes annually generates approximately 1.5 million metric tons
of scrubber blowdown. A unit incinerating 68,400 metric tons of
EDC wastes annually produces approximately 3.6 million metric
tons of scrubber blowdown. Waste water accounts for more than 99
percent of both these quantities.
As discussed in Appendix F, chlorine is the principal non-
aqueous constituent of scrubber blowdown, representing 0.7
percent of the total effluent. In the PCB case, ADL estimated
that 10,400 metric tons of chlorine per year are contained in
scrubber effluent. In the EDC case, ADL estimated that 24,784
metric tons of chlorine are removed by scrubbers and contained in
scrubber blowdown.
EPA regulates disposal of scrubber sludge or brine under
RCRA and controls the discharge of scrubber waste water under the
Clean Water Act, limiting the probability that hazardous scrubber
wastes will be released to the environment. In fact, three of
four incinerator operators contacted by ADL sell scrubber
effluent to be used, reused, recovered or recycled, eliminating
the release of any wastes to the environment. If scrubber waste
water is discharged, the operators typically neutralize it,
raising the pH to 7.0 or 7.5. As indicated above, its chlorine
content is normally maintained below one percent, with most
chlorine contained in low concentrations of dissolved salts. At
6-9
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a pH of 7.0 or above there is virtually no hydrochloric acid in
the effluent. Scrubber effluent also contains virtually no
organic material.
Treated scrubber effluent also can contain metals removed
from stack emissions. Assuming the scrubber removal efficiencies
described above, the maximum quantity of metals contained in
waste scrubber water will equal 40 percent of the total
throughput of cadmium, chromium, and nickel, and one-half the
total throughput of arsenic. Therefore, the maximum quantity of
metals contained in scrubber effluent from PCB incineration would
be 17.92 metric tons per year (5.04 metric tons each of cadmium,
chromium, and nickel, and 2.8 metric tons of arsenic); and 21.89
metric tons per year (6.156 metric tons of cadmium, chromium, and
nickel, and 3.42 metric tons of arsenic) in the EDC case.
Exhibit 6-6 illustrates the calculation of these estimates.
CAVEATS AND SENSITIVITY ANALYSIS
In addition to the caveats regarding estimates of PIC
emissions, this analysis assumes incinerators operate to meet EPA
permit conditions. With regard to this assumption, there has
been concern that periodic incinerator malfunctions or "upsets"
could lead to significant releases of unburned wastes. Federal
regulations require incinerators to be equipped with automatic
waste feed cutoff systems that prevent operation of the
incinerator in the event that critical operating conditions are
not met. In addition, the thermal inertia of a hazardous waste
incinerator is such that any wastes introduced into the system
immediately before and during an upset would be substantially
combusted. If automatic waste feed cutoff normally occurs in
less than one second and destruction efficiency in the event of
an upset is at least 99.9 percent, incinerator malfunctions
should have an insignificant effect on annual stack emissions.
In our worst case analysis—shutdown of operations within ten
seconds, maintaining only 90 percent DRE—emissions during the
upset period would be equivalent to normal emissions over three
hours of operation at 99.99 percent DRE, or 280 hours of
operation at the more stringent PCB level of 99.9999 percent
DRE.£/ In this case, about ten such upsets over the burn period
It/Memorandum from J.R. Ehrenfeld (ADD to Incineration Risk Study
File, "Potential Emissions Due to Incinerator Malfunction," 15
August 1984.
6-10
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for PCBs of 296 hours would have the effect of reducing DRE by
one order of magnitude. There would have to be about 600 such
upsets over the 169 hour burn period to reduce the DRE for EDC by
about an order of magnitude. Unfortunately, we have no data on
the number of upsets likely to occur.
SUMMARY
Ocean-Based Incineration
Our estimates of annual stack emissions from an ocean-based
incineration system are:
Table 6-1
Summary of Ocean-Based Stack Emissions
Undestroyed Wastes
PICs
Metals
Chlorine (as HC1)
Source: lEc Analysis
PCB Waste
(MT per year)
5.60E-2
6.33E-9
2.24E+1
1.05E+4
EDC Waste
(MT per year)
6.84E+0
2.06E+1
2.74E+1
2.50E+4
The quantity of chlorine emitted as HC1 clearly dominates
releases of the three other categories of emissions. Undestroyed
wastes, PICs, and metals emissions, however, are of greater
concern in characterizing the magnitude of potentially hazardous
emissions. As the table shows, our assumptions result in a
substantial quantity of metals emitted from the Vulcanus in both
the PCB and EDC cases. PIC emissions are also large in the EDC
case, but represent a far smaller share of total emissions in the
PCB case. Emissions are higher in the EDC case because the waste
is burned at a lower DRE, the PIC generation rate is
substantially higher, and the waste contains more chlorine than
the PCB waste.
6-11
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Land-Based Incineration
Our estimates of likely annual stack emissions from a land-
based hazardous waste incinerator are:
Table 6-2
Summary of Land-Based Stack Emissions
Undestroyed Wastes
PICs
Metals
Chlorine (as HC1)
PCB Waste
(MT per year)
5.60E-2
1.90E-5
4.48E+0
1.05E+2
EDC Waste
(MT per year)
6.84E+Q
6.11E-1
5.47E+0
2.50E+2
Source: lEc Analysis
The stack emissions for both wastes contain more chlorine (as
HC1) than any other category of emissions. The quantity of HC1
released, however, is likely to be of less concern than the
quantity of undestroyed wastes, metals and PICs. The table shows
that a substantial quantity of metals is released in both the PCB
and EDC cases, with metals emissions exceeding emissions of both
PICs and undestroyed wastes in the PCB case. The table also
shows that emissions of undestroyed wastes exceed PIC emissions
by two orders of magnitude in the PCB case, and one order of
magnitude in the EDC case. Total annual PIC emissions in the EDC
case are approximately three orders of magnitude higher than the
PCB case.
Releases from land-based incinerators can also include
scrubber wastes containing substantial quantities of chlorine and
metals. Because the disposal of scrubber sludge, brine and waste
water are regulated by EPA, uncontrolled releases of these
materials in hazardous form are unlikely. The presence of
scrubbers reduces stack emissions of chlorine as HC1 two orders
of magnitude below similar emissions for the Vulcanus.
6-12
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Similarly, scrubbers reduce expected annual metals emissions from
a land-based unit to 20 percent of the expected metals emissions
from the sea-based system.
As noted above/ emissions of undestroyed wastes from land-
based incinerators are assumed to be the same as from the
Vulcanus. PIC emissions, however, differ markedly. In the EDC
case, annual PIC emissions are two orders of magnitude lower for
land-based incinerators. In the PCB case, the opposite appears
to hold; PIC emissions for land-based incinerators are estimated
to be three orders of magnitude higher than PIC emissions for the
Vulcanus. As described previously, this apparent anomaly and the
uncertainties associated with the PIC analysis raise considerable
questions regarding the accuracy of the PIC estimates for both
the land-based and ocean-based systems.
6-13
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Exhibit 6-1
CALCULATION OF ANNUAL EMISSIONS OF UNDESTROYED WASTES
PCB, Was f:p
Assumptions:
ORE = 99.9999%
Annual throughput - 56,000 MT
Calculation:
Annual emissions
of undestroyed wastes = 56,000 HT * U-.999999)
= .056 MT
Annual emissions
of POHC (PCB) = .020 MT
EpC Waste
Assumptions:
ORE = 99.99%
Annual throughput = 68,400 MT
Calculation:
Annual emissions
of undestroyed wastes - 68,400 MT * (1-.9999)
- 6.84 MT
Annual emmisions
of POHC (EDO - 3.42 MT
Source: lEc Analysis
-------
Exhibit 6-2
CALCULATION OP ANNUAL PIC EMISSIONS FROM THE
INCINERATOR SHIP
PC
Assumptions:
PIC emission rate =
Annual throughput =
Calculation:
Annual PIC emissions
1.13E-11% of waste feed
56,000 MT
= 56,000 MT * 1.13E-13
= 6.33E-9 MT
EDC Waste
Assumptions:
PIC emission rate =
Annual throughput -
Calculation:
Annual PIC emissions
3.01E-2% of waste feed
68,400 MT
68,400 MT * 3.01E-4
20.59 MT
Aa.sis
Assumptions:
PIC emissions rate =
Annual throughput =
Calculation:
Annual PIC emissions
3.40E-8% of waste feed
56,000 MT
56,000 MT * 3.40E-10
1.90E-5 MT
Source: IEC Analysis
-------
Exhibit 6-3
CALCULATION OF ANNUAL PIC EMISSIONS
FROM A LAND-BASED INCINERATOR
PCB, ftaste
Assumptions:
PIC emission rate = 3.40E-8 percent of waste feed
Annual throughput = 56,000 MT
Calculation:
Annual PIC emissions = 56,000 MT * 3.40E-10
= 1.90E-5 MT
EDC Waste
Assumptions:
PIC emission rate = 8.44E-4 percent of waste feed
Annual throughput = 68,400 MT
Calculation:
Annual PIC emissions = 68,400 MT * 8.94E-6
= 6.11E-1 MT
Source: lEc Analysis
-------
Exhibit 6-4
ANNUAL METALS EMISSIONS FROM OCEAN-BASED INCINERATION
Metal
Arsenic
Cadmium
Chromium
Nickel
TOTAL
Concentration
In Waste
(ppm)
100
100
100
100
Annual Emissions
PCB Waste
(MT)
5.6
5.6
5.6
5.6
22.4
EDC Waste
(MT)
6.84
6.84
6.84
6.84
27.36
Source: IBc Analysis
-------
Exhibit 6-5
CALCULATION OP ANNUAL METALS EMISSIONS FOR
LAND-BASED INCINERATION
Assumptions
—Annual Throughput— Scrubber
(MT) Removal
Metal PCS Waste EDC Waste Efficiency
Arsenic
Cadmium
Chromium
Nickel
5.6
5.6
5.6
5.6
6.84
6.84
6.84
6.84
50 %
90 %
90 %
90 %
Total 22.4 27.36
CfrJ.culaEJ.ons
Annual Emissions = Annual Throughput * (1 - Removal Efficiency)
PCB Waste - Cadmium, Chromium and Nickel:
Annual Emissions = 5.6 MT * (1 - .9)
« 0.56 MT
PCB Waste - Arsenic:
Annual Emissions « 5.6 MT * (1 - .5)
= 2.8 MT
EDC Waste - Cadmium, Chromium and Nickel:
Annual Emissions = 6.84 MT * (1 - .9)
= 0.684 MT
EDC Waste - Arsenic:
Annual Emissions = 6.84 MT * (1 - .5)
= 3.42 MT
Source: lEc Analysis
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Exhibit 6-6
CALCULATION OP THE MAXIMUM QUANTITY OF METALS
CONTAINED IN TREATED SCRUBBER EFFLUENT
Assumptions
—Annual Throughput— Scrubber
(MT) Removal
Metal PCB Waste EDC Waste Efficiency
Arsenic
Cadmium
Chromium
Nickel
5.6
5.6
5.6
5.6
6.84
6.84
6.84
6.84
50 %
90 %
90 %
90 %
Total 22.4 27.36
Quantity in Effluent « Annual Throughput * Removal Efficiency
PCB Waste - Cadmium, Chromium and Nickel:
Quantity in Effluent « 5.6 MT * .9
- 5.04 MT
PCB Waste - Arsenic:
Quantity in Effluent = 5.6 MT * .5
= 2.8 MT
EDC Waste - Cadmium, Chromium and Nickel:
Quantity in Effluent = 6.84 MT * .9
- 6.156 MT
EDC Waste - Arsenic:
Quantity in Effluent = 6.84 MT * .5
= 3.42 MT
Source: lEc Analysis
-------
EFFECTS OF RELEASES FROM
OCEAN TRANSPORTATION CHAPTER 7
INTRODUCTION
The probability that hazardous wastes might be released
accidentally during the transit of the Vulcanus from the pier at
Chickasaw to the Gulf burn zone was described in Chapter 5.
Although spills are very unlikely, they could involve relatively
large quantities of waste. In addition, this type of release is
unique to ocean-based incineration systems and has no direct
parallel in land-based systems. Thus, we have included in our
analysis an evaluation of the possible environmental and human
health effects from spills of hazardous wastes into the marine
environment.
lEc subcontracted with Applied Science Associates, Inc.(ASA)
to analyze the pollutant transport and marine ecosystem effects
that could result from a loss of cargo from the ship at three
points along the vessel's transit path:
o in the Mobile Bay ship channel,
o over the continental shelf near the Mississippi
River delta (29 degrees 45 minutes North and 88
degrees 30 minutes West), and
o in the center of the designated burn zone (26
degrees 40 minutes North and 93 degrees 40 minutes
West).
7-1
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Since the characteristics of the marine environment differ along
the vessel's proposed path, analysis of the effects of spills in
these three areas was necessary to determine the range of
potential effects of accidental releases during the voyage to the
burn area.I/
We asked ASA to evaluate three release quantities — a loss
of half a tank, a loss of two tanks and a loss of the entire
cargo. As discussed in Chapter 5, the estimated overall spill
rate for the Vulcanus is very low — about 1 per 17,000 voyages
or 1 per 1,200 operating years. The estimated spill rate for any
particular location is even lower. Further, our analysis of the
distribution of spill sizes suggests that about 80 percent of the
time only one cargo tank will be affected. Casualties resulting
in damage to two or to three or more cargo tanks would occur
about 15 percent and 5 percent of the time, respectively. Thus,
the probability for a release of cargo from one tank, two tanks,
or three or more tanks in Mobile Bay is estimated to be on the
order of one per 11,000, 67,000, and 200,000 operating years,
respectively. Similar estimates for other locations are provided
in Chapter 5.
The analysis in Chapter 5 indicates that the probability of
a casualty affecting one or two tanks is very low and the
probability of a casualty resulting in a complete loss of cargo
is extremely low — even less than the 1 in 200,000 operating
years shown above for a loss involving 3 or more tanks.
Nonetheless, we have estimated the potential effects from the
loss of an entire cargo to bound the possible damage that could
result from an ocean transportation release.
ASA's calculations were carried out for each of the two
waste streams selected for this study:
I/Due to time and budget constraints, we have not evaluated the
effects of releases in the pier area, Chickasaw Creek, or harbor.
Information in Appendix C indicates that about 80 percent of
spills in the pier and harbor area would be expected at the pier.
We believe that containment or remedial actions undertaken as a
response to spills at the pier are likely to substantially reduce
the amount of contaminants remaining in the environment.
7-2
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1. a waste containing 35 percent by weight of
polychlorinated biphenyls (Arochlor 1254) and 65
percent non-hazardous material (it is expected
that PCB concentrations in waste streams in the
future will be in the 10 percent range), and
2. a waste containing 50 percent by weight of
ethylene dichloride and 50 percent non-hazardous
material.
The dispersion of a pollutant through the environment,
particularly in the ocean, can be strongly influenced by the
mixture of substances in which the pollutant is included and the
resulting physical and chemical state of the pollutant when
released. We asked ASA to ignore this "mixture" problem and
simply calculate dispersion and effects for the two individual
chemicals of interest. Although Arochlor 1254 is heavier than sea
water and would be expected to sink, we have considered both
"floating" and "sinking" cases to reflect the fact that the PCBs
might be entrained in a lighter-than-water fraction that would
float much like an oil slick.2/ Since ethylene dichloride is
soluble in water, ASA calculated EDC concentrations assuming that
the compound quickly dissolves and diffuses once released from
the ship.
Along with the specific composition of the waste, the
dispersion and ultimate effects of material released from the
ship during an accidental spill would depend upon other factors,
including the nature of the accident, weather and sea conditions
at the time, and the effect of any mitigating actions carried
out. We asked ASA to assume in their analysis that:
o the waste is released to the surface of the ocean
at a single point, instantaneously;
o no mitigating activities are carried out; and
2/JRB Associates, Inc. tested seven samples of PCB liquid wastes
to determine behavior in water. Four of the samples had
specific gravities greater than seawater and sank readily,
whereas three of the samples had specific gravities less than
seawater and floated (See JRB Associates, Inc., Expanded Modeling
£f Incineration ai S_ea Impacts; Glllf QL Mexico, Final Report,
June 1, 1984, p. 2 - 32).
7-3
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o weather and sea conditions reflect the annual
average.
These assumptions simplify the analysis considerably. For
example, the discussion in Chapter 5 indicates that the quantity
of waste released and the speed of release depends on a variety
of factors, such as the nature of the accident and the density of
the material relative to seawater. Further, the amount of
contaminants that remain in the marine environment after a spill
depends on the extent to which spills can be contained and
recovered.
Methods for containing and recovering floating spills
include the use of floating booms to contain slicks and of
skimmers to remove the slick from the surface. Techniques for
recovering materials that sink include the use of hand held
dredges, suction dredges, and hydraulic dredges. Such mitigating
activities are likely to be most successful in the pier and
Mobile Bay areas and least successful on the continental shelf
and in the burn zone. However, evaluating the likely
effectiveness of mitigating activities in removing contaminants
from the marine environment was beyond the scope of this study.
Our analysis of several release amounts provides information to
bracket the likely effects of spills and to estimate the effects
of various amounts of wastes remaining in the marine environment.
In addition to the analysis provided by ASA, lEc analyzed
the potential for short term human health effects from a spill
through inhalation of pollutants volatilized from the spill site.
ZEc's calculation of risks from spill volatilization is described
in detail in Appendix H.
The remaining sections of this chapter describe the methods
used by ASA and lEc and the limitations of these methods; and the
dispersion, marine effects and human health effects from spills
at each of the three sites. A more detailed discussion of ASA's
data, methods, assumptions and results is provided in Appendix I.
METHODS AND THEIR LIMITATIONS
ASA used a computerized ocean transport model to estimate
the movement of pollutants released over the continental shelf or
in the burn zone. This model represents the Gulf of Mexico in
square grids of size .25 degree, and uses data on average surface
7-4
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and subsurface current fields to move and disperse released
material across the area. Mixing in the vertical dimension occurs
through dispersion, settling, and (for shallow areas such as the
continental shelf) resuspension due to wave action.
Concentrations in the sediments for pollutants that settle assume
perfect mixing to a depth of 5 centimeters.
In the case of a floating PCB spill, the waste material is
assumed to be perfectly mixed in the top one meter of water and
to be moved and dispersed only by the seasonally averaged surface
currents and wind. In the case of a sinking PCB spill, all
hazardous material is assumed to fall through the water column
and reach the ocean floor. Some of the PCBs will sink rapidly to
the sea floor, whereas others would settle at different rates
depending on the settling velocities of particulate matter onto
which they absorb. Accordingly, ASA used three different
settling velocities (0.1, 0.01 and 0.001 m/s) and assumed equal
amounts of PCBs would settle out at each velocity. In the EDC
case, the material is assumed to dissolve and disperse rapidly.
It is important to note that none of these calculations include
the effects of weathering, volatilization or other physical or
chemical reactions which might reduce concentrations in the water
column or sediments.2/
Estimating the dispersion of releases in Mobile Bay for
persistent materials, such as PCBs, is difficult. Among the
factors that would influence the dispersion of materials in the
short-term are the density of the material (sinking or floating
spill), physical or chemical reactions of the material while in
the water column, settling velocities, the location of the spill,
wind speed and direction, and the direction and velocity of
surface and subsurface currents. ASA developed a number of
scenarios for the short-term dispersion of floating spills based
on most probable wind speeds and directions in Mobile Bay. The
long-term transport of PCBs in sediments was qualitatively
assessed based on information on average hydrodynamic energy
I/The JRB analysis cited previously indicates that only a small
percentage of PCBs in a surface slick would volatilize and most
of these would be the less chlorinated PCBs. Thus, we do not
expect such processes to materially reduce the amount of PCBs
remaining in the marine environment after a spill. However, a
significant amount of EDC could volatilize if there were a spill,
particularly in the shallow waters of Mobile Bay.
7-5
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levels in the Bay. Estimates of the dispersion of spills that
sink to the bottom of the Mobile ship channel are taken from the
JRB analysis.
Once transport and dispersion of the hazardous constituent
was calculated using the methods outlined above/ ASA estimated
the effects of the resulting water column and sediment
concentrations on ten trophic levels of marine organisms found in
Mobile Bay and the Gulf of Mexico. The trophic levels considered
include:
o phytoplankton,
o benthic flora,
o benthic deposit feeders (e.g. mollusks),
o demersal detritivores (e.g. shrimp, crabs),
o herbivorous zooplankton,
o carnivorous zooplankton,
o small pelagic fish (e.g. menhaden, herring),
o large pelagic fish (e.g. tunas, sharks),
o benthic invertebrate predators (e.g. corals), and
o demersal fish (e.g. flatfish, deep sea species).
ASA used a computerized marine ecosystem model to estimate
effects on these trophic levels. The model includes
formulations of physiological and metabolic processes for each
trophic level. Seasonal cycles are important in the areas of
interest and are reflected in the ASA model. The ecosystems
model estimates whether pollutant concentrations in the water
column and in sediments are acutely toxic to marine species (in
the event of sufficiently high concentrations) and estimates
bioconcentration through the food web. Dose-response
relationships for acute effects and bioconcentration factors
were estimated by ASA from available data in the literature.
Chronic marine effects (for example, changes in reproductive
rates) due to long-term exposure to sublethal concentrations or
to bioconcentration are not included due to lack of quantitative
7-6
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information relating cause and effect. A diagram showing the
interrelationships among trophic levels in the model is provided
as Exhibit 7-1.
ASA's analyses describe the effects of marine spills through
the following measures:
1. physical descriptions of the dispersion of the
hazardous constituent;
2. changes in the level of biomass in the area
affected by the spill, reflecting the acute
toxicity of the hazardous constituent to marine
organisms as well as effects through the food web;
and
3. changes in the tissue concentration of the
hazardous constituent in each of the ten trophic
levels to reflect bioconcentration and potential
chronic effects.
The transport model delineates the area affected by the spill and
estimates the contaminant concentrations in the sediments in this
area. For the continental shelf and burn zone cases, sediment
concentrations exceeding 1 ppb after settling of the pollutant
are used to define the area over which the ecosystems model is
run. Changes in the level of biomass and in tissue
concentrations are calculated assuming that the pollutant is
uniformly concentrated in the sediments over this area (the
average concentration is calculated by dividing the amount of
pollutant within the area by the volume of the top 5 cm of
sediments within the area). Marine species are assumed neither
to migrate into or out of the contaminated area.
For the Mobile Bay case, the ecosystems model was run
assuming uniform concentration across the entire bay (calculated
as a weighted average of contaminated and uncontaminated
sediments). This simplification was necessary because there is
insufficient information to predict accurately the long-term
transport of PCBs in sediments and to assess how the feeding
habits of marine species would affect bioconcentration if
portions of the Bay were contaminated at different levels. In
all analyses, biomass is estimated in units of milligrams of
carbon per square meter of area. This can be converted to
milligrams wet weight of living matter per square meter by
7-7
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multiplying by a factor of 20. As stated above, all of the
methods and data used and the results obtained by ASA are
explained in more detail in Appendix I.
In the event of a spill some hazardous constituents might
volatilize and subsequently could be inhaled by humans causing
possible short term health effects. We estimated the potential
for such effects by estimating the rate of volatilization for
each constituent for the first 24 hours following a spill and
modeling downwind ambient concentrations. For the harbor and
continental shelf spills, we used a simplified virtual point
source air dispersion equation to calculate ground level downwind
concentrations at the plume centerline. For the burn zone spill
we adapted ASA's air dispersion modeling results (see Appendix G)
to generate similar outputs. In all three cases, concentrations
for the first 24 hours following a spill were calculated for the
nearest point at which humans might be exposed, and the resulting
estimates were compared with allowable limits for short-term
exposure to the constituents of interest. Appendix H describes
lEc's volatilization analyses in detail.
The models and methods used by ASA and lEc to estimate
dispersion and effects from ocean transportation releases are by
nature incomplete and uncertain.!/ The major strengths of these
tools are that they:
o unify existing scientific knowledge into an
internally consistent framework,
o force explicit recognition of assumptions and data
sources, and
o allow investigation of the effect of alternative
data, methods or policies on the results
predicted.
A/The ASA model is the most comprehensive currently available.
However, because it has only recently been developed, it has not
yet undergone a comprehensive peer review.
7-8
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Because of the extremely complex processes being analyzed and the
significant scientific uncertainties that remain in many areas,
the results obtained should be viewed as a general indication,
rather than a precise measure, of pollutant transport and of
potential effects. Ideally, these models and methods should only
be used when time and resources allow extensive sensitivity
analyses to be carried out, coupled with verification studies
utilizing field measurements. Such studies have not been
performed for the applications reported here. The marine models,
however, have been run using data on background concentrations of
PCBs in sediments and the water column and have yielded estimates
of concentrations of PCBs in fish that generally agree with
measured concentrations.
All of the methods and results are described in more detail
in the appendices cited previously. These appendices also contain
discussions of the specific limitations which pertain to each
step of the analyses. All results should be interpreted with
caution, and with a full understanding of all of the limitations.
MARINE EFFECTS OF A RELEASE
OF PCBS IN MOBILE BAY
To analyze the effects of a release in Mobile Bay, we assume
that the spill occurs in the ship channel at the point shown in
Exhibit 7-2. Three release quantities are analyzed — half a
tank (88 metric tons of PCBs), two tanks (350 metric tons of
PCBs), and the entire cargo (1,400 metric tons of PCBs). The
paragraphs below describe the likely dispersion of the hazardous
constituents and the potential ecological effects.
Pollutant Dispersion
A spill of PCBs would float or sink depending on its density
relative to seawater. For the floating case, ASA assumed the
spill would behave much like an oil spill and estimates its
likely path using most probable wind directions and speeds for
the Bay. Exhibit 7-2 shows the likely paths of spills occurring
at low tide (the likely paths at high tide are shown in Appendix
I). The path of the spill depends both on wind direction and
water circulation, which is counter clockwise in the Bay. Case A
reflects winds coming out of the north and Case B reflects winds
coming out of the southwest. Since Case A represents a worst
case in terms of the initial area affected by a spill (in the
7-9
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absence of efforts to contain the slick) and in terms of the
Bay's retention of PCBs, we restricted further analysis to that
case.
The amount of PCBs likely to settle out into sediments
before the slick reaches the shoreline is difficult to estimate
precisely. ASA estimates that from 30 to 70 percent of the PCBs
could settle before reaching shore. We assume for further
analysis that 50 percent of the PCBs become entrained in
sediments on the floor of the Bay and the remaining 50 percent
become stranded on the shoreline.
Exhibit 7-3 shows the area of the Bay's sediments initially
affected by a spill of 8 tanks. As shown, about 15 percent of
the floor of the Bay is affected. A spill of half a tank would
affect about 5 percent and a spill of 2 tanks would affect about
9 percent of the floor of the Bay. Under the assumptions
outlined above, the initial concentration of PCBs in the top 5 cm
of sediments averaged over the contaminated zone would be about
13 ppm, 23 ppm, and 61 ppm for the half, 2 tank, and 8 tank
spills, respectively.
The long-term dispersion of PCBs in the Bay is difficult to
predict accurately. Data on net water circulation in the Bay
suggest that resuspended PCBs would move generally northward and
eastward on flood tides, though some PCBs could move out the
mouth of the Bay on ebb tides. Marine organisms may also play a
role in redistributing PCBs in the Bay. PCBs reaching the
shoreline probably would gradually penetrate into the fine
sediments and remain there for a long time.
PCB wastes with a density greater than seawater probably
would sink to the bottom of the ship channel, although some could
settle in shallower waters outside the channel depending on wind
conditions. The distance the wastes would be transported away
from the spill site would depend on the specific gravity of the
material, the extent of adsorption onto particulate matter, and
current direction and velocity at the time of the spill. Under
maximum current conditions, JRB estimated that some PCBs could be
transported as much as 7 to 18 kilometers from the spill site.
However, most of the waste probably would settle out much closer
to the spill site.
We have not attempted to evaluate the long-term dispersion
of "sinking" spills nor effects on the marine environment. We
expect that remedial actions would remove a substantial portion
7-10
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of the wastes and routine dredging of the ship channel each year
by the Army Corps of Engineers would remove further amounts from
the Bay. However, determining the likely effects of dredging
activities on removal and resuspension of PCBs is beyond the
scope of this study.
Marine Effects
Estimating the potential effects of spills in a complex
estuarine ecosystem such as Mobile Bay is difficult at best.
Nonetheless, to develop a general indication of the likely
effects of PCB spills we asked ASA to make a number of
simplyifying assumptions and then to apply their ecosystem model
to the Bay. The modeling assumptions are fully described in
Appendix I, but two of particular interest are (1) PCBs in
sediments are assumed to be fully "available" to benthos (in
terms of mortality response) and (2) marine organisms, on
average, are assumed equally likely to feed in contaminated or
clean areas. Since some PCBs are made biologically unavailable
through binding with organic carbon in sediments, the modeled
results tend to overstate biomass and bioconcentration effects.£/
Assuming "average feeding" allows the model to be run using an
average PCB concentration in sediments across the entire Bay and
tends to account for the potential spreading of PCBs over time.
Exhibits 7-4 and 7-5 present the model's estimates of the
effects of a spill on the biomass of various trophic levels and
on concentrations of PCBs in tissues. The results in Exhibit 7-4
indicate that benthic feeders and predators would be largely
eliminated in the Bay. While this exhibit shows results for an 8
tank spill, results are similar for spills of one half and two
tanks. Other trophic levels would not be significantly affected.
However, the model predicts that PCB concentrations in marine
organisms would increase by about 3 to 5 orders of magnitude
i/Studies of the effects of PCBs in sediments on marine life in
the Puget Sound and New York Bight areas indicate less adverse
effects than normally would be expected. These preliminary
findings suggest that the toxicity of PCBs can be reduced by
organic carbon binding, but existing data are not sufficient to
estimate precisely the extent of the reduction.
7-11
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depending on the size of the spill. Exhibit 7-5 shows PCB
concentrations increasing in small pelagic fish and shrimp by
about 4 to 5 orders of magnitude (to tissue concentrations
slightly in excess of 2 ppm) for a half tank spill. For larger
spills, such as an 8 tank spill, tissue concentrations are
estimated at about 15 ppm. These effects are expected to last
for an extended period of time.
The above results represent an "average" across all of
Mobile Bay. It is likely that portions of the Bay would be more
or less contaminated than the average. Thus, some benthic
species probably would survive in less contaminated areas.
Avoidance of contaminated areas by marine species also could
reduce average contamination levels. However, we have not
attempted to determine potential adverse effects on spawning and
nursery areas or on species in the affected low-lying marsh
areas.
MARINE EFFECTS OF A RELEASE OF PCBS
OVER THE CONTINENTAL SHELF
The continental shelf stretches roughly 100 to 150
kilometers offshore from the Gulf of Mexico coastline, and is
defined by water depths less than 100 meters. These relatively
shallow waters are rich in marine life and are important for both
ecological and commercial reasons. To evaluate the consequences
of a marine accident and spill in these waters, we modeled the
dispersion and effects of a spill at a point near the mouth of
the Mississippi River (29 degrees 45 minutes North and 88 degrees
30 minutes West), The paragraphs below summarize the results of
the analysis.
Pollutant Dispersion
The dispersion of PCBs was calculated for both a floating
and a sinking case. In the floating case, we assume that the
PCBs would be confined to the top one meter of the water column
and would be dispersed by surface currents and winds. The slick
would spread to cover about two square kilometers within several
hours of the spill, and then would break up into patches and
disperse over a wider area. Assuming average wind and current,
some portions of the slick would come ashore on the Mississippi
delta while the remainder would move in a generally eastward
direction. Exhibits 7-6 and 7-7 show the position of the slick
7-12
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at 10 and 50 days after the spill. (These exhibits show
concentrations calculated for the release of the entire cargo;
concentrations for lesser size spills would be proportionately
lower than those shown and the area of dispersion of the slick
would be slightly smaller.) After some time much of the PCBs
probably would sink to the bottom of the continental shelf due
to weathering, volatilization of the lighter hydrocarbons, and
adsorption onto particulate matter. The actual behavior of the
slick . would be governed by the specific wind and sea states at
the time of the spill.fi/
In the sinking case, we assume that the PCBs would sink to
the bottom and lodge in the top 5 centimeters of the sediments.
Because of the relatively shallow depths at the assumed spill
location, all the pollutant would reach the ocean floor within
two days after the spill event. Thus, concentrations in the water
column would be elevated for only a short time. Surface and
subsurface currents would move and disperse the PCBs as they fall
through the water column to the bottom. In addition, because of
the relatively shallow depth of the continental shelf, the PCBs
in the sediments would be continually resuspended by wave action
and storm events. Thus, PCBs would continue to spread and
disperse on the bottom for many years.
Maps provided as Exhibits 7-8 and 7-9 display the estimated
extent of PCB-contaminated sediments at 1 and 10 years for an 8
tank spill. The area of contamination would be about the same
for lesser size spills, but the concentrations would be
proportionately less. Over time, sediments contaminated to
levels greater than 1 ppb would include an area on the shelf of
about 17,500 square kilometers.
fi/An analysis performed by JRB estimates the percentage of spills
occurring on different segments of the ship track that would come
ashore (anywhere) in 3, 10 and 30 days. The analysis indicates
that a very high percentage of spills occurring close to Mobile
Bay would come ashore (over 90 percent within 10 days). This
percentage becomes lower as the spill location moves further from
Mobile Bay — closer to the Mississippi delta area. For example,
only about 15 to 30 percent of spills off the Mississippi delta
are estimated to come ashore within 10 days. However, about 70
percent of these are estimated to come ashore within 30 days.
(See the JRB study cited previously, pp. 2-7 to 2-10.)
7-13
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Marine Effects
We have not quantified the effects on the marine ecosystem
that a floating spill might have. A temporary effect of a PCB
slick would be to interfere with the "microlayer" on the surface
of the Gulf. Predicted concentrations of PCBs would be lethal to
the organisms in the microlayer, but at this time data do not
exist to quantify the role of the microlayer in the overall
marine ecosystem. As PCBs leave the slick and settle on the
ocean floor, the ecosystem effects expected would approach those
predicted for the sinking case. Indeed, the area of the slick
shown in Exhibit 7-7 corresponds fairly closely to the area of
sediments contaminated by a sinking spill as shown in Exhibits
7-8 and 7-9. If the slick comes into contact with the
shoreline, and PCBs still remain in it, significant, long-term
coastal impacts are likely but have not been estimated.
Exhibits 7-10 and 7-11 summarize the marine ecosystem
effects over the continental shelf predicted by the model for a
one half tank spill of PCBs that sinks. As reported above, an
area of sediment of roughly 17,500 square kilometers is likely to
be contaminated. The results indicate that there probably would
be a small decrease in the total biomass levels in the area, with
benthic organisms suffering a substantial reduction. However,
the major impact would be an increased level of PCBs in the
tissues of most trophic levels — as shown in Exhibit 7-11, most
trophic levels experience an increase of from two to three orders
of magnitude. Large pelagic and demersal fish would experience
the greater increase, followed by small pelagic fish and demersal
detritivores (e.g. shrimp and crabs). These levels of PCB
contamination might cause chronic effects in the marine species.
Spills of greater amounts are estimated to result in
concentrations in tissues proportionately higher, i.e., four
times greater for a 2 tank spill and 16 times greater for an 8
tank spill. The effects on the biomass of benthic organisms are
also predicted to be more severe. Specific modeling results for
these cases are shown in Appendix I.
There is substantial uncertainty concerning the length of
time and concentrations at which PCBs would remain in the
sediments. The increased PCB tissue concentrations projected in
Exhibit 7-11 to last for only several years are based on the
simplifying assumption made for modeling purposes that PCBs would
be released from sediments linearly at a fixed rate over time.
A decaying exponential release probably would be a more
7-14
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appropriate functional form. Under such an approach, the
duration of PCBs in sediments and of the bioaccummulation effects
would be much longer than shown in the exhibits.
MARINE EFFECTS OF A RELEASE OF PCBS
IN THE BURN ZONE
The center of the Gulf of Mexico burn zone is located in
1,400 meters of water at 26 degrees 40 minutes North and 93
degrees 40 minutes West. At this position, the zone is
approximately 315 kilometers south southeast of Galveston, Texas.
To evaluate the consequences of a spill in the burn zone, we
modeled the dispersion and effects of a spill at the center of
the zone. The paragraphs below summarize the results of the
analysis.
Pollutant Dispersion
As in the prior cases, the dispersion of PCBs was calculated
for both a floating and a sinking case. In the floating case, we
assume that the PCBs would be confined to the top one meter of
the water column and would be dispersed by surface currents and
winds. The spread of the slick would occur much as described for
the continental shelf spill. Assuming average wind and currents,
the slick from a burn zone spill would move generally westward.
Some portion of the slick could come ashore within 50 days of
release. However, most of the PCBs would sink to the ocean floor
by this time due to weathering, volatilization of the lighter
hydrocarbons, and adsorption onto particulate matter. Exhibits
7-12 and 7-13 show the position of the slick at 10 and 50 days
after the spill. These exhibits show concentrations calculated
for release of the entire cargo; concentrations for lesser spills
would be proportionately lower and the area of dispersion of the
slick would be slightly less. The actual behavior of the slick
would be governed by the specific wind and sea states at the time
of the spill.2/
I/The JRB analysis indicates that about 22 percent of slicks
originating in the burn zone would come ashore within 30 days.
(See the JRB study cited previously, p. 2-10.)
7-15
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In the sinking case for PCBsf we again assume that the PCBs
would sink to the bottom and lodge in the top 5 centimeters of
the sediments. Because we assume a distribution of sinking times,
the PCBs would arrive at the bottom from 1 to 25 days after the
spill event. Thus, concentrations in the water column are
elevated for a longer time than in the harbor and shelf cases.
Surface and subsurface currents move and disperse the PCBs as
they fall through the water column to the bottom. Once on the
bottom, resuspension is negligible due to the greater depths in
the area.
Maps provided in Exhibits 7-14 and 7-15 display the extent
of PCB-containinated sediments at 1 and 25 days after an 8 tank
spill. At 25 days all PCBs have reached the bottom and sediments
contaminated to levels greater than 1 ppb would include an area
of about 57,000 square kilometers. For lesser spills, the area of
contamination would be about the same, but the concentrations
would be proportionately less.
Marine Effects
He have not quantified the effects that a floating spill in
the burn zone might have on the marine ecosystem. A temporary
effect of a PCB slick would be to interfere with the
"microlayer" on the surface of the Gulf. The possible effects of
this interference would be similar to those discussed for the
continental shelf spill. As PCBs leave the slick and settle on
the ocean floor, the ecosystem effects would approach those
predicted for the sinking case.
Exhibits 7-16 and 7-17 summarize the marine ecosystem
effects modeled for a one half tank spill in the burn zone. As
reported above an area of sediments of roughly 57,000 square
kilometers would be contaminated. The results indicate that there
probably would be a small decrease in the biomass of some
benthic communities. The effects on benthic communities are
estimated to be more severe for larger spills, as is shown in
Appendix I. As shown in Exhibit 7-17, PCB concentrations are
projected to increase slightly in only benthic species and bottom
feeders. Larger spills are projected to increase PCB tissue
concentrations in benthic species and bottom feeders by three to
four orders of magnitude, but there is little effect on pelagic
fish. As mentioned earlier, there is considerable uncertainty
7-16
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over the duration of PCBs in sediments and it is likely that the
effects modeled for benthic communities would persist for fairly
long time periods.
MARINE EFFECTS OF RELEASES OF EDC
ASA also analyzed the marine effects of releases of the
entire cargo of EDC wastes in Mobile Bay, the continental shelf,
and the burn zone. The behavior of EDC in the marine environment
is very different from that of PCBs — it is highly soluble, it
is volatile, it is not highly toxic, and it does not
bioaccumulate. The net effect of these characteristics is that
spills of EDC have very little adverse effect on the marine
environment.
For a spill of EDC in Mobile Bay, we assume that all the
material would go into solution and would rapidly disperse
throughout the bay. The initial concentration would be about 700
ug/1. However, flushing of the bay and volatilization would
rapidly reduce EDC concentrations, so that within 50 days the
concentration of EDC would be virtually zero. The relatively
brief elevated water concentrations would cause a brief increase
in marine tissue concentrations of EDC. These tissues would
return quickly (roughly 60 days) to background levels. As no
acute toxic effects are expected, the marine effects of the EDC
spill are likely to be transient and relatively minor.
The effects of spills of EDC over the continental shelf and
in the burn zone are similar to the effects in the bay, though
the initial concentrations and their duration are less.
Consequently, marine effects of an EDC spill in either of these
locations are likely to be transient and minor.
HUMAN HEALTH EFFECTS OF SPILLS
OF PCB AND EDC WASTE
To evaluate short-term human health risks resulting from a
spill, we have compared the possible concentrations of
volatilized PCBs and EDC to the short-term exposure limit (STEL)
and the Threshold Limit Value (TLV) for these chemicals. The
STEL represents the maximum concentration to which workers can be
exposed for short periods without suffering irritation, tissue
damage or narcosis. The TLV represents the concentration to
which workers may be repeatedly exposed without adverse acute
7-17
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effects. We have adjusted the TLV values used for EDC and PCBs
downward to reflect continuous exposure rather than exposure for
a 40-hour work week.
Atmospheric concentrations of PCBs and EDC are calculated in
Appendix H. We estimated the rates of volatilization of each
material in the three spill locations and modeled downwind
ambient concentrations using average and "worst case"
meteorological assumptions.
Exhibit 7-18 displays the ratios of these calculated air
concentrations to the STEL and adjusted TLV values. As this
exhibit shows, concentrations of both PCBs and EDC exceed
adjusted TLV when the spill occurs at 1 km from Mobile. Only
under worst case meteorological conditions would the
concentrations of EDC exceed the STEL. For the spill at 15 km
from the city, only EDC under worst case meteorological
conditions would exceed the TLV. The ratios of concentrations of
PCBs or EDC due to spills over the continental shelf or in the
burn zone are far below one. In view of the fact that the
population would be exposed to volatilization from a spill for
period of a week or more, the adjusted TLV is the most
appropriate threshold to consider. Thus, it is likely that only
for spills closer than 15 km would air concentrations be of
concern from a human health standpoint.
SUMMARY
This chapter presents our estimates of the dispersion of
pollutants and resulting marine and human effects from releases
during ocean transportation. As stated in the Introduction, it is
important to understand that these releases are unlikely to occur
and that attempts to characterize the possible effects of such
releases have many limitations. Overall, the results show that
PCB spills in Mobile Bay would have extremely severe consequences
for the marine ecosystem. PCB spills over the continental shelf
could significantly harm the ecosystem, whereas spills in the
burn zone would have lesser effects, limited to benthic communi-
ties and to bottom feeders. In contrast, EDC spills do rela-
tively little damage to the marine ecosystem. Short-term human
health effects from inhalation of volatilized wastes are un-
likely, except in the case of an EDC spill very close to Mobile.
All of these results are explained further in Appendices H and I.
7-18
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Exhibit 7-1
SUMMARY OF ENERGY (CAR3O!!) FLOW IH THE ECOLOGICAL
MODEL AS APPLIED TO THE GULF OF MEXICO
LIGHT
Herbivorous
ZoopUnkton
Carnivorous
ZoopUnkton
* Only Mobile Bay
" Only Mobile Bay and Shelf
Only Shelf and Offshore
Source: Appendix I, Figure 3-1
-------
Exhibit 7-2
PROJECTED PATH OF SPILLS OCCURRING
IN MOBILE BAY AT LOW TIDE
SCALED
Kilometers
r~=3" >—: r-H
0246
DEPTH CONTOURS'
2m
3m
4m
• 5 5m
(Reference Plone-
Mean Low Water)
so-
so'
GULF | OF MEXICO
Source: Appendix I, Fiqure 6-3a
-------
Exhibit 7-3
AREA OF BAY SEDIMENTS INITIALLY AFFECTED BY
A FLOATING SPILL (CASE A)
SCALE:
Kilometers
' -— ' >-< r-l
0246
DEPTH CONTOURS'
--- 2m
---- 3m
MOBILE
• 5 5m
(Reference Plone-
Mean Low Water)
30*
30''
GUL F
88°
OF MEXICO
Source: Appendix I, Fiqure 6-3d
-------
Exhibit 7-4
PROJECTED BIOMASS LEVELS IN MOBILE BAY AFTER
A SPILL OF AN ENTIRE CARGO OF PCBS
r!.3' 9IOU.OUT U*
10'
o
o
t/)
1
CD
10' -
10"
I..i i, n,.
~1
XI.I.I. Mix..,
*»•!
I'M
_ 5
10
0.
5.
10.
IS.
20. 25. 30.
TIME (yrs)
35.
40.
45.
50.
Source: Appendix I, Figure 6-4a
-------
Exhibit 7-5
ESTIMATED PCB CONCENTRATIONS IN TISSUE AFTER A
HALF TANK SPILL OF PCBS IN MOBILE BAY
[PLOT: BIOU.COHC.U6
1.
1.
1-
lit
Ikl
• * r
1 1
l«
rut*
*«p*'' t
| »«I»MI
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•l«flr fl
1
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• • • •
'••
10 ->
105-,
JD :
Q. ,1
Q. 10 I
_ )
~Z. 10 i
o i
ce :
V— . l
^ 10 -i
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i
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'• i • , ^ „ . , - . _^. , J
i !• i
ji " " ""
1
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. .1,, f
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_l ^ __ ^ — •• ^ ^™ — ^— — — — — 1
1 . _, - — -— , —»^— — ^— —» — • • '• •• — . •
1 ' ' ' '. ' !, in 9?;. 30. 35. 40. 45- 50
5.
10.
15.
TIME (yrs)
Source: Appendix I, Figure 6-4d
-------
Exhibit 7-6
CULT OP UCXICO — SPILL ALONG SHIP TRACK
id OAT fCB CONC(NI»AT IONS ») UAIC* su»f*cf
ASSUUCS MO SCMUNC Of POLLUTANT
ON SHUT
Concentrations in ppb
Hource: Appondix I, Ficjurc 6-9
-------
Exhibit 7-7
GULF OF UEXICO — SPILL ALONG SHIP 7R/VCK. ON SHELf
SO 0»V PCB COMCCNTMT10NS AT HATCH
ASSUWCS MO SETHINC of POLLUTANT
Concentrations in ppb
Source: Appendix I, Figure 6-10
-------
Exhibit 7-8
GULF OF MEXICO — SPILL ALONG SHIP TRACK. ON SHELF
1 YCA* PCB COMCCWTIUT JONS ON BOTIOW
ASSUMING VARUIIC SIHllNC VtLOCIIHS
Concentrations in ppb
Source: Appendix I, Figure 6-5a
-------
Exhibit 7-9
CULF OF UEXICO — SPILL ALONG SHIP TRACK. ON SHELF
10 YEA* fCt CONCCWT HAT IONS OK BOTTOM
ASSUMING VAUIABLC SCTUIMC VtLOCITICS
Concentrations in ppb
Source: Appendix I, Figure 6-6a
-------
FPL or
Exhibit 7-10
PROJECTED BIOMASS LEVELS AFTER A HALF TANK SPILL
OF PCBS OVER THE CONTINENTAL SHELF
siou.our.SB
"1
CN
O
o
y,
O
•— <
CQ
10' -,
10-)
10'
»•!«f It fI ik*
10"
0.
10.
~\—
15.
~T
20.
25. 30
TIME (yrs)
35.
40,
~T
45
50
Source: Appendix I, Figure 6-16d,
-------
Exhibit 7-11
ESTIMATED PCB CONCENTRATIONS IN TISSUE AFTER A
HALF TANK SPILL OF PCBS OVER THE CONTINENTAL SHELF
PLOT• B:OU.CONC.sa
10'
^ 10' ^
JD
a
£ ios H
2 10'H
h—
<
10' -
w o
O i 0
z
o
O -i
CD
O
^ io-J-
r\
• \ V
V« l>- '*
•/;/ \'..
/:.' ?•
.
/
;t If, \
'V '' i
.f 'J:
-._,.
J L.
i g.»..t.t '.
10
15
20 25
TIME (yrs)
3C
35
40
—i—
45
Source: Appendix I, Figure 6-15c.
-------
Exhibit 7-12
CULT OF UEXICO -- INCINERATION SITE SPILL
10 OH* *CB COMCtWT*»UOWS AT *» U •
MO sciniNc or P
Concentrations in ppb
Source: Appendix I, Figure 6-20
-------
Exhibit 7-13
CULF OF UEXICO — INCINERATION SITE SPILL
SO OAV CCB COWCCWTIUnoNS »1 WMC« SURfACt
A54UWCS MO 5CTTL1MC Of POUU1»WT
Concentrations in ppb
Source: Appendix I, Figure 6-21
-------
Exhibit 7-14
GULF or MEXICO — INCINERM ION SITE SPILL
i DAY PCB coNctwmuoNs ON BOTTOM
VAR1ABIC SCTH1MC VC I OC 1 T 1C S
Concentrations in ppb
Source: Appendix I, Figure 6-17a
-------
Exhibit 7-15
CULT OF MEXICO INC1NERA 1 I ON SITE SPILL
?5 O^Y PCB COUC CWlfUIlOMS ON BOMOU
VARUBU itMLlMC VfLOClllCS
Concentrations in ppb
Source: Anpondix I, Fif|ui'c G-19a
-------
Exhibit 7-16
TAHK SPIU,
9iou.owr.o8
CM
o
o
10' -j
o
S
)0
.'0
10. IS.
20. 25. 30.
TIME (yrs)
35. 40. 45. 50
Source: Appendix I, Figure 6-26d.
-------
IT.
PLOT• 9IOU.CONC.08
Exhibit 7-17
ESTIMATED PCB CONCENTRATIONS IN TISSUE AFTER A
HALF TANK SPILL OF PCBS IN THE BURN ZONE
i*»i<»>i••
~1
2
O
o
2
O
O
CD
O
101-,
10' -
10
-'
-)—
40.
H
45.
10.
15.
20. 25.
TIME (yrs)
30.
35.
50.
Source: Appendix I, Figure 6-25c.
-------
Exhibit 7-18
RATIOS OF AIR CONCENTRATIONS TO SHORT-TERM LIMITS
Waste and Atmospheric Conditions
- Mobile Bay -
1 Km 15 Km
Continental Burn
Shelf Zone
STEL
PCB Waste
Average
Worst
EDC Waste
Average
Worst
0.2
0.3
0.4
3.8
0.01
0.03
0.03
0.33
0.003
0.021
0.0003
0.004
0.0008
0.00009
TLV
PCB Waste
Average
Worst
EDC Waste
Average
Worst
1.3
1.9
1.9
18.3
0.06
0.19
0.12
1.6
0.019
0.13
0.002
0.017
0.005
0.0004
Source: Appendix H, Exhibits H-ll, H-12
-------
EFFECTS OF RELEASES FROM
INCINERATION CHAPTER 8
INTRODUCTION
The quantity and composition of hazardous materials released
from ocean- and land-based incineration systems are described in
Chapters 3 through 6. As shown in those chapters, large
quantities of waste are released from incineration operations for
both ocean- and land-based incineration systems. For this reason,
we investigate and compare possible effects from these releases.
This chapter describes the results of this work.
We estimate both human and environmental effects that could
result from incinerator releases. For human populations we
estimate the incremental risk of developing cancer through
inhalation of atmospheric concentrations of hazardous materials
from incinerator releases. In addition, for stack releases from
land-based incineration we consider possible human health effects
resulting from ingestion of food contaminated by deposition of
pollutants on crops and subsequent bioconcentration in livestock
and poultry. In the ocean incinerator case we perform a similar
analysis for ingestion of pollutant-contaminated fish.
We also consider the possible environmental effects of
incineration releases, albeit at a lower level of effort and
resulting accuracy. For ocean-based stack releases, Applied
Science Associates, Inc. (ASA) characterized quantitatively the
possible effects resulting from deposition to the ocean surface
of POHCs, metals and chlorine. For land-based stack releases,
8-1
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Arthur D. Little, Inc. (ADD characterized the capture of metals
and chlorine in scrubber waters and the possible environmental
effects of final disposal of scrubber effluent and sludge. No
work has been completed to date on the effects of land-based
POHCs, PICs or metals on terrestrial or marine ecosystems.
All of the transport and effects estimates presented in this
chapter are calculated wherever possible using methods and data
developed or approved by EPA. Our use of these methods attempts
to:
o unify existing scientific knowledge into an
internally consistent framework,
o force explicit recognition of assumptions and data
sources, and
o allow investigation of the effect of alternative
data, methods or policies on the results
predicted.
Ideally, such methods should only be used when time and resources
allow sensitivity analyses of results to be completed and
compared to field verification studies. Such studies have not
been completed for the applications reported here. Thus, all of
the results obtained are uncertain, and should be viewed as
general characterizations of the transport and effects possible
from incineration releases. The sections below and supporting
appendices provide a discussion of the limitations that pertain
to each step of the analysis. All results should be interpreted
with caution and with a complete understanding of all of these
limitations.
The remaining sections of this chapter describe the human
health effects expected from ocean-based and land-based
incinerator releases, and then review the environmental effects
from each of these release points. The final section provides a
brief summary and comparison of the results obtained for the two
incineration systems.
HUMAN HEALTH EFFECTS
Our estimation of human health effects via inhalation for
ocean- and land-based systems includes three steps:
8-2
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1. estimation of atmospheric concentrations due to
stack releases,
2. calculation of resulting doses received by humans,
and
3. calculation of the increase in cancer risk if
human populations received these dosage levels
over a 70 year lifetime.
Each of these steps and associated interim results are presented
in detail in Appendix D (land-based systems) and Appendix G
(ocean-based systems). Although we calculate a variety of
concentration and health risk metrics in the appendices, the
discussion in the sections below is limited to the increase in
cancer risk for the most exposed individual (MEI). Risks for the
MEI are the highest estimated for any person and thus provide an
upper bound on the individual risk increases likely from
inhalation of incinerator releases.
All human health effects are estimated assuming that the
population is exposed over a 70 year lifetime. Thus, in these
calculations the annual incinerator release quantities presented
in Chapters 3 through 6 are assumed to continue for 70 years.
Although it is unlikely that incinerator operations and the
resulting releases will remain constant over such a long time
horizon, data and methods to predict human effects from shorter
exposures to chronic levels of these pollutants are not
available.
Ocean—Based Incineration
The atmospheric transport of POHCs, PICs and metals released
from the stack of the Vulcanus operating in the center of the
Gulf of Mexico burn zone was estimated by Applied Science
Associates, Inc. (ASA) using a numerical model of monthly surface
winds in the Gulf. The model incorporates two atmospheric removal
processes — washout due to rainfall and dry deposition. Washout
is modeled as a stochastic process based on long-term weather
observations in the Gulf. Dry deposition is a function of the
settling velocity of the pollutant. All pollutants that come
into contact with the ocean surface are assumed to be absorbed by
it. Dispersion modeling results are based on an average mixing
height in the western Gulf between 1000 meters (winter) and 2000
meters (summer). Ambient air concentrations of POHCs, PICs, and
8-3
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metals at coastal locations are estimated for each month of the
year.
ASA's transport results show that the position of the plume
changes monthly due to changes in the prevailing winds. Thus, no
single area of the coast is exposed continuously throughout the
entire year. Further, differences in the variability of wind
direction, within the months alter the concentration levels ex-
pected and the duration of exposure. To estimate worst case
exposure levels, ASA identified the location on the Gulf coast
that receives the highest modelled concentrations averaged over a
year from ship releases in the burn zone. This occurs at
approximately 24.5 north latitude and 97.8 west longitude, on the
coast near Brownsville, Texas. lEc used ASA's air modeling
results to determine health risks to a hypothetical "most exposed
individual" at this maximum dose location.
We use the cancer unit risk factors published by EPA's
Carcinogen Assessment Group for the POHCs, PICs and metals found
in the plume to calculate the increase in lifetime cancer risk
experienced at the MEI annual dosage level. These incremental
lifetime risks assume continuous exposure for 70 years and are
calculated for a 70 kilogram adult. The results of these calcula-
tions are summarized in Exhibit 8-1.
As shown in Exhibit 8-1, the hypothetical most exposed
individual incurs total increased risk of cancer of 6.4 in ten
million for the PCB waste and 1.1. in one million for the EDC
waste. For both wastes, over 99 percent of this increased risk
results from exposure to metals emitted from the stack.
Incremental risks for persons living at other locations on the
coast will be even lower.
Although the risks from metals are dominant in our analysis,
note that these results are sensitive to our assumptions about
metals concentrations. MEI risks would be lower for waste
streams having significantly lower concentrations of carcinogenic
metals. In addition, the results are sensitive to the settling
velocity assumed for metals. For modeling purposes, metals
emitted from the stack are assumed to rapidly take on the charac-
teristics of background metal particles in the atmosphere. These
background particles are small, approximately 1.5 micrometers,
and have slow settling velocities. If plume sampling indicates
metals emitted from the Vulcanus have higher settling velocities
than the background particles, MEI risks from metals could be
lower.
8-4
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In addition to these calculations of human health risks from
stack emissions, we analyze the risks possible through inhalation
of releases from transfer and storage of wastes at Chickasaw. We
use EPA's Atmospheric Transport Model (ATM) with meteorological
data for the Chickasaw area to estimate air concentrations out to
a 50 kilometer radius, assuming that the fugitive emissions are
released from a single point source. (Information about the ATM
model and our use of it is included in Appendix D.) The
concentrations predicted and the aggregate population exposure
are presented in Exhibit 8-2. For comparison, this exhibit also
includes the exposure estimates for fugitive emissions at the
land-based incinerators considered in this study.
Given the concentration for the maximum exposed individual
at Chickasaw as shown in Exhibit 8-2, we calculate the
incremental risk of cancer for the MEI assuming 70 years of
exposure. These estimates are shown on the bottom line of Exhibit
8-3. Exhibit 8-3 also includes the results presented in Exhibit
8-1 for purposes of comparison. As this exhibit shows, releases
from Chickasaw result in incremental risks from 2 in 100,000,000
to 5 in 10,000,000,000 for both waste streams, i.e., at least one
order of magnitude lower than the risks from stack emissions of
metals. Note that the location of the most exposed individual
differs for ocean-based stack emissions and for releases from
Chickasaw. No person at a single location would experience both
of these risk levels.
In addition to direct inhalation of stack, storage or
transfer releases, it is possible that human populations could
ingest foods contaminated by these releases. ASA characterizes
the effect that deposition of incinerator stack emissions could
have on pollutant concentrations in the water column or ocean
sediments, and the subsequent bioaccumulation of pollutants in
fish and other compartments of the marine ecosystem. The
analysis focuses on PCBs, the pollutant of interest that is most
likely to bioaccumulate in marine life, and examines the effect
of incineration of PCS wastes at sea over a 50-year period. The
results of the analysis suggest that at the expected PCS emission
rate there will be no observable change in the concentrations of
8-5
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PCBs in fish, shrimp or other Gulf marine life.I/ As a result,
seafood consumers would not face an increased cancer risk due to
deposition of stack emissions.
Land-Based Incineration
The atmospheric transport of POHCs, PICs, and metals
released from land-based incinerator stacks was estimated by lEc
for incinerators located in Arkansas and Texas. In addition, we
model the transport of transfer and storage emissions released
from these sites. Texas and Arkansas are selected as "typical"
locations because incinerators located at these sites are
currently permitted to burn PCBs. Also, these sites show
variations in meteorology, stack parameters and the size of the
surrounding population.
The analysis of risks from land-based incineration closely
parallels the incinerator ship analysis. The primary difference
between the ocean- and land-based analyses relates to the volume
of metals emissions. We assume that the land-based incinerators
are equipped with scrubbers which are capable of removing some of
the metals from the stack gases. The removal effectiveness of
scrubbers is a function of the size of metal particles in the
stack gases. For very volatile metals, such as arsenic, the
removal efficiency of scrubbers is low. For less volatile
I/To facilitate scaling the results to different levels of
incinerator performance, the ASA analysis presented in Appendix I
is based on a PCB emission rate of one kilogram per hour. At
this rate, PCB concentrations in some trophic levels — including
demersal fish and shrimp, staples of the Gulf commercial
fisheries — are predicted to increase by more than an order of
magnitude above background concentrations, posing an increased
cancer risk to seafood consumers. However, the one kilogram per
hour emission rate is more than two orders of magnitude greater
than the expected emission rate — 5.25E-3 kilograms per hour
given a 99.9999 percent DRE. According to ASA, the increased
concentration of PCBs in marine species is approximately linearly
related to the emission rate. Therefore, at the expected
emission rate, ASA expects no observable change in the
concentration of PCBs in fish, shrimp and other Gulf marine life.
8-6
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compounds, removal efficiency is higher. Analysis of trial burn
data suggests that metal emissions can range from less than one
percent to as much as 50 percent of the metals in the waste feed.
For the purposes of this analysis, we assume 50 percent of the
arsenic (a relatively volatile metal) in the waste feed is
emitted in the stack gases and 10 percent of the chromium,
cadmium and nickel. The possible environmental effects resulting
from the ultimate disposal of the scrubber effluent and sludge
are discussed in a later section of this chapter.
Our analysis of pollutant dispersion from the Texas and
Arkansas sites uses the ATM atmospheric dispersion model
developed for EPA's Office of Toxic Substances by researchers at
Oak Ridge National Laboratory. ATM is a Gaussian plume
climatological model linked to 1982 census data and to
meteorology data from 394 weather stations in the United States.
We use the model to determine atmospheric concentrations and
resulting human exposures within 50 kilometers of each
incinerator site. As in the analysis of ocean-based systems, we
assume both wet and dry deposition. Wet deposition is based on
average annual rainfall at each of the sites, and dry deposition
is a function of the settling velocity for gases and particles.
Our use of the ATM model is explained in Appendix 0.
As in the ocean-based case, we use the cancer potency
factors published by EPA's Carcinogen Assessment Group for the
POHCs, PICs, and metals found in the stack gases to calculate the
increase in lifetime cancer risk experienced by the most exposed
individual. These incremental risks assume continuous exposure
for 70 years and are calculated for a 70 kilogram adult. The
results of these calculations are summarized in Exhibit 8-4 and
explained in further detail in Appendix D.
As shown in Exhibit 8-4, the most exposed individual incurs
total increased risks of cancer ranging from 2 to 3 in 100,000
for the PCB waste and from 3 to 4 in 100,000 for the EDC waste.
Risk levels do not differ greatly for the two locations modeled.
At both sites, metals account for at least 90 percent of the
total risk. Risks from POHCs, PICs, and fugitive emissions are
approximately an order of magnitude lower than risks from metals.
Because the overall estimate of risk is determined by the volume
of metal emissions from the incinerator, the results are
sensitive to our assumptions about the quantity of metals emitted
in the stack gases. If the removal efficiencies of scrubbers are
higher than those assumed here, risk from metals is decreased.
Analysis of the trial burn data, however, suggests that it is
8-7
-------
unlikely that removal efficiencies would be higher by more than
an order of magnitude. This, in turn, would result in metal
risks approximately ten times lower than those in Exhibit 8-4
reducing the overall incremental risks of land-based incineration
to roughly one in a million.
In addition to the human health risks from inhalation
presented above, we consider possible human effects due to
ingestion of foods contaminated by stack releases of POHCs. No
PICs, metals or fugitive releases are considered in these
calculations. The ingestion risk estimates are adapted from two
studies recently completed for EPA which consider possible
ingestion risks around incinerators located in Southern
California, Wisconsin and Missouri. Our procedures to adapt
these results for this case study are described in Appendix D.
The results of our ingestion calculations show that
ingestion risks are generally at least two orders of magnitude
smaller than risks expected through inhalation. EDC wastes
generate approximately 5 times more risk through the ingestion
route than the PCS wastes.
Summary of Human Health Effects
The sections above summarize the human health risks from
releases of hazardous materials at ocean- and land-based
incinerators. These estimates are highly uncertain. The results
of air dispersion models are generally assumed to be accurate to
plus or minus 100 percent. Further, the GAG cancer unit risk
factors are generally considered certain only to plus or minus
one order of magnitude. As a result, the health risk estimates
have more meaning as relative indicators of risks from land-
versus ocean-based systems than as absolute estimators of the
levels of those risks.
Exhibit 8-5 summarizes the human health risk estimates for
releases from land- and ocean-based systems. The figures in this
exhibit are for inhalation risks to the most exposed individual
only. As the exhibit shows, the incremental risks generated by
the inhalation of pollutants are lower for the ocean-based
incinerator than they are for either our Arkansas or Texas
incinerators. For both the ocean and land case the total risks
are dominated by the risk from metals (as mentioned earlier, our
analysis probably overstates risks from metals). Although more
metals are emitted from the stack in the ocean case, they travel
8-8
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several hundred kilometers from the burn site to Brownsville
before they are inhaled by the most exposed individual. Thus,
despite the higher emission rates, the risks to the roost exposed
individual from an ocean-based incinerator are below those for
the land-based case.
A recent study prepared by EPA estimated risks to human
populations across the United States from inhalation of air
toxics. (The jggope and Magnitude of the Air Toxics Problem in the
United States, E. Haemisegger, A. Jones, B. Steigerwald, V.
Thomson, September 1984) . In this study the total risk from air
toxics at various locations throughout the U.S. is estimated to
range from 4 to 6 in 10,000 for the average individual. The most
exposed individual risks estimated for land- and ocean-based
incinerator releases are lower than risks to the average person
from air toxics estimated in this broader study.
ENVIRONMENTAL EFFECTS
Ocean-Based Incineration
Environmental effects could occur from deposition of ocean
incineration stack emissions onto the ocean's surface or from
other releases which enter the ocean during normal operations. As
explained in Chapters 5 and 6, we assume that stack emissions are
the only release expected during normal incineration activities.
(The effects of accidental releases due to a vessel casualty are
discussed in Chapter 7.) This section of Chapter 8 considers the
possible effects on the marine environment of POHCs, metals and
HC1 contained in the stack emissions. ASA evaluated the possible
effects of these materials on the marine environment. Their
analysis in this area is included as Section 5 of Appendix I,
and is summarized below.
The entry of atmospheric pollutants into the ocean is
mediated by the surface layer, and particularly by the
"microlayer." The microlayer, generally defined as the top 100
micrometers at the air-sea interface, has been shown to have very
high levels of biological activity and pollutant concentrations.
Physical and biological processes in the microlayer are not well
known, and time and resources have not permitted the inclusion of
the microlayer in the marine ecosystems model developed by ASA
and described in Chapter 7 and Appendix I. Thus, only
qualitative and relatively uncertain conclusions can be drawn at
8-9
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this time concerning the effects of POHC and metals deposition on
the ocean. The effects of chlorine deposition are better
understood.
In analyzing possible marine effects from POHCs, ASA
considered only PCBs. (Because EDC is highly soluble in water
and volatilizes rapidly, the effects of deposition of EDC into
the ocean is not of concern.) Analysis using ASA's atmospheric
and marine transport models indicates that concentrations of PCBs
in the water column during incineration would be about four
orders of magnitude below the concentrations resulting from
background deposition of PCBs.2/ Once the burn is completed,
these concentrations decline to an even smaller fraction of
background. Thus, concentrations of PCBs in the water column as
a result of incinerator plume deposition should have no
observable effect on the marine ecosystem.
A second potential ecosystem effect of PCS deposition is the
accumulation of PCBs in the ocean flow sediments, resulting in
increase in PCB concentrations in the benthos, demersal fish and
pelagic fish. At a PCB emission rate of 5.25 E-3 kilograms per
hour, ASA's analysis indicates that PCB deposition will have no
significant impact on the marine ecosystem.!/
2/These results were derived by scaling the concentrations
presented in Appendix I (based on an emission rate of one
kilogram per hour of PCBs) to reflect the assumed PCB emission
rate of 5.25E-3 kilograms per hour.
I/Once again, these conclusions are based on ASA's analyses in
Appendix I, which employ a PCB emission rate of one kilogram per
hour. At the one kilogram per hour emission rate, deposition
has a significant impact on the ecosystem. However, at the
assumed emission rate, the impact is negligible. (Personal
communication, Dr. Mark Reed, November 1984).
8-10
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This conclusion is supported by analysis showing that the
atmospheric flux of PCBs to the Gulf waters is much greater than
that expected from the Vulcanus. For example, the annual
deposition of PCBs from stack emissions to the area affected by
the plume (about 100,000 square kilometers) would be about 2
orders of magnitude less than the annual atmospheric flux to that
area. Similarly, the deposition of PCBs from stack emissions
would be about 3 orders of magnitude less than the atmospheric
flux of PCBs to the entire Gulf. (In the mid-seventies, PCB
concentrations in the atmosphere above the Gulf were higher by
about an order of magnitude, suggesting that background flux, at
one time, was 3 to 4 orders of magnitude greater than the deposi-
tion of PCBs expected for the Vulcanus.)
In assessing the possible effects of deposition of metals on
the ocean, ASA assumes that arsenic, cadmium, chromium and nickel
each are present in the waste feed at concentrations of 100 parts
per million and are emitted from the stack as free metal ions. In
general, these metals will be complexed as oxides or adsorbed to
particulates as they fall out from the stack gas plume. Once on
the ocean, remaining free metals will largely be adsorbed onto
organics in the raicrolayer. Thus, it is likely that much of the
metal fallout will be rendered non-toxic.
For modeling purposes, ASA employs a "generic" metal having
the average specific gravity, particle diameter, and molecular
weight of the four metals of interest. Based on these
characteristics, ASA's atmospheric transport model predicts that
60 percent of the metals released from the Vulcanus1 stack during
a single burn will be deposited in a 7,500 square kilometer area
of the Gulf before the plume reaches shore. ASA then calculates
the concentration of each metal if mixed to depths of 100
micrometers (i.e., all metals are retained in the microlayer), 1
meter, and 60 meters. Cadmium would exceed background
concentrations at all three mixing depths, albeit by less than a
factor of two in the 60-meter case. None of the other metals,
however, would exceed background levels at either the 60 meters
or 1 meter mixing depths. If mixed only in the microlayer, all
metals would greatly exceed background levels, as would be
expected. The impact of these high concentrations on the
microlayer is unknown at this time, though ASA notes that
measured concentrations of metals in the microlayer range from
one to fifty times surface-water background levels. Again, most
metals would not be in a reactive state when entering the ocean,
and most reactive metals that enter would be complexed and
rendered non-toxic in passing through the microlayer.
8-11
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Because their calculations assume that all metals are
retained within the mixing layer for the duration of an 11-day
burn, ASA believes that the 100 micrometer and 1 meter mixing
depths are unrealistic, and that the results of the 60-meter case
provide a reasonable worst-case prediction of metals
concentrations. The toxic effects of the slight increases in
metals concentrations shown in this case are dependent on the
degree of coroplexation and adsorption the metals undergo, but in
any case are likely to be small.
As shown previously, large amounts of chlorine in the form
of hydrochloric acid (HC1) will be emitted during incineration of
highly chlorinated wastes such as PCBs and EDC. Seawater has a
large buffering capacity and can absorb up to about 1 M mole of
HC1 per liter before the pH changes significantly. Given this
figure and assuming daily renewal of the Gulf's surface layer,
ASA estimates that all of the HC1 from a 6-day burn of EDC wastes
deposited within 14 kilometers of the ship could be mixed in the
top one centimeter of ocean with no effect on the water's pH
level. Given the normal renewal of the sea surface layer, the
turbulence of the upper 2-3 meters of the Gulf and the high
probability that the HC1 will be deposited over a much larger
area, mixing would be sufficient to absorb all HC1 released with
no noticeable effect on the marine ecosystem.
Land-Based Incineration
Hazardous materials released from land-based incinerators
could damage both terrestrial and marine ecosystems. However,
land-based units are generally equipped with scrubbers that
capture metals and chlorine before these materials are released
from the stack. While we did not consider the possible effects
of POHCs, PICs or metals from land-based units on the
environment, we asked Arthur D. Little, Inc. (ADD to judge
qualitatively the possible environmental effects of scrubber
effluent and sludge. ADL's analyses in this area are included in
Appendix F. The paragraphs below summarize ADL's findings.
Scrubber effluent or "blowdown" contains small amounts of
chloride and is disposed in several ways at existing commercial
incinerators. At one location the effluent is sold as a feedstock
to a nearby chemical plant; while at other locations the effluent
is discharged via deep wells, evaporation ponds, or waste water
treatment plants. Direct or indirect discharges to receiving
8-12
-------
water bodies must meet permit requirements and thus adverse
environmental effects are unlikely from these releases.
Similarly, disposal to deep wells is regulated and is unlikely to
cause adverse environmental effects.
Scrubber sludges are generated through the neutralization
and precipitation of scrubber effluent. The resulting solids
include particulate matter, metal precipitates and crystaline
calcium or sodium compounds (depending on the alkali base used in
the system). In general, these sludges must be disposed in a
surface impoundment or landfill meeting RCRA permit requirements.
If these permit requirements are met, no adverse environmental
effects are expected.
-Summary of Environmental Effects
The sections above consider some of the environmental
effects possible from releases of hazardous materials from land-
based and ocean-based incinerators. The analysis of these effects
is qualitative. For ocean-based systems, environmental effects
will be determined largely by the effect of incinerator releases
on the microlayer. The magnitude of these effects is uncertain
but is likely to be small. For land-based systems, the impact of
scrubber operations on the environment is also judged to be
small. Other possible effects on the environment are not
considered.
SUMMARY
This chapter presents estimates of the effects of releases
from ocean- and land-based incinerator operations. Human, health
effects are expected to be relatively small for land- and ocean-
based systems. Environmental effects from ocean-based operations
are uncertain at present due to lack of scientific data on the
importance and role of the microlayer but are likely to be small.
Risks from POHCs emitted from the ocean-based system will
typically be smaller than POHC risks at land-based facilities.
Greater uncertainty is associated with the relative risks from
PICs. However, it is unlikely that the risk from PICs emitted
from an ocean-based system would exceed the risk from PICs at
land-based facilities. Risks from metals are somewhat lower for
the ocean-based incinerator although these results are sensitive
to changes in the efficiency of scrubbers at the land-based
8-13
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facilities. Environmental effects from land systems are not
considered completely, but the effects of scrubber operations are
expected to be small.
8-14
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Exhibit 8-1
INCREMENTAL RISK TO MOST EXPOSED INDIVIDUAL
PROM OCEAN-BASED STACK EMISSIONS
Constituent PCB Waste EDC Waste
Stack POHCs 1.45E-10 5.51E-10
Stack PICs 1.68E-12 3.36E-9
Metals 6.37E-7 1.06E-6
TOTAL 6.37E-7 1.06E-6
Source: Appendix G, Exhibit G-30
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Exhibit 8-2
EXPOSURES DUE TO FUGITIVE EMISSIONS AT CHICKASAW AND
AT THE TEXAS AND ARKANSAS FACILITIES
Aggregate
Exposure
(person-ug/m3)
Maximum
Concentration
(ug/m3)
MEI
Concentration
(ug/m3)
Chickasaw
PCB Haste
EDC Waste
3.70E+3
5.90E+3
8.47E-4
1.35E-3
2.20E-5
3.50E-5
Texas Incinerator
PCB Haste 6.68EO
EDC Haste 9.48EO
7.96E-3
5.87E-3
1.51E-4
9.32E-5
Arkansas Incinerator
PCB Haste 4.59EO
EDC HAste 6.60EO
1.69E-3
1.19E-3
1.38E-3
9.72E-4
Source: lEc Analysis
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Exhibit 8-3
INCREMENTAL RISK TO MOST EXPOSED INDIVIDUAL
FROM ALL OCEAN-BASED EMISSIONS
Constituent PCB Waste EDC Waste
Stack POHCs 1.45E-10 5.51E-10
Stack PICs 1.68E-12 3.36E-9
Metals 6.37E-7 1.06E-6
TOTAL 6.37E-7 1.06E-6
Transfer/Storage
Chickasaw 2.02E-8 4.97E-10
Source: Appendix G, Exhibit G-30 and lEc Analysis
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Exhibit 8-4
INCREMENTAL RISK TO MOST EXPOSED INDIVIDUAL
FROM LAND-BASED EMISSIONS
Constituent
Stack POHCs
Stack PICs
Metals
Fugitives
Total
Texas
PCB Waste EDC Waste
6.10E-8
2.13E-6
2.14E-5
1..39E-7
2.37E-5
Arkansas
PCB Waste EDC Waste
1.70E-7
3.07E-8
2.61E-5
2.96E-9
4.16E-8
1.45E-6
2.98E-5
1.27E-6
1.16E-7
2.10E-8
3.63E-5
3.09E-8
2.63E-5
3.25E-5
3.65E-5
Source: Appendix D, Exhibit D-8
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Exhibit 8-5
SUMMARY OF INCREMENTAL HUMAN HEALTH RISKS
TO MOST EXPOSED INDIVIDUAL
Location PCB Waste EDC Waste
Land-based System
Texas 2.37E-5 2.63E-5
Arkansas 3.25E-5 3.65E-5
Ocean-based System
Coastline 6.37E-7 1.06E-6
Chickasaw 2.02E-8 4.97E-10
Source: Exhibits 8-3, 8-4
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-------
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-------
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•v.s. Gonmamrr PRINTING omen 1985-526-781/30377
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