REPORT OF THE, INTERAGENCY
AD HOC WORK GROUP
FOR THE CHEMICAL WASTE
INCINERATOR SHIP PROGRAM
SEPTEMBER 1980
U.S. ENVIRONMENTAL PROTECTION AGENCY
U.S. DEPARTMENT OF COMMERCE
MARITIME ADMINISTRATION
U.S. DEPARTMENT OF TRANSPORTATION
COAST GUARD
U.S. DEPARTMENT OF COMMERCE
NATIONAL BUREAU OF STANDARDS
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Octcfoer 8, 1980
MEMORANDUM FOR: Co-Chairmen of the Interagency Ad Hoc Work
Group for the Chemical Waste Incinerator Ship
Program
Mr. Russell H. Wyer
Co-Chairman, U.S. Environmental Protection Agency
Mr. Daniel W. Leubecker
Co-Chairman, U.S. Department of Commerce,
Maritime Administration
Subject: Report of the Interagency Ad Hoc Work Group for the
Chemical Waste Incinerator Ship Program
The serious environmental and public health problems associated
with the current hazardous waste situation require that the
Federal Government exercise the maximum effort to develop and
establish new technologies for treatment and destruction of these
wastes. Accordingly, we established the Interagency Ad Hoc Work
Group for the Chemical Waste Incinerator Ship Program in February
1980 to undertake a study of at-sea incineration technology and to
examine various alternatives available to the Federal Government
leading to the design, construction, and operation of one or more
incinerator ships.
Based upon the results of the Ad Hoc Work Group's study, as well
as previous studies conducted by the Environmental Protection Agency
and the Maritime Administration, we conclude that incineration at
sea is an effective and environmentally acceptable technology and
that an accelerated federal effort should be instituted to establish
chemical waste'incinerator ship capabilities in the United States.
We, therefore, approve the recommendations contained in the
subject report with the following comments:
1. In order to expedite essential coordination of
the Program, the Ad Hoc Work Group is hereby
redesignated as the Interagency Review Board
for the purposes spelled out in Recommendation
No. 7 of the Report.
2. The Economic Development Administration, the
National Oceanic and Atmospheric Administration,
the General Services Administration, and other
appropriate federal agencies shall be invited
to be represented on the Interagency Review
Board.
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2
3. Strong emphasis shall be placed on utilization
of privately-owned U.S. flag incinerator ships
as indicated in Recommendation No. 1. An
evaluation of additional alternatives to
promote the construction of privately-owned
U.S. flag incinerator ships shall be performed
on an accelerated timetable.
4. Appropriate public and private forums shall be
convened that will meet the following needs:
(a) assist in accelerating the Program by
disseminating the results of this study,
(b) dispense appropriate information on the
chemical waste disposal problem and the
potential for chemical waste incineration at
sea, and (c) obtain comments with respect to
risks, regulatory problems, and any other
concerns that have caused restraint in pursuing
at-sea incineration in the United States.
5. The appropriate offices of the Environmental
Protection Agency and the Maritime Administration
are directed to proceed with the Report's
recommendations.
In conclusion, we wish to thank you, the Co-Chapmen, and all the^
members of the Interagency Ad Hoc Work Group fbtf a iob werfl-doj
SAMUEL B. NEMIROW
Assistant Secretary
for Maritime Affairs
U.S. Department of Commerce
Administrator
U.Sj. Environmental Protection
Agency
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REPORT OF THE INTERAGENCY
AD HOC WORK GROUP FOR THE
CHEMICAL WASTE INCINERATOR
SHIP PROGRAM
September 1980
U.S. Environmental Protection Agency
U.S. Department of Commerce
Maritime Administration
U.S. Department of Transportation
Coast Guard
U.S. Department of Commerce
National Bureau of Standards
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REPORT OF THE INTERAGENCY
AD HOC WORK GROUP FOR THE
CHEMICAL WASTE INCINERATOR
SHIP PROGRAM
September 1980
APPROVED:
/IxstuaJ, Ofc
laniel W. Leuoecrer
Dame
Co-Chairman
U.S. Department of Commerce
Maritime Administration
russWy<
Co-Chairma^r
U.S. Envi^onnu
fonmental
Protection Agency
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EXECUTIVE SUMMARY
The Environmental Protection Agency has estimated that in 1980 at
least 57 million metric tons of hazardous waste will be produced in
the United States. Accumulation of uncontrolled, ever increasing
volumes of hazardous wastes threatens the public health* and the
nation's environment. The Surgeon General has indicated that toxic
chemicals seeping into the environment pose a major and growing health
problem that will plague the nation for years. Various United States
government agencies are investigating many alternative methods for
disposing of hazardous chemical wastes. Incineration at sea offers
an environmentally acceptable and cost-effective method for
destruction of many types of combustible chemical wastes. The
following conclusions and recommendations related to at-sea
incineration have been developed by the Interagency Ad Koc Work Group
for the Chemical Waste Incinerator Ship Program.
CONCLUSIONS
1. A high priority effort is required to solve the nation's
hazardous waste disposal problem. Incineration at sea
aboard specially designed or modified ships has been
demonstrated to be an environmentally acceptable and
efficient means for destruction of liquid hazardous organic
chemical wastes.
2. Adequate laws and conventions to regulate the design,
construction, and operation of incinerator ships presently exist,
e.g., the Marine Protection, Research, and Sanctuaries Act, as
amended, the Ports and Waterways Safety Act, as amended, and the
Clean Water Act, as amended.
3. Federal assistance for private incinerator ship construction
under the authority of the Merchant Marine Act of 1936, as
amended, is currently limited to federal ship loan guarantees.
4. A U.S. flag Chemical Waste Incinerator Ship Program is not likely
to develop without substantial federal assistance. Potential
investors are being extremely cautious about pursuing this
technology because of the lack of experience with operating
incinerator ships for the destruction of chemical wastes, the
need to develop a customer base for this service, and the
liabilities for any mishaps in handling these toxic wastes.
While there is some foreign flag operating experience, the
latter two factors have inhibited foreign operators from
exploiting in the United States any technological advantages
they may have.
5. Two new construction conceptual ship designs, an IMCO Type I hull
and an IMCO Type I/Type II combination hull, each with
approximately 8,000 metric tons of waste capacity, were
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determined to be optimum candidates for use at this time as a
demonstration vessel for at-sea incineration of hazardous wastes.
Either ship would be equipped with three liquid injection
incinerators for routine destruction of 30 metric tons per hour
of pumpable wastes and a single rotary kiln incinerator for
experimental incineration of solid wastes. Estimated construction
costs are $80 million for the Type I hull ship and $75 million
for the Type I/Type II hull ship, including installed incineration
equipment, for delivery in 1985. The actual cost of constructing
an incinerator ship varies with the size, type, mission,
sophistication, contract date, delivery date, market factors,
etc. The above cost estimates are considered to be maximum;
smaller, less sophisticated vessels would be priced at a
comparatively lower level. Economies of scale indicate that
a larger incinerator ship with higher burning rates could be
a more cost-effective option if large volumes of waste for
incineration are readily available and if the EPA-designated
burn site can absorb, without environmental damage, the higher
combustion emissions.
6. Conversions of existing ships, i.e., a Landing Ship Dock {LSD)
and a T-2 tanker, were evaluated and determined to be less
costly but inefficient investments compared to the optimum
design new incinerator ship for the dual mission of destroying
large volumes of pumpable wastes and conducting experimental
solid waste incineration.
7. Land based terminals are required for supplying wastes to the
incinerator ship. There are existing terminals in areas where
incinerator ships are likely to operate, or new facilities may
be constructed. Estimated capital costs for a new terminal
facility, excluding land costs, are $31 million for availability
in 1985.
RECOMMENDATIONS
1. The Maritime Administration and the Environmental Protection
Agency should pursue legislative action on a high priority
basis which would amend the Merchant Marine Act of 1936, as
amended, (the Act) and permit substantial federal assistance
and funding for the construction and operation of privately
owned U.S. flag chemical was^e incinerator ships. Such aid
would include Construction-Differential Subsidy, Operating-
Differential Subsidy, and the tax deferral benefits of the
Capital Construction Fund. Federal ship loan guarantees are
currently available under Title XI of the Act for construction
of incinerator ships. Such vessels built with federal
assistance would be designed, constructed, equipped, and
operated in accordance with the requirements of the Coast
Guard and the Environmental Protection Agency.
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If viable applications for federal assistance, as proposed in
Recommendation No. 1, are not received from private operators
within 12 months of authorization, the Maritime Administration
and the Environmental Protection Agency should evaluate other
alternatives including the construction of one federally owned
prototype chemical waste incinerator ship. This evaluation
should include the direct private sector funding for ship
construction using superfund authorities and indirect
construction support through guaranteed waste destruction
contracts.
The Environmental Protection Agency should seek federal funds
for the purpose of conducting research and development aboard
U.S. flag ships to advance the state of the art of at-sea
incineration, in particular solid waste destruction.
The National Bureau of Standards should investigate the
availability of durable and reliable materials for the safe
storage, transport, and handling of a wide variety of corrosive
hazardous chemical wastes and make appropriate recommendations.
The Environmental Protection Agency should conduct a
comprehensive study to assess the long range requirements for
at-sea treatment and destruction (for example, incineration,
chemical detoxification, and thermal treatment} of hazardous
wastes to determine the number of ships necessary, optimum
capacity and duty cycles, total forecasted volumes and tonnages
of wastes, and economic costs of system operations.
The Environmental Protection Agency, the Maritime Administration
and other federal agencies should conduct investigations
concerning methods of encouraging and assisting state and local
authorities in developing waterfront facilities to support
incinerator ships.
An Interagency Review Board consisting of representatives from
the Environmental Protection Agency, the Maritime Administration
the Coast Guard, and the National Bureau of Standards should be
established to monitor all federal government activities
related to legislation, funding, design, construction, and
operation of U.S. flag chemical waste incinerator ships.
Quarterly status reports should be prepared and submitted to
the Administrator of the Environmental Protection Agency, the
Assistant Secretary of Commerce for Maritime Affairs, the
Commandant of the Coast Guard, and the Director of the
National Bureau of Standards.
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY - CONCLUSIONS AND RECOMMENDATIONS v
INTRODUCTION 1
I. CHEMICAL WASTE INCINERATION AT SEA 3
A. Background 3
B. Need for Incineration Ships in the United States 5
C. Waste Types - Sources and Characteristics 6
D. Maritime Administration Chemical Waste Incinerator
Ship Project 9
E. Cost Analysis for Disposal of Organochlorine Wastes 9
II. ASSISTANCE PROGRAMS TO PROMOTE THE CONSTRUCTION AND
OPERATION OF CHEMICAL WASTE INCINERATOR SHIPS 11
A. Privately-Owned Vessel 11
B. Government-Owned Vessel 19
C. Hybrid (Government/Private) Vessel 24
III. SAFETY AND CONTROL MEASURES 2 5
A. International Convention on the Prevention of
Marine Pollution by Dumping of Waste and
Other Matter 25
B. International Agreements Pertaining to Maritime
Safety and to Protection of the Marine
Environment 2 6
C. Marine Protection, Research, and Sanctuaries Act
of 1972 (P.L. 92-532} (MPRSA) 27
D. National Environmental Policy Act of 1969
(P.L. 91-190} (NEPA) 28
E. Resource Conservation and Recovery Act of 1976
(P.L. 94-580) (RCRA) 29
F. Ports and Waterways Safety Act of 1972
{P.L. 92-340) (PWSA) 29
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TABLE OF CONTENTS (Continued)
Page
G. Federal Water Pollution Control Act Amendments
of 1972 (P.L. 92-500) (FWPCA) 31
H. Intervention on the High Seas Act, As Amended
(P.L. 93-248) 32
I. Coast Guard Regulations 32
J. Maritime Administration Standards 34
K. safety and Control Measures Summary 34
IV. INCINERATOR SHIP CONCEPTUAL DESIGNS 36
A. Incineration System/Ship Integration 36
B. Alternative Designs for Chemical Waste
Incinerator Ships 37
C. Conceptual Designs for U.S. Flag
Incinerator Ships 38
V. ENVIRONMENTAL ASSESSMENT 40
A. Accidental Discharge or Spillage 40
B. Incinerator Emissions 41
VI. WATERFRONT FACILITIES 4 5
A. Design and Function of Waterfront Facility 45
B. Environmental Protection Agency Regulations for
the Hazardous Waste Management System 48
C. Material Transportation Bureau Rules for Transport
of Hazardous Wastes and Hazardous Substances 50
D. Coast Guard Waterfront Facilities Regulations 50
REFERENCES 52
MEMBERSHIP - INTERAGENCY AD HOC WORK GROUP FOR THE CHEMICAL
WASTE INCINERATOR SHIP PROGRAM 55
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APPENDICES
A. U.S. Department of Commerce, Maritime Administration, Docket No.
A-131 - MarAd Chemical Waste Incinerator Ship Project, Final
Opinion and Order of the Maritime Administration and the
Maritime Subsidy Board, February 22, 1979.
B. U.S. Environmental Protection Agency, Design Recommendations for
a Shipboard At-Sea Hazardous Waste Incineration System, TRW, inc.,
EPA Contract No. 68-03-2560, Work Directive No. T5017, EPA Project
Officer: D.A. Oberacker, September 1980.
C. U.S. Department of Commerce, Maritime Administration, Concept
Design of U.S. Flag Vessels for the Chemical Waste Incinerator
Ship Program (PD-246), September 1980.
D. U.S. Environmental Protection Agency, Design Requirements for a
Waterfront Facility to Support Chemical Waste Incinerator Ships,
TRW, Inc., EPA Contract No. 68-03-2560, Work Directive No. T5017,
EPA Project Officer: D.A. Oberacker, September 1980.
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INTRODUCTION
The United States is currently faced with a serious and massive
hazardous materials disposal problem. The public health and the
nation's environment are being threatened by the accumulation of
uncontrolled/ ever increasing volumes of hazardous wastes. The
Environmental Protection Agency (EPA) has estimated that 10-15 percent
of the annual production of about 344 million metric tons (wet) of
industrial waste is hazardous. The organic chemical industry alone is
estimated to have generated 11.7 million metric tons (wet) of
hazardous waste in 1977. EPA has also estimated that 90 percent of all
hazardous waste is managed by practices that will not meet the new
federal standards being implemented under the Resource Conservation and
Recovery Act of' 1976. (1) The Agency has further stated that there
are thousands of disposal sites throughout the country being
improperly operated or maintained and that a large number may pose
significant health problems. (2)
A safe, effective, and relatively non-polluting method for the
destruction of many combustible hazardous wastes, particularly
organic chemical wastes, is incineration by ships at sea. A
successful application of this method of disposal has been carried out
aboard several foreign flag incinerator vessels. International safety
standards governing the design and operation of incineration vessels
have been developed under the auspices of the United Nations
Intergovernmental Maritime Consultative Organization (IMCO) and have
been adopted by contracting governments to the 1972 London Dumping
Convention. Both EPA and the Maritime Administration (MarAd) have
conducted extensive studies and research analyses which have confirmed
the environmental acceptability and potential economic viability of the
thermal destruction of liquid chemical wastes at sea. (3-12)
In response to the requirements of the Marine Protection, Research, and
Sanctuaries Act of 1972, as amended, to control all dumping of
hazardous materials into the sea, MarAd initiated its Chemical Waste
Incinerator Ship Project to provide a viable alternative to the ocean
dumping of hazardous wastes. With the assistance of EPA, MarAd issued
a Final Environmental Impact Statement (FEIS) concerning this Project
in July 1976. (10) Subsequently, the Maritime Administration/
Maritime Subsidy Board approved the FEIS and concluded in its Final
Opinion and Order (Docket No. A-131, February 22, 197 9)(Appendix A),
that the Project should be pursued with federal assistance. The MarAd
aid plan, as currently described, involves several elements:
(a) loan guarantees to aid in the construction of incinerator ships,
(b) sale of National Defense Reserve Fleet (NDRF) vessels for
conversion to incinerator ships, and (c) financial support for an
incinerator ship system safety analysis.
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Due to the lack .of formal applications from private industry for
assistance under the Chemical Waste Incinerator Ship Project and the
urgent need for such ships to safely dispose of hundreds of thousands
of metric tons of hazardous wastes annually, an Interagency Ad Hoc
Work Group was formed in February 1980. (13, 14, 15) The first
meeting of the Work Group was held at MarAd Headquarters on March 19,
1980, and was attended by representatives from EPA, MarAd, the Coast
Guard, and the National Bureau of Standards. The purpose of this
interagency effort has been to conduct a feasibility study which
examines the various alternatives available to the federal government
leading to the design, construction, and operation of (a) a federally-
owned or controlled incineration ship, and (b) federally assisted,
privately-owned incineration ships. The federally-controlled
incineration ship would be used for research and development purposes
in order to advance the state of the art of at-sea incineration as
well as for disposing of hazardous wastes under federal government
jurisdiction.
This document reports on the findings of the Interagency Ad Hoc Work
Group for the Chemical Waste Incinerator Ship Program.
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CHAPTER I
CHEMICAL WASTE INCINERATION AT SEA
The management of hazardous wastes in the United States is
generally inadequate and a threat to the public health and welfare.
Improper disposal practices have led to direct exposure of humans
to toxic wastes, contamination of ground waters and surface waters,
air pollution, damage to wetlands and other environmentally sensitive
areas, explosions of landfill gas, contamination of croplands with
heavy metals, and other adverse effects. Potentially the most widely
significant effect is contamination of ground water. Once seriously
contaminated, an aquifer is no longer useable as a drinking water
source. (16)
A viable alternative to help alleviate this problem is the destruction
of certain hazardous wastes, particularly organic chemical wastes,
at sea in specially designed incineration ships. EPA evaluations of
existing foreign flag incineration vessels have shown thermal
destruction of liquid chemical wastes at sea to be an environmentally
acceptable means of disposal. (3-9) The following paragraphs address
the background of incineration at sea, the need for incineration
ships in the United States, and the types of wastes to be destroyed.
A- BACKGROUND
Prior to the passage of the Marine Protection, Research, and
Sanctuaries Act in 1972 (P.L, 92-532) (MPRSA), it' was coramon practice
to dump chemical wastes directly into the sea. With the prohibition of
such disposal methods by the MPRSA and the 1972 International
Convention on the Prevention of Marine Pollution by Dumping of Wastes
and Other Matter (London Dumping Convention}, alternative technologies
for chemical waste disposal had to be developed. Land-based
incineration, deepwell injection, and landfill methods have been .
primarily used in the United States. However, in Europe, in
addition to land disposal methods, at-sea incineration technology
has been developed using several incineration tank vessels. Incineratiori
at sea is currently regulated nationally under the MPRSA and
internationally under the London Dumping Convention.
One of these European incineration ships is the M/T VULCANUS, a
converted cargo ship of 4768 metric tons deadweight with a waste tank
capacity of 3503 cubic meters. Waste is burned in two incinerators
that have a combined maximum feed rate of 2 5 metric tons/hour. A
crew of 18 mans the ship, 12 to operate the vessel and 6 to operate
the incinerators. The M/T VULCANUS meets all applicable requirements
of IMCO concerning the transport of dangerous bulk chemical cargoes.
See Appendix B.
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The first officially sanctioned at-sea incineration operation
conducted in the United States was performed aboard the M/T
VULCANUS, in the Gulf of Mexico, during October 19 74 through
January 1975. Four shiploads, about 4,000 metric tons each, of
toxic organochlorine wastes from the Shell Chemical Company, Deer
Park Manufacturing Complex, Texas, were incinerated under permits
granted by EPA at a federally approved incineration site 143 nautical
miles (305 kilometers) southeast of Galveston, Texas, and 165 nautical
miles (352 kilometers) south of Cameron, Louisiana. The site was
beyond the continental shelf, in water depths of 3,000 to 6,000 feet
(914 to 1,829 meters), outside all major shipping lanes; and well
beyond commercial shrimping and fishing depths. The burns were
monitored by EPA, the National Oceanic and Atmospheric Administration
(NOAA), and the National Aeronautics and Space Administration (NASA).
The wastes, which had resulted from the production of glycerin,
vinyl chloride, epichlorohydrin, and epoxy resins, were a mixture
of chlorinated hydrocarbons with trichloropropane, trichloroethane,
and dichlo'roethane predominating. The first two shiploads were
each incinerated under an EPA Research Permit; the second two
shiploads were burned under an EPA Interim Permit. Composition of
the waste feeds was similar during the two research burns: both
contained 63 percent chlorine, 29 percent carbon, 4 percent hydrogen,
4 percent oxygen, and traces of heavy metals. Combustion chamber
flame temperatures ranged from 1340 - 1610 degrees centigrade.
Combustion efficiencies, i.e., the percentage of hydrocarbons
combusted, ranged between 99.92 and 99.98 percent. For the most
part, the uncombusted hydrocarbons were not organochlorines.
Efficiency of destruction of organochlorines averaged 99.995 percent. (3)
A second at-sea incineration operation took place during the period
of March to April 1977 under an EPA Special Permit. Organochlorine
wastes generated by the Shell Chemical Company were destroyed by the
M/T VULCANUS in an incineration area located 130 miles south of
Sabine Pass, Texas, in the Gulf of Mexico. A total of approximately
16,000 metric tons of wastes were destroyed in four burns. The
first burn was monitored by a team of scientists and engineers from
TRW Inc., Redondo Beach, California, under contract to EPA. Average
waste feed rate was 22 metric tons per hour. Combustion efficiency
was 99.95 percent. (5)
A third incineration at sea of organochlorine wastes occurred during
the period of July 14 to September 2, 1977, on board the M/T VULCANUS
under contract to the U.S. Air Force. The operation was carried out
in three consecutive burns, the first under an EPA Research Permit
and two under a Special Permit, at a designated area in the Pacific,
approximately 200 miles west of Johnston Atoll, These burns were
mohitored by a team of scientists from TRW, Inc., under contract to
EPA. During the first burn, an EPA observer was present. An Air
Force.officer, as a working member of the analytical team, was
present during all three burns.
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This operation required special monitoring and safety procedures
because the. waste was Herbicide Orange and contained 2,3,7,8-
tetrachloro-dibenzo-p-dioxin (TCDD) as an impurity to the extent of
an average 2 parts per million. Because of the extremely high
toxicity of TCDD, special precautions were placed in effect during
all loading and operating procedures on the ship.
All burns were successfully completed. Average feed rate was
14.5 metric tons per hour. Destruction efficiencies for 2,4-D and
2 > 4,5-T were greater than 99.999 percent. Average combustion
efficiency was 99.99 percent. Average destruction efficiency of
TCDD was 99.93 percent. (6)
B. NEED FOR INCINERATION SHIPS IN THE UNITED STATES
In 1978, EPA estimated that the United States annually gene., ^tes
about 344 million metric tons of industrial wastes, including 30 to
40 million tons of hazardous wastes. Serious environmental, public
health, economic, and administrative problems and issues are associated
with the management of these wastes. (16) EPA also has projected
that in 1980 at least 57 million metric tons of hazardous waste
will be produced nationally. (17)
Various United States government agencies are investigating many
methods for disposing of chemical wastes, as part of the effort to
establish safe disposal standards for the hazaradous wastes produced
in this country. Organic petrochemical residues are among the most
durable and difficult wastes to handle. Effective and efficient
disposal methods to handle such wastes are needed immediately, because
these chemicals persist once released into the environment. Abandoned
landfill facilities, such as Love Canal in Niagara Falls, New York,
and flagrant waste disposal abuses, such as the Valley of the Drums
in Kentucky and the Chemical Control Corporation disposal site in
Elizabeth, New Jersey, have demonstrated that industrial wastes
have created a serious hazard to public health. The dumping of
such wastes into the environment is now widely recognized as a tragic
mistake that has continued for decades and will take decades to
correct. (12,18)
The Resource Conservation and Recovery Act of 1976 (P.L. 94-580) (RCRA)
gives the federal government powers to control hazardous waste disposal
across the country in order to prevent further contamination.
Establishing additional waste management facilities will be difficult.
New disposal standards limit the number of acceptable sites for waste
landfills, and nearby communities oppose the location of hazardous
waste disposal sites in their neighborhoods. Public opposition to the
siting of hazardous waste management facilities, particularly landfills,
is the most critical problem in developing new facilities. (12,19)
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Increasing citizen concern on location of land-based toxic waste
disposal of treatment facilities is seen in regard to the Rollins
Environmental Services, Inc. installation in New Jersey. Another
example of the difficulties presented by public opposition to the
siting of hazardous waste facilities occurred at Wilsonville, Illinois/
where Earthline Corporation constructed a model secure landfill.
Earthline obtained all the required State permits and began operating
the site in late 1976. In April 1977, residents learned that wastes
containing polychlorinated biphenyls (PCB's) from a cleanup operation
in Missouri were disposed of at the site. Fearing environmental and
health damages and voicing opposition to their community becoming a
dumping ground for other people's wastes, residents filed suit in an
attempt to force Earthline to close the site and to "restore and
reclaim the area so it is safe and not an eyesore." EPA, along with 27
technical experts, testified as friends of the court in favor of
Earthline's facility. Despite these efforts, the State Circuit Court
ordered the facility closed in August 1978.
Incineration at sea offers an attractive alternative to present waste
disposal practices for many types of combustible chemical wastes.
It is the technical equivalent of land-based incineration, since
99.995 percent destruction efficiency can be achieved. An incineration
ship destroys wastes away from populated areas, thereby avoiding
the risk to nearby communities and reducing, or even eliminating,
community opposition to its operation. Also, the acidic stack gases
that the incinerator emits can be directly dispersed over the ocean
surface without the elaborate "scrubbing" that is needed for acidic
stack emissions from a land-based incinerator. Finally, incineration
at sea for combustible, liquid chemical wastes is an industrial
operation which is available now and can be implemented without much
of the preliminary testing that other alternatives may require. (12)
C. WASTE TYPES - SOURCES AND CHARACTERISTICS (Appendix B)
Much of the millions of metric tons of chemical wastes produced in
the United States can be assumed to be incinerable. They originate
mainly from four principal industries: petroleum refining, organic
chemicals, synthetic fibers and resins, and pesticides. Such wastes
may be under private control or come under government jurisdiction.
The volume of waste produced annually, along with waste currently
stockpiled or from cleanup of old dump sites, appears to be more
than adequate to support the operation of at least several incineration
ships. (11) Chemical wastes may be generated from the routine
operations of manufacturing processes, intermediate manufacturers,
and end product users as well as from nonroutine events such as
spills and accidents.
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Chemical wastes which are likely to be destroyed by incineration
are basically organic in nature; thus, it follows that the major
locations of the manufacturing sources of wastes will largely
follow the pattern of the chemical industry. Therefore, it is
expected that major concentrations of sources will be along the Gulf
and Atlantic Coasts. These areas are expected to have the greatest
concentration of wastes from primary sources. Sources of waste
involving specialty chemicals and pesticides can also be readily
pinpointed because of the relatively small number of manufacturers.
Wastes from intermediate or secondary sources will be much more
widely dispersed but will still tend to follow the location pattern
typical of the chemical and petrochemical industries. Sources of
wastes from end product users (e.g., PCB-containing electrical
capacitors) can also be expected to be widely dispersed.
In classifying chemical wastes for thermal destruction, it has been
found useful to categorize them on the basis of their elemental
chemical composition. Within each class of compounds with the same
elemental composition, subclasses may be developed based on properties
(e.g., physical form, chemical composition, heat content, viscosity,
etc.) which are related to specific burning characteristics.
Examination of chemical waste streams shows that those suitable for
thermal destruction fall into one of the following four classes:
1. C-H and C-H-0 compounds, yielding CO2 and H2O on complete
combustion,
2. C-H-N and C-H-O-N compounds, yielding C02, H20 and
nitrogen oxides,
3. C-H-Cl and C-H-O-Cl compounds, yielding C02, H20 and
HC1 (gas), and
4. Other wastes including organic wastes containing both
nitrogen and chlorine, organic wastes containing sulfur,
organic wastes containing bromine, organic wastes
containing flourine, organic wastes containing phosphorus,
organic wastes containing silicon, and varied wastes
not included in the first three major classes.
Wastes can come in a variety of physical forms, e.g., liquids, solids,
slurries, and sludges; the ash formed from the incineration process
can be nonfusible, fusible, and/or metallic.
A few of the many waste streams which could be incinerated at sea
are listed in TABLE 1. The heating value for each waste stream
can be either low (less than 2,800 kcal/kg), medium (2,800 to 5,600
kcal/kg), or high (greater than 5,600 kcal/kg), as the precise
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TABLE 1. Candidate Wastes for Incineration at Sea
Waste Stream Characteristics
Hazardous Waste Stream
Constituents
Physical
Form
Heating*
Value
Silvex Herbicides
(Recalled Products}
Esters of 2,4j-D and
2,4,5-T with TCDD
contaminant
Liquid
High
Dodecyl Mercaptan
Manufacturing Wastes
Mercaptons and
organic sulfides
Liquid
High
Organic Chemical
Capacitor, Transformer
Production Wastes
Containing PCB's and
Alpha Methylstyrene
Waste containing
PCB1s and alpha
methylstyrene, in
capacitors
Solid,
Low
Nitrochlorobenzene
Manufacturing Wastes
Heavy ends and tars
from orthochloro-
nitrobenzene vacuum
di stillation
Tar
Medium
High - greater than 10,000 Etu/pound (5,600 kcal/kg)
Medium - 5,000 to 10,000 Btu/pound (2,600 to 5,600 kcal/kg)
Low - less than 5,000 Btu/pound (2r800 kcal/kg)
heat content of most waste streams is not well-defined or consistent.
It is important to recognize that waste stream descriptions obtained
from the literature, or supplied by a plant, cannot be considered
reliable until actual representative samples of the waste stream
which is to be delivered have been obtained and analyzed. Refer to
Appendix B for details on waste stream characteristics and suitable
incineration processes.
The major category of toxic chemical waste is represented by the
organic chemicals, both chlorinated and non-chlorinated, which
constitute approximately 71% by weight of the total anticipated
economic waste quantity for ocean incineration as of 1977. Next are
petroleum refinery wastes at 15%, inorganic chemicals at 11%, and
pesticides at 31. Based on environmental quantities, excluding the
inorganic chemical wastes from the economic quantities, organic- wastes
represent 801, petroleum wastes 17%, and pesticide wastes 3% of the
total. For the most part, the wastes are either liquids .or can be
handled in slurry form.
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D. MARITIME ADMINISTRATION CHEMICAL WASTE INCINERATOR SHIP PROJECT
In response to the requirements of the MPRSA to control the dumping of
hazardous materials into the sea, the Maritime Administration
initiated its Chemical Waste Incinerator Ship Project in 1974 to
provide a viable alternative to ocean dumping of hazardous wastes.
Pursuant to the National Environmental Policy Act, a Final
Environmental Impact Statement (FEIS) was issued in 1976. (10)
Subsequently, the Maritime Administration/Maritime Subsidy Board
approved the FEIS and concluded in its Final Opinion and Order
(Docket No. A-131, February 22, 1979) that the Project should be
pursued with federal assistance. The federal aid plan, as recommended
by the Board, involves the following primary elements: (1) Title XI
mortgage loan guarantees to aid in the construction of incinerator
ships, and (2) sale of National Defense Reserve Fleet (NDRF) vessels
for conversion to incinerator ships. It was later determined that
financial support for an incinerator ship system safety analysis was
also applicable to the Project.
As an initial phase of the Chemical Waste Incinerator Ship Project,
MarAd contracted with Global Marine Development, Inc., for a "Study
of the Economics and Environmental Viability of a U.S. Flag Toxic
Chemical Incinerator Ship." (11) The study, completed in December
1978, concluded that ocean incineration of toxic chemical wastes is
both economically and environmentally viable for U.S. flag ships and
that the estimated number of incinerator ships required to handle
the toxic wastes is four in 1983 and five in 1989 with each ship
capable of carrying 12,000 metric tons of waste.
As of. September 26, 1980, there have been no commercial applications
to participate in the MarAd Chemical Waste Incinerator Ship Project.
U.S. flag chemical waste incinerator ships are not likely to be built
without additional federal assistance. Potential investors are being
very cautious about pursuing this technology because of the lack of
experience with operating incinerator ships for the destruction of
chemical wastes, the need to develop a customer base for this service,
and the liabilities for any mishaps in handling these toxic wastes.
E. COST ANALYSIS FOR DISPOSAL OF ORGANOCHLORINE HASTES
A comparative study made in 1978 of the disposal of liquid
organochlorine waste by land-based incineration, at-sea incineration,
and chlorolysis at a Houston, Texas location showed at-sea
incineration to be the least costly option at $80 to $91 per metric
ton. Comparable costs were $181 to $212 per metric ton at a
centralized land-based incinerator, and $134 to $158 per metric ton by
the Hoechst-uhde chlorolysis process if suitable feedstocks are
available. Environmentally, maximum ground level concentrations of
inorganic chlorine and organochlorine species and particulates emitted
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from land-based incinerators and chlorolysis are all several orders of
magnitude lower than their respective Threshold Limit Values (TLVs) or
are within air quality standards. The only wastewater problem
identified for both disposal processes is discharges with high total
dissolved solids. For at-sea incineration the maximum sea level
concentration of hydrogen chloride is 4.4 mg/cu m and below its TLV
of 7 mg/cu m. The maximum sea level concentration of unburned wastes
is several orders of magnitude lower than the TLV of most
organochlorine compounds. Water quality is not necessarily impacted
by at-sea incineration. (8)
Overall, it may be concluded that land-based incineration, at-sea
incineration, and chlorolysis are all viable options for the disposal
of liquid organochlorine wastes. Chlorolysis should be considered if
suitable feedstocks are available and the selling price for carbon
tetrachloride remains relatively stable, mainly because it is a
recycling process that conserves resources and causes minimum
environmental impact. At-sea incineration is cost-effective for the
disposal of large quantities of liquid organochlorine wastes, and the
environmental risks are considered to be acceptable when properly
controlled and monitored. Land-based incineration, although relatively
more expensive, is suited for the disposal of other types of liquid
wastes as well as solid wastes, with no restraints on the minimum
accepted for disposal. (8)
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CHAPTER II
ASSISTANCE PROGRAMS TO PROMOTE THE CONSTRUCTION
AND OPERATION OF CHEMICAL WASTE INCINERATOR SHIPS (2 0)
The Marine Protection, Research, and Sanctuaries Act of 1972, as
amended \/ (MPRSA), directs the Secretary of Commerce to render
financial aid and other assistance to various public and private
agencies and to individuals for the purpose of determining means of
eliminating and minimizing the dumping of materials into the oceans .?/,
and to consider alternative methods of waste disposal 2/. To this
end, MarAd developed the Chemical Waste Incinerator Ship Project and,
with the assistance of EPA £/, published a Final Environmental Impact
Statement (FEIS) 5./ for the Project in 1976. The FEIS and Docket
A-131 6/, which adopted the FEIS, listed three forms of MarAd support
for an incinerator ship project. Title XI loan guarantees, sale of
National Defense Reserve Fleet (NDRF) vessels, and a combination of
the two. It is the purpose of this chapter to expand upon these three
options and address other means of funding the construction and
operation of incinerator ships.
The chapter is divided into the following three categories dealing
with government funding mechanisms: (a) a privately owned incinerator
vessel, (b) a government-owned vessel, and (c) a hybrid category
involving incidents of both government and private control.
A. PRIVATELY-OWNED VESSEL
As one of the main goals of MarAd is to promote the development
of the American merchant marine, funding mechanisms which encourage
1/ P.L. No. 92-532, 33 U.S.C. 1401, et seg.
2/ Section 203, 33 U.S.C. 1433.
3/ Section 202(a), 33 U.S.C. 1442(a).
4/ The Environmental Protection Agency regulates ocean incineration
of wastes under the Marine Protection, Research and Sanctuaries
Act of 19 72 , as amended..
5/ Final Environmental Impact Statement, Maritime Administration
Chemical Waste Incinerator Ship Project, MA-EIS, 73Q2-76-041F,
July 2, 1976 {Reference 10).
6/ Docket A-131, MARAD CHEMICAL WASTE INCINERATOR SHIP PROJECT,
Final Opinion and Order by the Maritime Subsidy Board and
the Maritime Administration, February 22, 1979 (Appendix A).
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private entrepreneurs to build and operate incinerator ships
should be given top priority in any ranking of proposed actions by
the Ad Hoc Work Group.
1. MarAd Programs
MarAd has several programs which should be considered in developing
a comprehensive Chemical Waste Incinerator Ship Program. They are: the
Title XI Loan Guarantee Program, sale of National Defense Reserve Fleet
(NDRF) vessels, the Construction-Differential Subsidy Program (CDS),
the Operating-Differential Subsidy Program (ODS), the Capital
Construction Fund (CCF), the Construction Reserve Fund (CRF), and
financial support for an incinerator ship system safety analysis
through procurement of engineering and related services. The amount
of new construction, operation, or other activities which can be
financed is necessarily governed by obligation restrictions,
available appropriated funds, eligibility standards, or other
limitations applying to these programs. Therefore, within such
governing terms, government assistance is to be channeled to those
applications which most closely meet the purposes of the Merchant
Marine Act, 1936, as amended (the "Act").
a. Title XI Federal Ship Loan Guarantees
Title XI of the Act 2/ provides for a Loan Guarantee
Program whereby the "full faith and credit" of the U.S.
is pledged to the repayment of principal and interest on
debt obligations issued by U.S. shipowners. These
guaranteed obligations are used to finance construction or
reconstruction of U.S. flag ships in American shipyards
and must not exceed 75 or 87-1/2 percent of the actual
cost of the vessel, depending on the specific application.
In addition, applicants must meet statutory requirements
with respect to financial strength and the ability to
operate the vessel on an economically sound basis. The
program enables shipowners to obtain long term financing
in the private sector at favorable terms and interest rates
that are not usually available to the average shipowner.
In Docket A-131, issued on February 22, 1979, by the Maritime
Subsidy Board of the Maritime Administration, it was held that
Title XI guarantees could be granted to secure financing for the
construction of incinerator vessels or the conversion of NDRF
vessels into incinerator ships.
7/ 46 U.S.C. 1271, at Seg.
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b. Sale of a National Defense Reserve Fleet Vessels
The National Defense Reserve Fleet (NDRF), maintained by the
Maritime Administration, is comprised of several hundred
merchant ships available for use during national emergencies £/.
As these vessels lose their value for such use, due to old
age, advances in technology or changes in U.S. emergency needs,
MarAd may either scrap the vessels or sell the vessels by
competitive sealed bids j*/. It is possible that these vessels,
upon conversion, would be capable of chemical waste incineration
at sea. Docket A-131 includes as one option the sale of NDRF
vessels for conversion into incinerator ships and states that
Title XI loan guarantees could be used to secure financing
for the conversion.
c- Construction-Differential Subsidy (CDS)
The Construction Differential Subsidy Program established by
Title V ±2' of the Act, provides for the payment of construction
subsidies to American shipbuilders in order to place the cost
of constructing a vessel in the United States on a parity with
foreign construction costs. The amount of subsidy awarded is
the excess of U.S. shipbuilding costs over the fair and reasonable
estimate of costs to construct the same vessel in a foreign
shipyard. Currently the maximum amount of CDS which can be
awarded is 50 percent of the U.S. construction price. CDS may
also be granted for reconstruction and reconditioning of existing
ships in exceptional cases.
Vessels built with CDS are subject to several restrictions
including a reguirement that the vessels be built for use in
the foreign commerce ii/ of the U.S. or in trade between foreign
ports.
8/ Merchant Ship Sales Act of 1946, 60 Stat 41, U.S.C. App. 1735,
et seq.; Docket A-131 at 5.
9/ While the Merchant Ship Sales Act, supra note 8, permits MarAd
to sell vessels either to an American citizen or to an alien, as
a matter of public policy, preference is given to Americans.
10/ Section 501, 46 U.S.C. 1151.
11/ "Foreign commerce" or "foreign trade" is defined in section 905
of the Act, 46 U.S.C. 1244, as commerce or trade between the
United States, its Territories or possessions, or the District
of Columbia,"and a foreign country. For the purposes of the
CDS and CCF Programs, bulk cargo trading between foreign ports
is also included in the definition of foreign commerce.
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Recently, the consensus within MarAd has been that the proposed
operations of incinerator ships do not fall within the foreign
commerce of the United States, as defined in the Act, and, as
a result, CDS may not be awarded for construction of incinerator
ships. Modifying legislation would be required before CDS would
be granted.
d. Operating-Differential Subsidy (OPS)
The Operating-Differential Subsidy Program, established by
Title VI of the Act 12/. provides for the payment of subsidy
to qualified U.S. flag shipping companies for the operation
of ships in essential services in the foreign commerce of the
United States, or in bulk cargo carrying services which may
include foreign-to-foreign trading. In general, this program
seeks to equalize the disparity in operating costs between
those of American ships and their foreign competitors with
respect to the wages of officers and crews, insurance, and
maintenance and repairs not compensated by insurance.
As incinerator ships are not yet considered to be operating
in the foreign commerce of the United States ±2/, as required
by Title VI, operating-differential subsidy is presently not
available to owners of such ships. As with CDS, modifying .
legislation to the Act would be required before granting ODS
for incinerator ships.
e. Capital Construction Fund (CCF)
The Capital Construction Fund Program .!£/ was created by the
19 70 amendments to the 1936 Act as a method of helping ship-
owners to accumulate the large amounts of capital needed to
acquire, construct or reconstruct additional vessels.. Once
a shipowner has established a Capital Construction Fund by
entering into a CCF agreement with the Secretary of Commerce,
he may reduce his taxable income by making deposits into the
Fund. These deposits may consist of earnings realized from
the operation of an agreement vessel, net proceeds realized
from the sale or.disposition of an agreement vessel, insurance
proceeds from the loss of an agreement vessel, earnings from
the investment of amounts on deposit in the Fund, and allowances
for depreciation. Qualified withdrawals from the Fund must be
used to construct, reconstruct or acquire additional qualified
vessels to be used in the foreign commerce, Great Lakes or
noncontiguous domestic trade or in the fisheries of the United
States. CCF benefits are presently not available to shipowners
12/ Section 601, 46 U.S.C. 1171.
13/ See Section on Construction-Differential Subsidy, supra.
14/ Section 607.
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who propose to construct or acquire incinerator vessels,
because the incinerator ship trade has not been defined as
being in the foreign trade. Under certain circumstances,
however, the operation of an incinerator ship from the
United States to fixed offshore incinerator platforms might
be considered to be in the noncontiguous domestic trade for
the purposes of the CCF Program UL/. As with CDS and ODS,
modifying legislation would be required to allow the CCF
Program to apply to incinerator ships.
f. Construction Reserve Fund (CRF)
The Construction Reserve Fund Program Ifi/ is similar to the
Capital Construction Fund Program in that both programs offer
tax deferral benefits to U.S. flag shipowners who deposit the
net proceeds or net indemnity from the sale, disposition or
loss of vessels into a special fund for use in constructing,
acquiring or reconstructing vessels. The CCF Program
offers greater tax benefits than the CRF Program by permitting
shipowners to deposit amounts from current earnings into the
Fund. However, the CCF Program is limited to the operation of
vessels in the U.S. foreign trade, Great Lakes trade, noncontiguous
domestic trade or in the fisheries. The CRF Program, on the
other hand, while not sheltering earnings as does the CCF
Program, is available to shipowners and operators in all forms
of domestic commerce as well as the Great Lakes and foreign
commerce and fisheries. The domestic commerce of the United
States includes trade between ports of the United States, its
territories and possessions embraced within the coastwise laws,
on the Great Lakes and on inland rivers. As a result, even
though the incinerator trade is presently not considered to be
in the foreign commerce for the purposes of ODS, CDS and CCF, it
might be considered to be in the domestic commerce for the
purpose of the CRF Program. A more detailed discussion of the
foreign commerce issue follows.
2• Foreign Commerce
As noted above/ several of the promotional programs run by the
Maritime Administration are available only to U.S. citizens who
propose to operate or construct a vessel to be used in the foreign
commerce of the United States. As defined in Section 905(a) of
the Act iZ/,"foreign commerce" or "foreign trade" is commerce or
trade between the United States, its Territories or possessions, or
the Pistrict"of Columbia, and a foreign country. The present
15/ See section of this chapter on Fbreign Commerce.
16/ The CRF Program was established by Section 511 of the
Merchant Marine Act, .19 36, as amendedi 46 U.S.C. 1161.
17/ 46 U.S.C. 1244, (emphasis added).
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consensus with MarAd U/ holds that the proposed incinerator vessels
will not operate "in the "foreign commerce" of the United States
because they will not travel from the United States to a foreign country.
Instead, the vessels will operate between the United States and
an EPA-designated burn site located in international waters.
The operations of an incinerator ship, while not considered to be
in the foreign commerce for the purposes of ODS and CDS, could, in
certain limited circumstances, be held to be in the noncontiguous
domestic trade for the purposes of the CCF Program. As defined in
section 607(k)(8), noncontiguous domestic trade is "trade between
the contiguous forty-eight states on the one hand and Alaska, Hawaii,
Puerto Rico and the insular territories and possessions of the
United States on the other hand. . ."
A recent legal memorandum from the General Counsel's staff
held that offshore platforms fixed to the U.S. Outer Continental
Shelf are to be considered "insular territories and possessions of
the United States" for the purpose of Section 607 of the Act. A
similar conclusion could be reached for permanently fixed incinerator
platforms created by the conversion of abandoned drilling rigs and
set up in burn sites designated by the U.S. Environmental Protection Agency
within the 200 mile fishing management zone. Incinerator ships
traveling from a U.S. port to the platform within the burn site could
be deemed to be operating in the noncontiguous domestic trade for
the purpose of the CCF Program. Such a determination would depend
upon the facts of each application for assistance.
While MarAd does not presently consider incinerator traffic to be within
the definition of "foreign commerce" of the United States for the purpose
of the Merchant Marine Act, other agencies of the government, notably
the Coast Guard and the Customs Service ££/, are not likely to consider
18/ FEIS supra note 5 at 1-4.
19/ Memorandum for Assistant General Counsel, Division of Maritime
Aids, from Melvin S. Eck, Attorney-Advisor, Re: CCF-Status of
Fixed Platform on U.S. Outer Continental Shelf (June 12, 1980).
20/ A letter from J.P. Tebeau, Director, Carriers, Drawback and
Bonds Division, U.S. Customs Service, to Mr. M.L. Neighbors, Vice
President, Universal Shipping Co., Inc. (June 7, 1973), regarding
the operation of the M/T VULC-ANUS from a U.S. port, states
"No law administered by the Bureau of Customs would prohibit any
vessel from transporting waste materials from a point within the
United States to a point on the high seas to be destroyed. Section
883; title 46, United States Code, (the Jones Act) forbids foreign
vessels from engaging in coastwise trade by transporting merchandise
be.tween points in- the United States and therefore would not be
applicable to the operation you describe."
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such traffic to be within the protected Jones Act domestic trade where
only U.S. flag ships nay operate. Informal opinions by U.S. Customs
Service officials have held that toxic chemical wastes which will be
transported by the incinerator vessels do not constitute
"merchandise" within the terms of the Jones Act/ and that the burn
sites are not "points or places within the U.S." for the purpose of
the cabotage laws. As a result, foreign vessels 21/, unhampered by
Jones Act restrictions, will be permitted to offer their services to
American waste generators and to the U.S. government, while the
fledgling American incinerator ship industry 22/ will be unable to
qualify for MarAd subsidy aid to compete with these foreign vessels for
cargoes originating in the United States. Title XI guarantees and the
sale of NDRF vessels, while offering much needed assistance, are not as
helpful as 0D9 and CDS in placing American operators in a position to
compete with the more experienced European operators.
This dependence on foreign flag incinerator ships is not in the
best national interest. The nation has an urgent need for incinerator
vessels to safely dispose of hundreds of thousands of metric tons of
hazardous wastes which are generated annually in the United States.
Inadequate land-based disposal methods have endangered countless
lives and the problem has reached crisis proportions in many areas
of the United States ±A'-. The EPA has issued regulations to impose
stringent requirements on waste generators for the disposal of their
hazardous chemical wastes. Once the rules become effective, however,
American waste generators who wish to dispose of wastes at sea will
have to rely on the availability of foreign flag incinerator ships in
order to meet their obligations under the new regulations. In
addition, foreign flag ships will be unlikely to place a high priority
on providing emergency disposal services for the federal or state
governments. The ship operators will owe their primary allegiance to
the flag they fly as well as to their customers who nay not be in the
United States, especially if the ship regularly serves clients in
other countries.
21/ Foreian flag vessels currently capable of incinerating v;aste
include the :i/T VULCANUS, the K/B VESTA, and the MATTHIAS. II.
The VULCANUS was chartered by Shell Chemical Company, Deer Park,
Texas to incinerate toxic organochlorine wastes in 1974-1975 and
1977, 'and the U.S. Air Force chartered the vessel to incinerate
Herbicide Orange in 1977.
22/ American companies interested in constructing and ,operating
incinerator ships include General American Transportation, Inc.,
At Sea Incineration, Inc., and Global Marine Development, Inc.
23/ Some of the more recent environmental tragedies involving improper
disposal of hazardous wastes occurred at the Love Canal in Niagra
Falls, New York, at the Valley of the Drums in Kentucky, and at
Elizabeth, New Jersey where explosions and fire ripped through
the Chemical Control Corporation dumpsite on April 21, 1980.
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In order to alleviate this problem, MarAd could adopt one of several
alternatives for promoting the domestic incinerator ship industry.
These mothods include: (1) determining that incinerator vessels
operate in the foreign commerce and are therefore eligible for ODS,
CDS and CCF, (2) determining that incinerator vessels operate in the
noncontiguous domestic trade and are therefore eligible for CCF,
(3) introducing new legislation which authorizes MarAd to provide
subsidy assistance to owners of incinerator vessels and appropriates
funds to the CDS and ODS Programs for this use, and (4) requesting
Presidential approval, pursuant to Title VII of the Act, for MarAd to
construct incinerator vessels for sale or charter to private
individuals in the interest of national security and public health.
In addition, i-larAd could explore the possibility of constructing a
government-owned vessel, as discussed in section B of this chapter.
3. funding Mechanisms for a Privately-owned Vessel
a. MarAd FY 1982 Budget
In the current budget request for Fiscal Year 1982 fLi/ there
is a provision for prospective construction of two incinerator
ships at v50 million each. If these vessels are built with
CDS, the cost to MarAd would be $50 million, given a 50 percent
ceiling on CDS payments. At present, funds are not requested
for the Program but a supplemental request for funding could
be r.ade at a later tine if the use of CDS for incinerator ships
were authorized. The actual cost of an incinerator ship depends
on the type, size, sophistication, and delivery date of the
vessel and could range from $20-80 million.
b. Authorization and Appropriations Acts
Pursuant to section 20 9 of the Act 1.5/ an authorization act is
required before appropriations can be made for acquisition,
construction, or reconstruction of vessels, for the CDS and
ODS programs, and for reserve fleet expenses, among other
items. Since an authorization bill is necessary before funds
can be allocated for the Incinerator Ship Project, language can
be included in the authorization bill to overcome present
obstacles by defining the operation of an incinerator ship to
be in an essential service in the foreign commerce of the United
24/ Fiscal Year 1982 Maritime Administration Budget Request to
the Secretary of Commerce, (June 2, 1980) at MA-9.
25/ 46 J.S.C. 1119.
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States, as defined in section 905ta) of the 1936 Act. A similar
approach was used in the Deep Seabed Hard Mineral Resources Act,
passed by Congress on June 28, 1980, to ensure that vessels used
in the recovery, processing, and transportation of hard mineral
resources from the sea would be eligible for MarAd financial
assistance. Section 102(c)(4) of the Act reads: "For purposes
of the shipping laws of the United States, any vessel documented
under the laws of the United States and used in the commercial
recovery, processing, or transportation from any mining site of
hard mineral resources recovered under a permit issued under this
title shall be deemed to be used in, and used in an essential
service in, the foreign commerce or foreign trade of the United
States, as defined in section 905(a) of the Merchant Marine Act,
1936, and shall be deemed to be a vessel as defined in section
1101(b) of that Act." 26/
B. GOVERNMENT-OWNED VESSEL
In lieu of offering public assistance to private operators for
construction of incinerator ships, the Maritime Administration or
the Environmental Protection Agency may decide that a vessel should
be constructed for the government's account for use in disposing of
toxic chemical wastes and to provide emergency incinerator service
in times of national crisis. There are many ways in which funding
for a government-owned incinerator ship could be obtained. Perhaps
the easiest way would be for the Environmental Protection Agency
to request funding for the vessel as part of its anti-pollution
efforts to clean up land-based toxic chemical waste dumpsites and to
destroy chemical wastes under government jurisdiction. Money.for
design and construction of the vessel could then be transferred,
by an inter-agency agreement, to MarAd pursuant to the Economy Act
of 19 32 or other statutory provisions.
In addition, the Maritime Administration has the authority to construct
vessels for government account under the provisions of Title VII.
Thirty-five Mariner vessels were constructed for the government in
the early 1950's under an appropriation act which incorporated the
construction terms of Title VII. ' After being successfully demonstrated
in actual operation, these vessels were sold to private operators,
thereby recovering U.S. funds.
1. Environmental Protection Agency (EPA) Vessel
The EPA can request funding for construction and operation of an
incinerator vessel for its own account under the authority of the
Resource Conservation and Recovery Act (RCRA) 27/.
26/ P.L. 96-283 (June 28, 1980), 30 U.S.C; 1401, 1412? 94 Stat.
553, 559.
27/ 42 U.S.C. 6901.
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Section 8001 (a) 13/ of RCRA authorizes EPA to cooperate with, and
render financial assistance to, other federal agencies engaged in
research on methods of hazardous waste management. Section 8004 29/
authorizes the EPA administrator to provide financial assistance in
the form of grants to construct and to operate a full scale
demonstration facility, such as the prototype incinerator vessel.
In addition, EPA officials may wish to request funding for the
construction of the incinerator ship under the authority given to
them by the Marine Protection, Research and Sanctuaries Act of
1972 22/ (the 'Ocean Dumping Law') to regulate ocean dumping, or
propose special legislation to obtain appropriations specifically
for the incinerator ship project.
Once the EPA has obtained the necessary appropriations, EPA can
arrange with the Maritime Administration for the construction and
operation of the ship. Funds can be transferred to MarAd by an
interagency agreement under the authority of the special appropriations
act, provisions in RCRA 21/, the Ocean Dumping Law 22J, or the
Economy Act of 1932 22/•
After the vessel is constructed, the Maritime Administration
can bareboat charter the vessel to private owners for the EPA's
account under the provisions of Section 715 of the Merchant Marine Act,
1936, as amended. Up to ten vessels can be operated and tested in any
one year for the purpose of practical development, trial and testing
28/ 42 U.S.C. 6981.
29/ 42 U.S.C. 6984.
30/ 33 U.S.C. 1401 et seq.
31/ Under RCRA, the EPA Administrator is authorized to "utilize
the information, facilities, personnel and other resources of
federal agencies. . . on a reimbursable basis, to perform
research and analyses and conduct studies and investigations
related to resource recovery and conservation and to other-
wise carry out the Administrator's functions under this Act."
Section 2002(a)(5), 42 U.S.C, 6912 (emphasis added). Likewise,
MarAd is required to make its resources available to EPA, on
a reimbursable basis, to carry out the functions of RCRA.
Section 6003, 42 U.S.C. 6963.
32/ Title II of the Ocean Dumping Law directs each agency of the
federal government to cooperate with the Secretary of Commerce
in a comprehensive and continuing program of monitoring and
research on ocean dumping.
33/ 31 U.S.C. 686.
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which could include research on the economic viability of operating
an incinerator ship as well as research on the seaworthiness of such
a vessel.
2. Maritime Administration Vessel
The Maritime Administration may construct vessels for government
account or have old vessels remodeled under the provisions of
Title VII, when the national policy 24/ and objectives 3jL/ of
34/ The national policy of the Merchant Marine Act, 1936, as
amended, is declared in Section 101 of the Act (46 U.S.C.
1101).
"Section 101. It is necessary for the national defense
and development of its foreign and domestic commerce
that the United States shall have a merchant marine (a)
sufficient to carry its domestic water-borne commerce
and a substantial portion of the water-borne export and
import foreign commerce of the United States and to
provide shipping service essential for maintaining the
flow of such domestic and foreign water-borne commerce
at all times, (b) capable of serving as a naval and
military auxiliary in time of war or national emergency,
(c) owned and operated under the United States flag
by citizens of the United States insofar as may be
practicable, (d) composed of the best-equipped, safest,
and most suitable types of vessels, constructed in the
United States and manned with a trained and efficient
citizen personnel# and (e) supplemented by efficient
facilities for shipbuilding and ship repair. It is
hereby declared to be the policy of the United States
to foster the development and encourage the maintenance
of such a merchant marine."
35/ The objectives of the Act are stated in Section 210 (46
U.S.C. 1120) as follows:
"First,the creation of an adequate and well-balanced
merchant fleet# including vessels of all types, to provide
shipping service essential for maintaining the flow of
the foreign commerce of the United States, the vessels
in such fleet to be so designed as to be readily and
quickly convertible into, transport and supply vessels
in a time of national emergency. In planning the develop-
ment of such a fleet the Secretary of Commerce is directed
to cooperate closely with the Navy Department as to national-
defense needs and the possible speedy adaptation of the
merchant fleet to national-defense requirements."
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the Merchant Marine Act, 19 36, as amended, cannot be fully
realized within a reasonable time under the provisions of Titles V
(Construction-Differential Subsidy) and VI (Operating-Differential
Subsidy), and the President of the United States approves of such
construction.
Contracts with a private shipbuilder for the construction or
reconstruction of a government vessel will be made only after
advertisement and upon sealed competitive bids, and such contracts
will be subject to all requirements of Title V 22/ . If satisfactory
contracts cannot be obtained from private shipbuilders, MarAd may
have the vessels constructed or remodeled in U.S. Navy yards 22/.
After construction, the vessels shall be chartered or sold as soon as
practicable to private operators. MarAd can operate the vessel
for its own account for a limited amount of time for research and
testing under the provisions of Section 715.
Title VII was invoked in 1949-51 to authorize the construction of
a prototype cargo vessel which could be adapted to mass production
with a minimum of changes 2JL' . In addition, Congress enacted
special legislation to authorize construction of 35 Mariner-type
"Second, the ownership and the operation of such a merchant
fleet by citizens of the United States insofar as may
be practicable.
Third, the planning of vessels designed to afford the
best and most complete protection for passengers and
crew against fire and all marine perils.
Fourth, the creation and maintenance of efficient ship-
yards and repair capacity in the United States with
adequate numbers of skilled personnel to provide an
adequate mobilization base."
36/ Section 703, 46 U.S.C. 1193.
37/ Section 7.02, 46 U.S.C. 1192.
38/ Built by Ingalls Shipbuilding, Corp., the vessel was an
experimental type, C3-S-DX1, designed to be built by mass-
production methods in case of emergency, but also to be an
efficient and economical cargo carrier for peacetime service.
United States Maritime Commission Report to Congress for the
Fiscal Year Ended 1949, at 4; See Annual Report of the Federal
Maritime Board and Maritime Administration, U.S. Department
of Commerce, 1950 at 9.
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vessels under the terms of Title VII to meet the defense needs of
the nation during the Korean Conflict 22/. Both projects were
intended to fulfill MarAd*s goal in creating an adequate and
well-balanced merchant fleet which could maintain the flow of
foreign commerce in peacetime and be readily and quickly converted
to transport and supply vessels in a time of national emergency M/
As noted in the section on Foreign Commerce, the nation has an
urgent need for U.S. flag incinerator vessels which has not been
met by private operators. MarAd can attempt to promote the
private development of incinerator ships by making the various
maritime aid programs available to ship operators, as discussed
in part A of this chapter, or can propose that the President's
approval be requested pursuant to Title VII to construct a
prototype incinerator vessel which can handle commercially-
generated toxic wastes in times of peace and be quickly
Department of Defense in times of war or
Additional funds will need to be appropriated by Congress to enable
MarAd to undertake the Program, regardless of whether Congress
chooses to promote the U.S. flag incinerator trade by making
promotional programs (CDS, ODS) available to private operators or
by authorizing government construction of a vessel.
If Congressional policy considerations dictate that emphasis be
placed on the promotional programs, MarAd officials could propose
that any authorization and appropriation bill which includes amounts
for the CDS and ODS Programs with respect to an Incinerator Ship
Program contain a proviso that if viable applications are not
received from private operators within 6 months to 1 year, the money
may be used by MarAd to construct a vessel under Title VII, if
Presidential approval is obtained.
39/ Annual Report of the Federal Maritime Board, Maritime
Administration, U.S. Department of Commerce, 1951 at 5. Funding
for the Mariner project was provided by P.L. No. 911, 81st
Congress, 2nd Session.
40/ Section 210, 46 U.S.C. 1120.
41/ In 1977, the U.S. Air Force chartered the foreign flag M/T
VULCANUS to incinerate Herbicide Orange in the Pacific
Ocean. There were no U.S. flag incinerator vessels available
to handle the task.
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C. HYBRID (GOVERNMENT/PRIVATE) VESSEL
If a government vessel is built, under the provisions of Title VII,
MarAd has the authority, under section 715 of the Act, to operate
the vessel under a general agency agreement or bareboat charter
for the purposes of practical development, trial and testing. As
noted above, the testing can include research on the economic
viability of operating an incinerator ship as well as research on
the mechanics of operating such a ship. These charters and general
agency agreements must be reviewed annually for the purpose of
determining whether conditions exist to justify continuance of the
charter or agreement.
Once the period of trial and testing is completed, however, MarAd
has the obligation to arrange, as soon as practicable, to offer
the vessel for sale, or charter to private operators Preference
in the sale of vessels will be given to U.S. citizens zzj and charter
is by sealed competitive bids Iz/, unless the vessel was constructed
specifically to develop a certain essential trade route in which
case MarAd may charter the vessel under Section 714 to the present
U.S. flag operator on the trade route, without advertisement or
competition 45/. However, as an incinerator vessel will in all
likelihood be treated like a bulk cargo-carrying vessel rather than
a liner vessel, the vessel will not be destined for operation on
a specific trade route and, therefore, Section 714 will not apply.
If the vessel is chartered, the federal government will have title
to the vessel but the private bareboat charterer will control the
vessel's daily operations.
42/ Section 704 and 705.
43/ Section 7, Merchant Marine Act, 1920? 46 U.S.C. 866.
44/ Section 706, Merchant Marine Act, 1936, as amended, 46 U.S.C. 1196.
45/ Section 714, 46 U.S.C. 1204.
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CHAPTER III
SAFETY AND CONTROL MEASURES (9,10)
Chemical waste incinerator ships designed and built in the United
States and flying the U.S. flag are subject to the extensive safety
and pollution prevention requirements administered by the U.S. Coast
Guard (USCG), the American Bureau of Shipping (ABS), the Environmental
Protection Agency (EPA), and the Intergovernmental Maritime Con-
sultative Organization (IMCO). These standards and regulations have
been established under the authority of national legislation and
international, conventions. In addition, the Maritime Administration
(MarAd) has its own requirements for the safe operation and pollution
control of ships built in the United States with federal assistance.
The most important of these design, construction, and operating
requirements for U.S. flag incinerator ships are those, of the Coast
Guard, which apply to the bulk chemical tank vessel, and those of
EPA, which apply to the incinerator system. The regulations of
both agencies reflect the international standards established under
the auspices of IMCO. This chapter provides a brief overview of
the authoritative and regulatory controls applicable to chemical
waste incinerator ships. For more information in this regard, refer
to references 9 and 10.
A. INTERNATIONAL CONVENTION ON THE PREVENTION OF MARINE
POLLUTION BY DUMPING OF WASTE AND OTHER MATTER
The Convention on the Prevention of Marine Pollution by Dumping of
Wastes and Other Matter (1972 London Dumping Convention) was negotiated
in London in November 1972, and came into force on August 30, 1975.
Under the provisions of the Convention, nations agree to regulate
all ocean dumping through national administrative authorities.
Dumping is not allowed without a permit. The disposal of wastes
or other matter directly arising from or related to the exploration,
exploitation, and associated offshore processing of seabed mineral
resources is not covered by the provisions of the Convention.
The Convention requires each contracting nation to regulate the
dumping of all material loaded in its ports for the purpose of being
dumped at sea or loaded on a vessel or aircraft of its flag or registry
in the territory, .pf. _a nation,-not- aparty-.tofchftCon vent ion. Participating
nations are further required to maintain records concerning the nature
and quantities of material which they permit to be dumped and the
circumstances of such dumping. They must report this information
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periodically to IMCO, the organization responsible for administration
of the Convention. Contracting parties are also to promote the disposal
and treatment of wastes and other measures to prevent or mitigate
Dollution by dumping.
Incineration at sea of wastes is regulated at the international
level under the 1972 London Dumping Convention. The Convention has
been amended to include mandatory regulations and recommendatory
technical guidelines on the control of incineration of wastes and
other matter at sea.
B. INTERNATIONAL AGREEMENTS PERTAINING TO MARITIME SAFETY AND TO
PROTECTION OF THE MARINE ENVIRONMENT
In addition to the foregoing international agreement, the following
international conventions and codes dealing with maritime safety
and with protection of the marine environment* primarily' from vessel
source pollution, apply to chemical waste incinerator ships:
1. The International Convention for the Prevention of
Pollution from Ships, 197 3 (MARPOL).
2. Protocol of 1978 Relating to the International Convention
for the Prevention of Pollution from Ships, 1973 (MARPOL
Protocol) .
3. International Convention Relating to Intervention on
the High Seas in Cases of Oil Pollution Casualties, 1969.
4. Protocol Relating to Intervention on the High Seas in
Cases of Marine Pollution by Substances Other Than Oil, 1973.
5. International Convention on Safety of Life at Sea,
1974 (SOLAS).
6. Protocol of 1978 Relating to the International Convention
on Safety of Life at Sea, 1974 (SOLAS Protocol),
7. IMCO International Maritime Dangerous Goods Code, as
amended.
8. IMCO Code for the Construction and Equipment of Ships
Carrying Dangerous Chemicals in Bulk, as amended.
9. International Convention on Standards of Training,
Certification, and Watchkeeping for Seafarers, 1978.
All of the above conventions and codes are administered by IMCO.
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c. MARINE PROTECTION, RESEARCH, AND SANCTUARIES ACT OF 1972
(P.L. 92-532) (MPRS%r
This Act, enacted on October 23, 1972, provides for the regulation
of ocean dumping, research on ocean dumping and other man-induced
changes to the ocean ecosystems, and the designation, acquisition,
and administration of marine sanctuaries. Titles I and II address
ocean dumping.
Title I of the MPRSA provides for a regulatory scheme to control
all materials transported from the United States for the purpose of
dumping into ocean waters. In addition, the Act controls the dumping
of material originating outside of the United States, if that dumping
takes place in ocean waters subject to the jurisdiction or control
of the united States. Finally, consistent with the declared policy,
the Act also regulates the activities of federal departments and
agencies transporting material for dumping into ocean waters,
regardless of the location from which the transportation is initiated.
Title I requires that no person, regardless of his nationality, may
depart a United States port with material intended for dumping anywhere
in the world's oceans, unless he has first obtained a federal permit.
The MPRSA also has a total prohibition against the dumping- of
radiological, biological, and chemical warfare agents, or any high-
level radioactive wastes. These hazardous substances may not be
dumped or transported for dumping, and no permit can be issued for
their disposal.
Title II Section 201 of the Act directs the Secretary of Commerce to
work with the Coast Guard and to initiate a Comprehensive and
continuing program of monitoring and research regarding the effects
of ocean dumping, and, in consultation with other agencies, to
initiate a comprehensive and continuing research program with respect
to possible long range effects of pollution, overfishing, and man-
induced changes of ocean ecosystems. A major purpose of these
research and monitoring activities is clearly intended to provide
scientific findings, evaluations, and conclusions that are relevant
to defining use conflicts that could influence the decisions to
grant or deny dumping permits. In requiring annual reports to
Congress, the Act provides a convenient and timely mechanism for
documenting these efforts.
Title II Section 203 requires the Secretary of Commerce to conduct
and encourage research, investigations, experiments, training,
demonstrations, surveys, and studies for the purpose of determining
means of minimizing or ending all dumping of materials within five
years of the effective date of the Act. (The MarAd Chemical Waste
Incinerator Ship Project (Appendix A) is in response to this
Title II requirement).
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The EPA has permit granting authority with respect all ocean dumping
except dredged material; this permit authority includes incineration
at sea. The dumping of dredged material requires a permit from
the U.S. Army Corps of Engineers. The EPA Ocean Dumping Regulations,
40 CPR Parts 220-230, describe the procedures relating to the
application for, issuance of, and denial of permits for ocean
dumping. Criteria for evaluation of permit applications are also
included. The categories of permits issued are: general, special,
emergency, interim, research, and incineration at sea. EPA regulates
incineration at sea in a manner consistent with the intent of the
Ocean Dumping Convention and the MPRSA.
D. NATIONAL ENVIRONMENTAL POLICY ACT OF 1969 (P.L. 91-190) (NEPA)
The purposes of this Act are: to declare a national policy which
will encourage productive and enjoyable harmony between man and
his environment; to promote efforts which will prevent or eliminate
damage to the environment and biosphere, and stimulate the health
and welfare of man; to enrich the understanding of the ecological
systems and natural resources important to the nation; and to
establish a Council on Environmental Quality (CEQ).
Section 102(2)(C) of NEPA and the amended CEQ Guidelines, as published
in the Federal Register of November 29, 1978, require all federal .
agencies to include, in every recommendation or report on proposals
for legislation and other federal actions significantly affecting
the quality of the human environment, a detailed statement on the
environmental impact of the proposed action. Underlying the
preparation of such environmental impact statements is the mandate
of both NEPA and Executive Order 11514 of March 5, 1970, that all
federal agencies, to the fullest extent possible, direct their
policies plans and programs to protect and enhance environmental
quality.
EPA conducts environmental impact assessments for all disposal sites
and publishes environmental impact statements (EIS's) prior to
designating a site for incineration at sea. This constitutes
compliance with the EPA regulations on ocean dumping. The EPA
published a Final EIS for an incineration site in the Gulf of Mexico (4)
and is currently preparing an EIS for the Atlantic site, commonly
known as the **106 industrial waste site."
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E. RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 (P.L. 94-580)(RCRA)
The purpose of RCRA is to provide technical and financial assistance
for the development of management plans and facilities for the
recovery of energy and other resources from discarded materials,
for safe disposal of discarded materials, and to regulate the
management of hazardous waste. The Act requires the Administrator
of EPA to promulgate regulations establishing performance standards
for the treatment, storage, and disposal of hazardous waste.
EPA published in the Federal Register of May 19, 1980, the final
rules concerning the hazardous waste management system (40 CFR
Parts 260-265). The regulations address: general information
concerning the hazardous waste management system, identification
and listing of hazardous waste, standards applicable to generators
of hazardous waste, standards applicable to transporters of hazardous
waste, and standards and interim status standards for owners and
operators of hazardous waste treatment, storage, and disposal
facilities.
Although the provisions of this Act are applicable to incineration
at sea, this method of hazardous waste disposal is adequately
regulated under the Marine Protection, Research, and Sanctuaries
Act of 1972 (MPRSA) and, because of the interrelationship between
the MPRSA and the Ocean Dumping Convention, regulations developed
under RCRA are not being used to control incineration at sea.
However, RCRA does regulate land-based transport and storage of
hazardous wastes permitted to be incinerated at sea, as well as
the land-based alternatives to incineration at sea, and promotes
resource recovery.
F. PORTS AND WATERWAYS SAFETY ACT OF 1972 (P.L. 92-340) (PWSA)
The PWSA is intended to promote the safety of ports, harbors,
waterfront areas, and navigable waters of the United States. It
consists of two sections.
Title I of the PWSA gives the Secretary of the Department in which
the Coast Guard operates the authority to take means to prevent
damage to, or the destruction or loss of, any vessel, bridge, or
other structure on or in the navigable waters of the United States,
or any land structure or shore area immediately adjacent to those
waters; and to protect the navigable waters and the resources
therein from environmental harm resulting from vessel or structural
damage, destruction, or loss.
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Title II provides for the establishment of comprehensive minimum
standards of vessel design, construction, alteration, repair, maintenance
and operation to prevent or mitigate the hazards to life, property,
and the marine environment. These standards apply to all vessels
documented under the laws of the United States or entering the
navigable waters of the United States.
The PWSA was amended during 1978 by the Port and Tanker Safety Act of
1978 (P.L. 95-474). This new law provides a stringent and comprehensive
program dealing with the design, construction, operation, equipping,
and manning of all tank vessels using U.S. ports to transfer oil
and hazardous materials. The design, construction, and equipment
requirements contained in this law are, for the most part, in
agreement with the results of the 1978 International Conference
on Tanker Safety and Pollution Prevention. This Conference
resulted in the adoption of Protocols for two of IMCO's most
important Conventions, 1973 MARPOL and 1974 SOLAS.
Incineration vessels must comply with the design, construction,
and operation requirements issued by the U.S. Coast Guard under the
PWSA, as amended. Of particular importance are the Coast Guard
rules for chemical carriers (46 CFR Part 153) which implement the
IMCO Bulk Chemical Code. (21) These Coast Guard requirements,
as well as the IMCO Bulk Chemical Code, are based upon the philosophy
of relating cargo containment features of vessel design, construction,
and operation to the hazards of various chemicals. The key provisions
of these requirements as they relate to dangerous cargoes specify
three different levels of vessel construction, containment system,
and containment system location within the vessel:
Type I - a containment system to transport products which
require maximum preventive measures to preclude their release;
Type II - a containment system to transport products which
require significant preventive measures to preclude their
release;
Type III - a containment system to transport products which
require moderate preventive measures to preclude their release.
These three containment systems specify the location of the cargo
tanks and piping within the ship and place minimum requirements for
damaged and intact vessel stability. These assignments to containment
system types take into account the nature and severity of the
product's hazards if released.
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The highest standard of cargo containment, Type I, is placed on
those cargoes that on release could have the most wide-reaching
effect beyond the immediate neighborhood of the vessel. No portion
of the Type I cargo containment system may be located closer than
one-fifth the vessel beam from the side of the vessel or a distance
equal to one-fifteenth the vessel beam above the vessel keel.
The vessel with a Type I containment system must be designed to
withstand prescribed damages (two-compartment standard of subdivision
and damage stability throughout its length). In addition, to
prevent the large-scale release of Type I cargo in event of rupture
of the containment system, the size of each tank is limited to
1,250 cubic meters.
Cargoes with significant hazards, but whose release would not have
far reaching effects, are carried in Type II containment systems.
A Type II containment system must be located a minimum distance of
760 mm from the vessel side and one-fifteenth the vessel beam above
the vessel's keel. These requirements should provide cargo protection
against groundings and low-energy collisions. In addition, each
vessel greater than 150 meters long must have a two-compartment
standard of subdivision and damage stability throughout its length.
Vessels less than 150 meters must meet a two-compartment standard
of subdivision and damage stability in the cargo containment portion
of each vessel and a one-compartment standard for the engine room.
To prevent the large-scale release of a Type II cargo, the individual
tank size is limited to 3,000 cubic meters.
A Type III containment system is prescribed for products with lesser
hazards. No separation of the cargo containment system from the
ship's hull is required. However, increased damage stability, in
excess of that required for a typical tanker, is required. Vessels
greater than 125 meters with a Type III containment system must be
able to survive damage to any location except either bulkhead of an
aft machinery space.
G. FEDERAL WATER POLLUTION CONTROL ACT AMENDMENTS OF
1§11 (P.L. $2-506) (FWPCA)
In Section 311 of this Act, Congress declared that it is the policy
of the United States that there should be no discharge of oil or
hazardous substances into, or upon, the navigable waters of the
United States, adjoining shoreline* or upon, or into, the waters of
the contiguous zone*
Some essential features of the Act relating to spills include a
revolving fund for cleanup operations, a national contingency plan
for control of spills of oil and hazardous polluting substances,
and authority to remove polluting spills of oil and hazardous
substances. In addition, the President shall issue regulations
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consistent with maritime safety and with the marine and navigation
laws: (a) establishing methods and procedures for removal of dis-
charged oil and• hazardous substances and (b) establishing procedures,
methods and requirements for equipment to prevent discharges of
oil and hazardous substances from vessels and from onshore facilities
and offshore facilities.
The Clean Water Act of 1977 (CWA) (P.L. 95-217) further amended the
FWPCA with respect to liability for oil and hazardous substance
spills. Most notably, the CWA extends U.S. national jurisdiction
for water pollution control to the ocean beyond the contiguous zone
where fisheries and other natural resources of the U.S. may be
adversely affected.
EPA rules to implement the FWPCA, as amended, are contained in
Title 40 of the Code of Federal Regulations. Of particular importance
with respect to incinerator ships are: 40 CFR Part 110 - Discharge
of oil, 40 CFR Part 112 - Oil pollution prevention, 40 CFR Part 116 -
Designation of hazardous substances, and 40 CFR Part 117 - Determination
of reportable quantities of hazardous substances.
H. INTERVENTION ON THE HIGH SEAS ACT, AS AMENDED (P.L. 93-248)
The purpose of this Act is to implement the International Convention
Relating to Intervention on the High Seas in Cases of Oil Pollution
Casualties and Marine Pollution by Substances Other than Oil.
The Act authorizes the Department of Transportation (U.S. Coast
Guard) to prevent, mitigate, or eliminate pollution or threat of
pollution on the sea by oil and other substances which results from
a ship collision, stranding or other incident of navigation.
In the event that an incineration vessel, while transporting hazardous
wastes, became involved in a marine disaster, the U.S. may take
appropriate measures to eliminate an imminent danger to U.S. coast-
lines or related interests of the United States.
I. COAST GUARD REGULATIONS
As noted previously, the Ports and Waterways Safety Act of 1972 and its
amended version, the Port and Tanker Safety Act of 1978, give the
Coast Guard, U.S. Department of Transportation, the authority to
regulate vessels and facilities handling hazardous materials. The
Coast Guard also has responsiblities under the Federal Water Pollution
Control Act, as amended. Coast Guard regulations are contained in
the Code of Federal Regulations: Title 33 - Navigation and Navigable
Waters and Title 46 - Shipping. Related regulations of the Materials
Transportation Bureau, U.S. Department of Transportation, are contained
in Title 49 - Transportation. Regulations which are particularly
applicable to the safety and pollution control characteristics of
chemical waste incinerator ships are:
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1. Title 33, Chapter I
a. Subchapter K - Security of Vessels
e.g. Part 124 - Control over movement of vessels
b. Subchapter L - Waterfront Facilities, Security
Zones, and Regulated Navigation Areas
e.g. Part 126 - Handling of explosives and other
dangerous cargoes
c. Subchapter 0 - Pollution
e.g. Part 151 - Oil pollution regulations
Part 153 - Control of pollution by oil and
hazardous substances, discharge
removal
Part 154 - Large oil transfer facilities
Part 155 - Vessel design and operations
Part 156 - Oil transfer operations
Part 157 - Rules for protection of the marine
environment relating to tank vessels
carrying oil in bulk
Part 159 - Marine sanitation devices
d. Subchapter P - Ports and Waterways Safety
e.g. Part 161 - Vessel traffic management
Part 162 - Inland waterways navigation regulations
Part 164 - Navigation safety regulations
2. Title 46, Chapter I
a. Subchapter D - Tank Vessels
b. Subchapter E - Load Lines
c. Subchapter F - Marine Engineering
d. Subchapter I - Cargo and Miscellaneous Vessels
e. Subchapter J - Electrical Engineering
f. Subchapter 0 - Certain Bulk Dangerous Cargoes
e.g. Part 153 - Safety rules for self-propelled
vessels carrying hazardous liquids.
3. Title 49, Chapter I
a, Subchapter C - Hazardous Materials Regulations
e.g. Part - Carriage by vessel
Coast Guard regulations pertaining to vessels carrying hazardous
liquids in bulk are contained in 46 CFR Past 153. The regulations
list the substances which are covered. New substancesproposed for
shipment are evaluated by the Coast Guard on the basis of their hazards,
and the minimum carriage requirements are developed before they are
permitted to be shipped. Currently, products proposed for shipment
on incinerator ships also undergo this same evaluation before they
are permitted to be carried.
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In the interest of maintaining uniform international standards,
requirements for vessels carrying hazardous liquids in bulk are
developed by the Intergovernmental Maritime Consultative
Organization (IMCO). The IMCO Subcommittee on Bulk Chemicals (BCH)
developed the IMCO Bulk Chemical Code which is the basis for
requirements in 46 CFR 153. The Subcommittee is currently
developing special requirements for ships engaged in incineration
at sea. Vessels built before final requirements are finalized
should be built to comply with interim guidelines which have already
been developed and approved by IMCO. The interim guidelines must
be used in conjunction with the Bulk Chemical Code.
The Ports and Waterways Safety Act also gives the Coast Guard
authority to develop requirements for facilities transferring hazardous
materials. Regulations are currently under development and will
generally apply to facilities where substances to be incinerated
are transferred to vessels. The Coast Guard Captain of the Port
has the overall responsibility of ensuring that hazardous materials
are transferred, loaded, and transported through the port in a safe
and environmentally acceptable manner.
J. MARITIME ADMINISTRATION STANDARDS
MarAd has developed standard specifications to provide guidance for
merchant ship designers preparing detailed ship specifications.
Significant improvements in ship design, construction, and equipment
for the purposes of safety and pollution prevention have been
integrated into ships built with MarAd financial assistance. In
this regard, MarAd1s Standard Specifications for Merchant Ship
Construction include sections for: (a) invoking compliance with
regulatory body requirements? (b) contributing to the overall
physical safety potential of the vessel; (c) enhancing the safe
navigation and operation of the vessel; and (d) mitigating marine
pollution. All MarAd supported ships must comply with all applicable
portions of Coast Guard regulations and those of other regulatory
agencies named in each individual ship specification and in the
MarAd standard specifications.
K* SAFETY AND CONTROL MEASURES SUMMARY (10)
U.S. flag chemical waste incinerator ships are subject to the stringent
requirements of the Coast Guard, the Environmental Protection Agency,
the Maritime Administration, and the Intergovernmental Maritime
Consultative Organization. Each U.S. flag incinerator ship would
have the following fundamental characteristics: (a) highly automated,
safe, and reliable; (b) operated by a highly trained crew; (c) an
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efficient user of all energy generated; and (d) designed and equipped
with all vital safeguards and controls, such as accurate incinerator
monitoring equipment, double bottom and double sides, and advanced
navigation and communication aids. The Coast Guard and MarAd
have primary control over the design, construction, and equipment
of each ship; the Environmental Protection Agency has jurisdiction
over the incinerator system design and operation and related matters.
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CHAPTER IV
INCINERATOR SHIP CONCEPTUAL DESIGN
U.S. flag incineration ships can serve two broad functions: first,
they can be used for the destruction of hazardous wastes in EPA-
designated burn sites which minimizes the risk to public health and
the environment; second, they can provide safe platforms to conduct
EPA research and development efforts in hazardous waste incineration.
This chapter discusses the fundamental characteristics of chemical waste
incinerator ships. Detailed presentations concerning shipboard
incineration systems and incinerator ship conceptual designs,
including estimated costs, are contained in Appendices B and C.
A. INCINERATION SYSTEM/SHIP INTEGRATION (Appendix B)
The ship layouts in FIGURE 1 indicate some of the ways that incineration
systems can be integrated on board ships to provide desired
incineration capacity and operational time at sea. Ships of two
different capacities are depicted with liquid injection incinerators
installed aft. These incinerators are intended for high rate
destruction of hazardous wastes at sea. A rotary kiln incinerator
is also installed on the larger ship for research purposes. Rotary
kilns are the most universal incinerators available, capable of
destroying liquids, slurries, tars, and solids, separately or
combined, Athough widely used on land, rotary kilns have not
been used on ships, and would require modifications for shipboard
operation. The rotary kiln in conjunction with a liquid injection
incinerator is the most versatile combination for thermal destruction
of a wide variety of hazardous wastes.
FIGURE 1. Incineration System/Ship Integration
LIQUID INCINERATORS (2)
LIQUID
INCINERATORS (3)
8000 MT | DECK
WASTE STORAGE | HOUSE
1
130 M '
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The smaller ship shown in FIGURE 1 - 100 meters long with 4,000
metric tons waste capacity - is approximately the capacity of the
VULCANUS, which has two stern-mounted incinerators. Liquid wastes
are pumped from the tanks to each incinerator burner. At a waste
feed rate of 10 metric tons/hour for each incinerator, this ship
would require slightly over eight days of continuous burning to
dispose of 4,000 metric tons of liquid waste. The bridge and deck-
house are shown immediately forward of the incinerators, as on the
VULCANUS. A location farther forward near the bow would be preferable
for the safety of the crew.
The large ship of FIGURE 1 has 8,000 metric tons of waste capacity
and is 130 meters in length. This ship layout is similar to the
conceptual designs described in Appendix C. Three liquid incinerators
burning 10 metric jbons/hour each would dispose of 7,200 metric tons
of liquid waste in ten days. A rotary kiln of 1.5 metric tors/hour
solid waste capacity is shown connected to one of the liquid incinerators,
which is utilized as an after burner. Solid wastes are stored in
bulk containers, which are transported by conveyer to the kiln.
Automated equipment lifts the bulk containers and discharges the
solid wastes into the kiln through a sealed hopper. Ash from solids
incineration is stored and returned to land for analysis and
disposal. The deckhouse for this ship is located forward of the
waste tanks, near the bow of the ship.
These ship layouts indicate some of the ways that incineration systems
can be integrated on board ships. Optimization studies to determine
the size of incinerator ships, the number of incinerators/ship, and
the incineration time versus loading and transit times can be made.
Economies of scale indicate that larger incinerator ships with
higher burn rates could be more cost-effective than the ships shown
in figure 1.(22) This possible advantage for larger ships is contingent
upon the ready availability of large volumes of waste for
incineration and the ability of the EPA-designated burn sites to
absorb without environmental damage the higher combustion rates.
A dedicated laboratory on each incinerator ship is required to
provide operational safety through detection of waste constituents
in the shipboard environment and for verification of waste combustion
efficiency. Environmental monitoring of at-sea incineration is also
required to assure personnel safety and to protect the environment.
B. ALTERNATIVE DESIGNS FOR CHEMICAL WASTE INCINERATOR SHIPS
(Appendix C) : ——
Among the proven technologies of the maritime industry, alternative
approaches to the transportation and incineration of chemical wastes
include:
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1. A monohull vessel outfitted with incinerators aft
and deckhouse forward. Such designs are discussed
in Appendix c and include new construction and
conversion design options.
2. An integrated tug-barge system, where the cargo carrying
incinerating barge and the propulsion tug are separable.
For this unit, the tug and barge could be built separately
and simultaneously, thereby shortening the construction
period. Also, in an emergency, it would be possible to
uncouple the tug from the barge and set the barge to
drift or under tether. The integrated tug/barge design
reverses the general arrangements of conventional ships,
locating the incinerators at the barge's forward end, with
the propulsion plant, the tug, at the stern. While incinerating
waste, the tug pulls the barge to provide maximum separation
between the exhaust plume and the crew.
3. A barge carrying ship, where fully loaded waste containing
barges are loaded onto the ship. The barges can be loaded
outside the harbor limits as long as sea conditions
permit. The ship, which is the incinerator platform,
would generally remain outside the heavily trafficked
port area while the waste containing barges are delivered
to it by tugs.
4. A tethered tug-barge combination which provides ample
separation between the incineration platform and the
propulsion platform.
C. CONCEPTUAL DESIGNS FOR U.S. FLAG INCINERATOR SHIPS
Appendix C presents conceptual designs for U.S. flag Incinerator
ships. Each ship design has a full-bodied cargo ship hull with
extensive auxiliary processing systems to handle and incinerate
hazardous chemical wastes. The vessel designs must conform with all
applicable Coast Guard regulations, such as 46 CFR Part 153 - Safety
Rules for Self-Propelled vessels Carrying Hazardous Liquids, and
with the IMCO Code for Construction and Equipment of Ships Carrying
Dangerous Chemicals in Bulk. Two new construction designs are
presented, as well as an NDRF conversion, since EPA is interested
in advancing the state of the art of hazardous waste disposal, each
ship design incorporates a demonstration plant for solid waste
handling and incineration at sea as well as a high capacity industrial
plant for transporting, pumping and incinerating liquid wastes at sea.
The designs require that a land-based terminal exists to support the
operation of incinerator ships.
The concept design study of Appendix C presents two new ship
alternatives and discusses alternative technologies for use as an
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incinerator ship. Each ship is outfitted with three liquid injection
incinerators and one experimental solid waste rotary kiln
incinerator, plus the auxiliary equipment and the cargo systems
needed to support the incineration plant. The new vessels should be
able to burn a total of 7200 metric tons of liquid waste and
360 metric tons of containerized solid waste during ten days of
continuous burning.
Both designs must conform to the highest standard of marine chemical
cargo protection and containment. The PD-246A can carry a full load
of the most hazardous chemical cargoes, those rated Type X according
to the IMCO Bulk Chemical Code. Very few chemicals now require
Type I protection, so that the PD-246A is a conservative design. The
other new ship design, the PD-246B, is a combination Type I/Type II
ship, which carries the same amount of waste cargo in a slightly
smaller hull. Most candidate chemicals for incineration at sea are
Type II chemicals that could be adequately protected by this hull
design. The Type I cargoes could be carried only in the ship's
centerline tanks.
In addition to the new ship designs, a conversion alternative,
PD-246C, was evaluated using a Landing Ship Dock (LSD) as the baseline
ship for a Type I hull chemical waste incinerator ship. However,
because the available space for the liquid cargo tanks is flanked by
the existing propulsion plant, the LSD has been determined to be
inappropriate for use as a liquid waste incinerator ship equivalent
to either of the new ships. The LSD may still be useful as a
research platform for solid waste incineration at sea, as the
containerized solid cargo can be safely handled within the cargo
well space. Another conversion may be possible for an equivalent
incinerator ship, but the extensive modifications needed for most
older ships, such as T-2 tankers, would make the converted vessel
an inefficient investment for this mission.
The estimated cost and construction schedule for a single ship of each
new ship design, for delivery in 19S5, including installed incineration
equipment, are as follows:
DESIGN NEW TYPE I NEW TYPE I/II
NAME PD-246A PD-246B
LENGTH 129.5m (425'-0") 121.9m UOO'-O")
BEAM 25.0m <82'-0") 23.8m (78'-0")
DEPTH 13.4m (44'"»0") 12.Sm <41'-a")
COST ($ millions) 80 75
SCHEDULE (raos.) *0 30
Estimated annual operating costs for either vessel are $15 million
based upon information obtained from industry.
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CHAPTER V
ENVIRONMENTAL ASSESSMENT
Incineration at sea has been shown to be a technically and
environmentally acceptable alternative to land-based disposal of
hazardous wastes. (3-12) The principal environmental considerations
incident to the operation of a chemical waste incinerator ship
are: accidental discharge or spillage of hazardous waste cargo
and the effects of the incinerator emissions. In addition, there
are other potential pollutants from the operation of the ship itself,
such as fuel oil, sewage, garbage and domestic wastes, and
stack emissions from the machinery plant. This discussion will
summarize the major environmental factors to be considered when
operating a chemical waste incinerator ship—all of which are
addressed by national and international regulations and'programs.
Refer to references 3-12 for additional information.
A. ACCIDENTAL DISCHARGE OR SPILLAGE (9,10)
A chemical waste incinerator ship is a specialized bulk chemical
carrier designed and operated to safely transport and dispose of
hazardous chemical wastes. Due to the special design and operation
of incinerator ships, tank cleaning and deballasting operations are
not pollutant sources. Potential for environmental pollution does
exist due to accidents—both from faulty transfer operations and
from vessel casualties. Such accidents could occasion moderate or
serious consequences, depending in large measure upon where the
discharge occurred and the quantity and type of wastes released.
For instance, a major spill near shore which affects an estuary
would destroy many organisms, including benthic forms, and would
contaminate the area for a substantial period of time. A large
spill on the continental shelf or beyond could have significant
short-term impacts on local organisms. However, the actions of waves
and currents would greatly disperse the contaminant, and the large
volume of oceanic water would dilute the contaminant. Therefore,
the long-term impacts at the site would be significantly reduced.
There are three primary reasons for polluting accidents during
transfer (loading) operations: mechanical failures, design
deficiencies, and human error. The human error factor increases
as the number of incompatible chemical cargoes increases. Vessel
casualties which could cause chemical waste pollution are grounding,
collision, ramming, fire, explosion, structural failure, and
mechanical breakdown—any one of which, if serious enough, could
result in the vessel capsizing or sinking. Due to the extensive
safety and control measures required in connection with the design
and operation of incineration ships and the related land-based
terminals, the potential for accidental spillage of chemical wastes
would be minimized.
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In order to reduce the potential for polluting discharges of oil
and hazardous substances, the Coast Guard conducts surveillance
flights over ports and coastal waters. Specific coastal surveillance
areas are determined by the pollution potential expected as a
result of vessel density studies and historical spill data. The
Federal Water Pollution Control Act, as amended, requires those
responsible for spills to report them; and non-spilling industries
and the public are encouraged to report spills in order to augment
this mandate.
The Coast Guard promulgates and enforces regulations that protect
the environment from chemical carrier pollution. These regulations
fall into several categories: (a) standards for design, equipment,
construction and operation of vessels; (b) cargo containment and
fire protection requirements; (c) navigating equipment necessary
for safe operation; (d) cargo transfer regulations? and (e) procedures
for notifying the proper authorities if a spill occurs. In addition,
the Coast Guard Captain of the Port (COTP) is responsible for general
port safety and enforcement of pollution prevention regulations.
The COTP staff daily inspects vessels, facilities, and anchorages.
The purpose of these inspections is to safeguard vessels, waterfront
facilities, the harbor, and the port by enforcement of hazardous
material and related safety regulations. The COTP is also responsible
for establishing, coordinating, and, if necessary, implementing
emergency contingency plans in the event of a major casualty or
spill in the port.
B« INCINERATOR EMISSIONS (9)
One of the key considerations for minimizing the environmental impact
of incineration at sea is proper selection by EPA of the site for
treatment and disposal. Of equal importance are the regulation of
incinerator emissions, the control of operating procedures, and the
requirements for equipment and devices to minimize malfunctions of
the incinerator ship system. Such matters are currently addressed
by federal regulations and international agreements.
1. incineration Site Designation
Sites for at-sea incineration are selected to minimize the interference
of waste disposal activities on the marine environment, particularly
avoiding-areas of existing fisheries or shellfisheries, regions of
heavy commercial or recreational navigation ai*<$ areas of mineral
extraction or special scientific importance. Disposal site evaluation
studies are conducted which are based on E?A criteria. The results
of these studies are presented in support of the site designation
in the form of an environmental assessment of the impact of using
the site for disposal. An environmental impact statement is prepared
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for each site designation where such a statement is required by
EPA policy.
2. Incinerator Emission Products
Wastes which are incinerated at sea on an industrial or commercial
basis are principally organic chemicals. Such wastes are usually
liquid, although certain organic solids may be candidates because
they are soluble in liquid waste or in fuel oil. In addition, the
wastes may be "wet" or emulsified in water. The incineration of
solid organic wastes has not been conducted successfully at sea to
date and is planned on a research and development basis by EPA.
This research and development work will be part of EPA's program
to implement new and improved management techniques for hazardous
waste management.
In general, the wastes are organochlorine compounds whose principal
combustion products are CO2, I?2®» an(^ HC1. Other acceptable wastes
are hydrocarbons or oxygenated organic compounds, provided that
they are combustible and do not contain prohibited materials.
Principal combustion products from these non-chlorinated materials
are C02 and H2O.
A basic characteristic of at-sea incineration is that the combustion
products of the waste go directly .from the stack of the incinerator
into the air and the ocean without any further treatment. (Emission
control devices are being considered by EPA for future research and
development work, however.) The stack emissions contain the major
products of combustion - CO^t *^0, and HC1; certain minor constituents
of the waste; whatever unburned waste which remains; and any organic
materials which may have been synthesized during the incineration
process. Trace metals which may have been present in the waste appear
in the effluent gases as particulates. Phosphorus, sulfur, and much
of the combined nitrogen appear as P2O5/ S0X, NOx* Certain other
minor constituents caused by equilibrium conditions in the furnace
and stack, i.e., CO, CI2* and H2, may also be present to the extent
of 10~5 to 10~® mole fractions. In general, organic waste of high
inorganic content, such as heavy metals, are not suitable for at-sea
incineration.
3v Incinerator Efficiencies
Combustion efficiency (CE) and destruction efficiency (DE) are two
parameters often used to describe an incinerator's effectiveness
in disposing of organic wastes. The combustion efficiency for a
certain burn is based on measurements of CO and CO2 concentrations of the
hot gases leaving the combustion chamber and is given by the following
expression:
CE(%) ® (CO2) - (CO) x 100
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Destruction efficiency is basically a measure of the difference
between the amount of waste being fed to the incinerator and the
amount of waste contained in the exiting gas stream. A variety
of sampling, analysis, and calculation procedures can be used
to determine the destruction efficiency of a particular burn. (5,6)
Combustion efficiencies of 99.99 percent and destruction efficiencies
of 99.999 percent have been demonstrated on the M/T VULCANUS.(6)
National and international standards require both the combustion
efficiency and the destruction efficiency to exceed 99.9 percent.
The flame temperature of the liquid injection incinerators is
maintained at all times above 1250°C during the incineration of
organochlorine wastes.
4. Impact on Air Quality
Some largely local impacts on air quality from at-sea incineration
occur in the burn site. Among these are the large output of
hydrogen chloride with far lesser amounts of carbon monoxide,
chlorine, and unburned hydrocarbons. At 99.96 percent destruction
efficiency of the waste, the maximum predicted concentration of
organochlorines would be approximately 2.75 micrograms/cubic meter
of exhaust gas. In the 1977 Gulf burn aboard the M/T VULCANUS,
the maximum air concentration of hydrogen chloride found downwind of
the ship was 10 parts/million. Most frequently, values ranged
from 0-5 parts/million.(5) Sea level concentrations of hydrogen
chloride generally were in the range of 1-2 parts/million several
kilometers downwind during the 1974 burn. (3) These low atmospheric
concentrations of hydrogen chloride posed no hazard to birds or
personnel in the area. The concentrations of carbon monoxide and
chlorine in the atmosphere are negligible.
Within 5-10 miles of the incinerator ship, acid rain from incineration
could equal or exceed that normally produced when rain washes out the
naturally occurring acidic sulfur (SO*) and nitrogen (NOx) as well
as chloride in seawater spray. In this case, the acid rain would
be neutralized immediately by the natural carbonates in the ocean.
Beyond ten miles, any hydrogen chloride remaining in the air would
be so diluted that it would be insignificant compared to naturally
occurring acidic components of the atmosphere. Aerial monitoring of
at-sea incineration in 1974 showed that the maximum concentration of
hydrogen chloride in the,air five miles downwind was on the order
of 0.1 parts/million. This concentration is much lower than the
Threshold Limit Value (TLV) for humans in the workplace of 7 milligrams/
cubic meter. Eight miles downwind the concentration was below detection
limits (0.005 parts/million). This concentration is lower than the
concentration of other acidic components allowed under the most
stringent air standards for either SOx or NOx.
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At any greater distance than ten miles, the effect would be even
less with continued dispersion and neutralization of the hydrogen
chloride which contacts the ocean or reacts with naturally occurring
ammonia in the atmosphere. For these reasons, the acidity of
rainfall on coastal locations would not be increased due to at-sea
incineration in EPA-designated burn sites.
5. Impact on Water Quality
The ability of seawater to assimilate hydrogen chloride without
measurable change is well known. Analysis of seawater samples for
organochlorines during organochlorine burns resulted in values
below the 0.5 parts per billion limit of detection. In addition,
surface water samples collected during burns showed no significant
differences in trace metals between test and control stations
lander normal meteorological conditions.
A "worst case"condition would be the rapid fallout of HC1 caused
by rainfall. If rainfall occurred in the immediate vicinity of the
incinerator vessel, it is estimated for a typical organochlorine
waste (63 percent chlorine) that the maximum fallout of HC1 would
be between 30 and 60 grams/square meter of ocean surface. A depression
of pH would occur but would have only short-term and local effects
since neutralization would occur within the first few meters of the
water column. If the rain occurred directly downwind at a distance
of 5-10 miles from the incinerator vessel, acid rain would be neutralized
immediately by the natural buffering capability of the ocean. At
distances greater than 10 miles, acidity due to input of HC1 from
incineration of organochlorines would be neutralized by ambient
ammonia in the atmosphere.
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CHAPTER VI
WATERFRONT FACILITIES FOR STORAGE,
PROCESSING, AND TRANSFER OF WASTES
An incinerator ship service requires a land-based support network
consisting of waterfront storage tanks, waste processing and handling
equipment, a laboratory for waste analysis, and a cargo transfer
terminal, plus an inland transportation system to haul wastes. (12)
See Appendix D for design and operational requirements for such
a shoreside facility.
Storage facilities may be leased tank capacity in an existing
chemical tank farm. Storage capacity should be several times the
capacity of one incinerator ship in case incineration operations
are disrupted. A well-established incinerator ship service would
very likely require new terminal construction, though leased
tank capacity in several ports may still be necessary. When
a dedicated facility is built, it will require the capability for:
dedrumming wastes, slurrying of powdered and soluble solid wastes,
and loading of solid wastes into sealed fiber or bulk material
containers. (12, Appendix B)
Inland delivery networks to the ship's loading terminal must be
established. To haul the wastes safely, special trucks, railcars,
or barges would be used. These vehicles and vessels could be
owned by the ship operator or may be leased. Barges, for example,
should be able to discharge their liquid waste cargo directly into
the ship's tanks, just as fuel oil barges load ships when they are
at dock or at anchor. (12)
The following section describes the waterfront facility design and
function. The remainder of this chapter then discusses several
current regulatory programs and activities which specifically address
the land-based handling of hazardous materials and hazardous wastes.
A. DESIGN AND FUNCTION OF WATERFRONT FACILITY
The purposes of the waterfront facility are the following:
• Receive liquid and solid hazardous wastes either by land or
by waterborne barge transport
• Analyze, blend, shred, and containerize or package the
materials as appropriate for incineration at sea
• Load the waste aboard ship in a safe and efficient manner
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• Remove and receive residues from the incinerator ship for
analysis and disposal either on land or at sea, in the case
of incineration of wastes producing a collectable residue
during disposal
A preliminary design has been developed for this facility and is
described in Appendix D. Also summarized in this appendix are the
results of a survey of existing terminal facilities which could be
used for hazardous materials.
Several design criteria were used in the preliminary design and will
also apply for subsequent design stages. The facility must accommodate
wastes in almost any physical form and in several types of containers*
some of which may be olderf corroded, and possibly leaking. Ideally
the facility would service three transportation modes for delivery of
wastes: truck, rail and barge. The facility must consecutively
accommodate up to two incinerator ships, each of which is on a
two-week cycle. The required waste storage capacity of the facility
is as follows:
Liquid Waste 30,000 m3 (181,000 bbl)
Solid Waste 1,800 m3 (64,000 ft3)
The facility must also provide for preparing and blending wastes for
optimum transfer and combustion, and for unloading ash residue from
the incineration process from each ship.
The ideal site for the facility would be located where potential
environmental impact is minimal, transportation time for the various
modes are minimal, and topography is convenient. Structural
standards must be carefully followed, and these are normally defined
by the Uniform Building Code and additional location-specific
building regulations.
The design must also meet safety, health and environmental criteria,
which include provisions for facility monitoring,- personnel safety,
and contingency planning in the event of both major and minor
releases of chemical wastes that have the potential to reach soil,
water, or air. In general these criteria are specified by federal
regulations.
Liquid waste, solid waste, and ash residue from incinerators will be
processed and stored separately. Liquid waste in drums and other
containers will be sent through a shredder in the dedrumming facility.
Liquid from both the containers and the decontamination of the
containers will be blended to optimize transfer and combustion
processes and pumped to storage tanks. Liquid waste arriving in tank
trucks or tank cars, along with the tanker decontamination rinse, will
also be blended and pumped to the storage tanks.
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Solid waste arriving at the site will be unloaded at the unloading
rack, prepared for incineration by shredding, and placed in bulk
material containers (BMC) to be loaded on the ship.
The ash residue from the at-sea burn will be returned to the
waterfront facility and kept in the residue storage area until
removed for ultimate disposal, probably in a landfill approved
for hazardous waste disposal.
The waterfront facility is designed to prevent emissions of hazardous
materials; to contain spills, leaks and other accidents; and to
minimize harm to personnel in the event of accidents. Planned
measures include the following:
• Collection and disposal systems for vapors from waste
transfer
• Detailed material balance audits
• Dry break valves which prevent spillage during
disconnecting
• Aboveground plumbing and convenient access to fittings
• Use of corrosion resistant materials
• Pipes sloped away from points of potential discharge
• Complete fire prevention and control systems
• Security provisions including guards and continuous
fencing around facility
• Special training in hazardous wastes for personnel
• Effluent and media monitoring in and around facility
• Dikes around liquid storage areas
The facility is expected to require approximately 75,000 square
meters (18 acres) of land and will require a staff of approximately
40 to operate on a two-shift schedule.
Capital costs for the installed facility (excluding dock rental and
land costs) are estimated to be $19 million in 1980 dollars. Land
costs will vary greatly depending on the location and are expected to
be in the range of $5 to $20 million. The operating costs, including
labor, maintenance, depreciation, power and ash disposal, are
estimated to be $4 million annually. This excludes insurance costs
and potential land and dock rental costs. Insurance premiums are
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estimated to be $3 million to $6 million annually. In case the land
and dock will not be purchased, lease costs will be at least $300,000
annually.
The survey of existing terminal facilities in the United States found
that 139 ports and 1,221 terminal docks, piers or wharves on the East,
Gulf, and West coasts of the continental U.S. have sufficient water
depth and space to receive the incinerator ship. These terminals are
concentrated primarily in the states of Texas, New Jersey, Louisiana,
California and New York. Most terminals are privately owned. These
owners feel that compliance with regulations not yet finalized is the
major determinant of their ability to handle hazardous wastes. The
technical feasibility to handle these wastes is a secondary question.
Several military depots appear to have capability for handling both
liquid and solid hazardous wastes and this possibility should be
explored further.
None of the bulk liquid terminal operators thought it advisable to
provide solid waste service at a bulk liquid terminal, primarily
because of differences in the handling characteristics of the wastes.
Although separate facilities for liquid and solid wastes are not
necessarily a recommendation of this report, it is suggested
that this apparent concern be investigated further.
B. ENVIRONMENTAL PROTECTION AGENCY REGULATIONS FOR THE HAZARDOUS
WASTE MANAGEMENT SYSTEM "
The EPA published in the Federal Register of May 19, 1980, the
final rules concerning the hazardous waste management system
{40 CFR Parts 260-265). This rulemaking is in response to the
Resource Conservation and Recovery Act (RCRA) of 19 76 which directs
EPA to promulgate regulations to protect human health and the
environment from improper management of hazardous waste.
A brief summary of this regulatory action follows.
Rulemaking 40 CFR Part 260 sets forth definitions which appear in Parts
261 through 2 65 and contains provisions which are generally applicable
to all of these regulations.
Rulemaking 40 CFR Part 261 identifies four characteristics of
hazardous waste to be used by persons handling solid waste to
determine if that waste is hazardous waste. In addition, it lists
85 process wastes as hazardous wastes and approximately 400 chemicals
as hazardous wastes if they are discarded. Persons who generate,
transport, treat, store, or dispose of hazardous wastes identified
or listed in this regulation must comply with all applicable requirements
of Section 3010 of RCRA. Part 261 also sets forth the criteria used
by EPA to identify characteristics of hazardous wastes and to list
hazardous wastes.
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Rule 40 CFR Part 262 sets standards applicable to generators of hazardous
waste. The hazardous waste generator standards require a generator
to determine if the waste is a hazardous waste and then to prepare
manifests for the shipment of all such wastes sent off-site for
treatment, storage, or disposal. For these shipments, the generator
must also package, label, mark and placard the waste according
to Department of Transportation and EPA rules. The generator must also
keep records, report those shipments which do not reach the
facility designated on the manifest, and submit an annual summary
of their activities.
The 40 CFR Part 263 regulations establish standards for transporters
of hazardous waste. The hazardous waste transporter standards require
each transporter of regulated wastes to obtain an EPA identification
number, comply with the manifest system initiated in 40 CFR Part 262,
deliver the entire quantity of hazardous waste to the designated
treatment, storage, or disposal facility, and keep records of the
transportation of hazardous waste. Additionally, each transporter
is to take certain actions in the event of a discharge of hazardous
waste, e.g., clean up the hazardous waste discharge, notify the
National Response Center, and report in writing to the Materials
Transportation Bureau.
The regulations under 40 CFR Part 264 include the first phase of
the standards which will be used to issue permits for hazardous
waste treatment, storage, and disposal facilities. Included are
requirements respecting preparedness for and prevention of hazards,
contingency planning and emergency procedures, the manifest system,
and recordkeeping and reporting. Also included are general require-
ments respecting identification numbers, required notices, waste
analysis, security at facilities, inspection of facilities, and
personnel training. Additional Part 264 regulations will be
promulgated.
The regulations of 40 CFR Part 265 establish requirements applicable
during the interim status period regarding preparedness for and
prevention of hazards, contingency planning and emergency procedures,
the manifest system, recordkeeping and reporting, ground-water
monitoring, facility closure and post-closure care, financial
requirements, the use and management of containers, and the design
and operation of tanks, surface impoundments, waste piles, land
treatment facilities, landfills, incinerators, treatment units
(thermal, physical, chemical, and biological), and injection wells.
In addition, there are included some general requirements respecting
identification numbers, required notices, waste analysis, security
at facilities, inspection of facilities, and personnel training.
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EPA also published with these final rules two proposals to modify
40 CFR Part 265 concerning the financial requirements for hazardous
waste management systems and the requirements for hazardous waste
disposal by underground injection.
C. MATERIAL TRANSPORTATION BUREAU RULES FOR TRANSPORT OF HAZARDOUS
WASTES AND HAZARDOUS SUBSTANCES
The Materials Transportation Bureau, Department of Transportation,
published in the Federal Register of May 22, 1980, a final rule
(49 CFR Parts 171, 172, 173, 174, 176, 177) concerning identification
numbers, hazardous wastes, hazardous substances, international
descriptions, improved descriptions, forbidden materials, and organic
peroxides. The purpose of this regulation revision is to accomplish
the following: (1) adopt a numerical identification system for
hazardous materials transported in commerce; (2) adopt regulations
pertaining to the transportation of hazardous wastes; (3) adopt
regulations pertaining to the identification of, and discharge
notification for, hazardous substances; (4) list certain forbidden
materials by name and revise general criteria applicable to
forbidden materials; (5) provide proper shipping names for organic
peroxides; (6) require inclusion on shipping papers of the technical
names of certain hazardous components of materials covered by "not
otherwise specified" entries; and (7) provide for optional use of
certain United Nations shipping descriptions.
The principal objective of this rule, as it pertains to the use of
identification numbers, is to improve the capabilities of emergency
response personnel, such as firemen and policemen, to quickly identify
hazardous materials and to assure the accurate transmission of
information to and from the scenes of accidents involving hazardous
materials.
D. COAST GUARD WATERFRONT FACILITIES REGULATIONS (23)
The Coast Guard is revising and developing regulations for waterfront
facilities handling hazardous commodities (33 CFR Subchapter L). The
new regulations are being developed in a number of packages, each
package basically devoted to a different type of facility as follows:
general facility requirements, bulk liquid facilities, liquefied
gas facilities, container/break bulk/explosives facilities, bulk
solid facilities, and other facilities. The Coast Guard presently
has regulatory responsibilities for a total of 2,216 waterfront
facilities; this regulatory authority will be expanded to approximately
4,890 waterfront facilities in 275 ports and harbors of the United
States when the new rules take effect.
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The new waterfront facilities regulations seek to promote safety
and to minimize environmental pollution. The regulations deal
with design, construction, equipment, fire protection, operations,
maintenance, security, and personnel qualifications and training.
When new facilities handling hazardous commodities on the waterfront
are built or when existing facilities are significantly modified,
in-depth environmental impact statements will be ordered.
The new regulations will apply to many more commodities than those
presently listed as cargoes of particular hazard by the Coast Guard.
Specifically, waterfront facilities handling quantities beyond stated
threshold limits of the following materials will be subject to
the regulations: oil of any kind or in any form (including, but not
limited to petroleum, fuel oil, sludge, oil refuse, and oil mixed
with wastes other than dredge spoils) and all of the articles,
materials, chemicals or cargoes referred to in the following regulatory
publications: 46 CFR Subchapter D {bulk liquids and gases), 46 CFR
Subchapter 0 (bulk dangerous cargoes),46 CFR Part 148 (bulk solid
hazardous materials), 49 CFR Subpart 172.101 (packaged hazardous
materials), 33 CFR Subpart 124.14 (cargoes of particular hazard), and
40 CFR Part 116 (hazardous substances).
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REFERENCES
1. U.S. Environmental Protection Agency, EPA Journal, Hazardous
Waste Fact Sheet, Volume 5, Number 2, February 1979, page 12.
2. EPA information prepared for the U.S. Senate Subcommittee on
Health and Scientific Research which began considering the
hazardous waste disposal problem on June 6, 1980.
3. U.S. Environmental Protection Agency, Disposal of Organochlorine
Wastes by Incineration at Sea, T.A. Wastler, C.K. Offutt, C.K.
Fitzsimmons, and P.E. Des Rosiers, EPA-430/9-75-014, July 1975.
4. U.S. Environmental Protection Agency, Final Environmental
Impact Statement - Designation of a Site in the Gulf of Mexico
for Incineration of Chemical Wastes, EPA-EIS-WA 76X-054, July 8,
VTTST
5. U.S. Environmental Protection Agency, At-Sea Incineration of
Organochlorine Wastes Onboard the M/T VULCANUS, J.F. Clausen,
H.J. Fisher, R.J. Johnson, E.L. Moon, C.C. Shih, R.F. Tobias,
and C.A. Zee (TRW Inc.), R.A. Venezia (EPA), EPA-600/2-77-196,
September 1977.
6. U.S. Environmental Protection Agency, At-Sea Incineration of
Herbicide Orange Onboard the M/T VULCANUS, D.G. Ackerman,
H.J. Fisher, R.J. Johnson, R.F. Maddalone, B.J. Matthews,
E.L. Moon, K.H. Scheyer, C.C. Shih, and R.F. Tobias (TRW Inc.),
R.A. Venezia (EPA), EPA-600/2-78-086, April 1978.
7. U.S. Environmental Protection Agency, Environmental Assessment:
At-Sea and Land-Based Incineration of Organochlorine Wastes,
S.F. Paige, L.B. Baboolal, H.J. Fisher, K.H. Scheyer, A.M. Shaug,
R.L. Tan, and C.F. Thorne (TRW Inc.), R.A. Venezia (EPA),
EPA-600/2-78-087, April 1978.
8. U.S. Environmental Protection Agency. Comparative Cost Analysis
and Environmental Assessment for Disposal of Organochlorine
Wastes, C.C. Shih, J.E. Cotter, D.Dean, S.F. Paige, E.P. Pulaski,
and C.F. Thorne (TRW Inc.), R.A. Venezia (EPA), EPA-600/2-78-190,
August 1978.
9. U.S. Environmental Protection Agency, Final Environmental Impact
Statement for the Incineration of Wastes at Sea under the 1972
Ocean Dumping Convention, February 9, 1979.
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10. U.S. Department of Commerce, Maritime Administration, Final
Environmental Impact Statement - Maritime Administration
Chemical"Waste Incinerator Ship Project, MA-EIS-7302-76-04F,
July 2, 1975.
11. U.S. Department of Commerce/ Maritime Administration, A
Study of the Economics and Environmental Viability of a U.S.
Flag Toxic Chemical Incinerator Ship, M. Halebsky (GMDI Inc.),
W.L. F*ink (MarAd) , MarAd Report No. 04068-002, NTIS Report No.
PB 291931, 3 Volumes, December 1978.
12. Martinez, L.A., Hazardous Chemical Incineration at Sea: A
Disposal Alternative for the United States, Unpublished Research
Report Supported by the Maritime Administration (M.S. Thesis
at the Massachusetts Institute of Technology), February 1980.
13. Letter from the Assistant Secretary for Maritime Affairs,
U.S. Department of Commerce, to the Administrator, U.S.
Environmental Protection Agency, Joint EPA/MarAd Program for
Construction of a Chemical Waste Incinerator Ship, December 13,
1979.
14. Letter from the Administrator, U.S. Environmental Protection
Agency, to the Assistant Secretary for Maritime Affairs, U.S.
Department of Commerce, January 25, 1980.
15. Interagency Meeting, Joint EPA/MarAd Program for the Construction
of a Chemical Waste Incinerator Ship, U.S. Maritime Administration
Headquarters, February 14, 1980.
16. U.S. Environmental Protection Agency, EPA Activities Under the
Resource Conservation and Recovery Act of 1976, Annual Report
to the President and the Congress for Fiscal Year 1978,
SW-755, March 1979.
17. U.S. Environmental Protection Agency,Everybody's Problem -
Hazardous Waste, SW-286, 1980.
18. U.S. Environmental Protection Agency, EPA Journal, Cleaning
Up in New Jersey, Volume 6, Number 6, June 1980, pages 10-11.
19. U.S. Environmental Protection Agency, Siting of Hazardous Waste
Management Facilities and Public Opposition, SW-809, November 1979.
20. Sneff, W.R., Maritime Administration Assistance Programs,
Unpublished Legal Research Report, U.S. Maritime Administration,
Office of the General Counsel, July 1980.
21. Intergovernmental Maritime Consultative Organization, Code for the
Construction and Equipment of Ships Carrying Dangerous Chemicals
in Bulk, as Amended.
5 3-
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22. U.S. Department of Commerce, Maritime Administration,
Final Environmental Impact Statement - Maritime Administration
Tanker Construction Program, NTIS No. EIS 730725-F, May 30, 1973.
23. U.S. Department of Transportation, Coast Guard, Draft
Environmental Impact Statement - Waterfront Facilities Requlations.
TTTT. 2 ~
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MEMBERSHIP
INTERAGENCY AD HOC WORK GROUP FOR THE
CHEMICAL WASTE INCINERATOR SHIP PROGRAM
Maritime Administration
Robert Bryan (M-743)
Edwin Cangin (M-721)
Rick Cassee (M-721)
Gene Coffman (M-724)
Lloyd Fink (M-940)
Constantine Foltis (M-724J
Kenneth Forbes (M-733)
Robert Garske (M-222)
David Gessow (M-732)
David Hanson (M-225)
Thomas Hooper {>1-724)
Daniel Leubecker (M-7 33)
Lissa Martinez (M-721)
John Nachtsheim (M-700)
Thomas Olsen (M-74 2)
Thomas Pross (M-730)
David Sh-ahan tM-370)
Wendy Sneff (M~222)
Richard Sonnenschein (M-724)
Ronald Stone (M-500.1)
Michael Touma (M-724)
Calvin Turner (M-743)
Edward Uttridge (M-550)
Environmental Protection Agency
Gerald Chapman (OSMCD)
Allen Cywin (OWWM)
Robert Johnson (EPA consultant)
Donald Oberacker (IERL)
William Rosenkranz (ORD)
David Sanchez (IERL)
Glenn Shira (ORD)
Ronald Venezia (EPA consultant)
Russell Wyer (OSMCD)
Coast Guard
Frits Wybenga (MHM)
National Bureau of Standards
Terry Matthews (TAC)
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APPENDIX A
to
REPORT OP THE INTERAGENCY
AD HOC WORK GROUP
FOR THE
CHEMICAL WASTE INCINERATOR
SHIP PROGRAM
-------
(SERVED)
( February 2?., 1979 )
( MARITIME ADMINISTRATION )
( MARITIME SUBSIDY BOARD )
U.S. DEPARTMENT OF COMMERCE
MARITIME ADMINISTRATION
DOCKET NO. A- 131
MARAD CHEMICAL WASTE
INCINERATOR SKIP PROJECT
In the matter of environmental review of the Maritime
Administration Chemical Waste Incinerator Ship
Project, including review of the Final Environ-
mental Impact Statement - Maritime Administration
Chemical Waste Incinerator Ship Project, NTIS
Report No. MA-EIS-7302-76-041F issued on July 2,
1976, under the National Environmental Policy
Act of 1969.
FINAL OPINION AND ORDER
Samuel B. Nemirow, Maritime Subsidy Board Chai-rman;
C.G. Caras, Member, James S. Dawson, Jr., Alternate
Member, and Acting Assistant Secretary for Maritime
Affairs Samuel B. Nemirow
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I. INTRODUCTION
The Maritime Subsidy Board and Assistant Secretary
for Maritime Affairs herein present the decision
and action to be taken on the Maritime Administration (MarAd)
Chemical Waste Incinerator Ship Project (Project) under the
National Environmental Policy Act of 1969 (NEPA) 1/ NEPA
requires federal agencies, in connection with "major Federal
actions significantly affecting the quality of the human
environment," to produce a detailed statement pertaining to
the environmental implications of the proposed actions and
to act using all practicable means so as to protect and
enhance the nation's environment.2/
In fulfillment of this requirement, a detailed
Environmental Impact Statement (EIS) concerning the MarAd
Chemical Waste Incinerator Ship Project was developed. The
1/ 42 U.S.C. §§4321 et seq. It should be noted that actions
which will be taken under this project involve two types
of authority: (1) delegated authority to the Board to
make contracts for the sale of vessels, and (2) authority
of the Secretary of Commerce under the Merchant Marine
Act, 1936, as amended, delegated to the Assistant
Secretary of Commerce for Maritime Affairs. In the
interest of avoiding repetition, we shall speak to the
"Board" as embracing all authorities within the Maritime
Administration.
2/ 42 U.S.C. §4331(b), 4332.
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"Final Environmental Impact Statement — Maritime Admini-
stration Chemical Waste Incinerator Ship Project,"
designated NTIS Report MA-EIS-7302-76-04IF, was issued by
the Department of Commerce on July 2, 1976. The final EIS
reflects the comments of various governmental and private
organizations concerned with environmental quality.3/ In
the Board's view, this final EIS was prepared in accordance
with all statutory and regulatory requirements and reflects
consideration of all relevant environmental consequences.4/
The Board herein reviews the environmental impli-
cations of the MarAd Chemical Waste Incinerator Ship Project,
and alternatives to the project, as noted in the final EIS,
and indicates environmental protection actions to be taken
relative to Che project.
3J For a partial listing of those who have generously given
of their efforts in this regard,note page "c", Volume I
and pages iii and iv of Volume II to the EIS.
4/ Congress intended under NEPA that a detailed EIS would
assure that agency decisionmakers had before them and
considered an analysis setting forth the environmental
implications of proposed action and alternative courses
of action. Calvert Cliff's Coordinating Committee, Inc.
v. AEC, 449 P. 2d 1109, 1114 (D.C. Cir. 1971). See also
42 U7S.C. §4332(2)
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II. THE MARAD CHEMICAL WASTE INCINERATOR SHIP PROJECT
The MarAd Chemical Waste Incinerator Ship Project
was developed in response to The Marine Protection,
Research, and Sanctuaries Act (P.L. 92-532) enacted on
October 23, 1972 (Act). The Act provides for the regulation
of ocean dumping, research on ocean dumping and other man-
induced changes to the ocean ecosystem, and the designation,
acquisition, and administration of marine sanctuaries. In
part, the Act directs the Secretary of Commerce to work in
conjunction with other federal agencies in an effort to
minimize the environmental consequences of ocean dumping.
Specifically, Title II, Section 203 of the Act requires the
Secretary of Commerce to conduct and encourage studies for
the purpose of determining means of minimizing or ending all
dumping of materials within five years of the effective
date of the Act.
The environmentally safe disposal of chemical wastes
is a serious international problem. In 1973 it was estimated
that approximately 10 million tons of non-radioactive,
hazardous waste are generated yearly in the United States.
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The rate has been increasing over the years roughly parallel
to the increases in the chemical industry — a rapidly
growing field. Disposal of these wastes, particularly by
direct ocean dumping, is becoming increasingly intolerable
from an environmental standpoint. One effective alternative
to ocean dumping is incineration at sea. Successful disposal
of combustible, liquid chemical wastes has been undertaken
for several years, primarily in Europe, aboard various
incinerator ships. The experience of these vessels has been
very encouraging and has provided significant information
which is used here.5/
In furtherance of the Secretary's goals and re-
sponsibilities under the Act, MarAd is considering federal
support for the development of a U.S. capability to incinerate
toxic chemical wastes at sea. No single -mode of support, to
the exclusion of others, is contemplated at this time. Al-
though MarAd support could come in many forms, three
specific forms are most likely:
5/ See Volume 2 of the EIS for particularly detailed dis-
cussions of research burns aboard these vessels.
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1. The National Defense Reserve Fleet (NDRF) is
maintained by MarAd and comprises severaL hundred merchant
ships available for use during national emergencies.6/ From
time-to-time, some of these vessels become obsolete due to
their age, advances in technology and changes in U.S.
emergency needs. It is possible that such obsolete vessels,
upon conversion, would be capable of chemical waste
incineration at sea. In the past, many such obsolete vessels
have been successfully utilized as platforms for various
non-shipp ing functions.
2. The Merchant Marine Act, 1936, as amended, pro-
vides for a loan Guarantee Program whereby the full faith
and credit of the United States is pledged to the repayment
of principal and interest on qualified shipbuilding loans.7/
These so-called Title XI guarantees could be granted in
connection with the consideration of chemical waste incinerator
6/ Merchant Ship Sales Act of 1946, 60 Stat, 41, U.S.C.
App. 1735 et_ seq.
U 46 U.S.C. 1271 et seq.
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ships and would greatly facilitate the construction financing
of such vessels.
3. The advantages of both NDRF and Title XI mortgage
loan guarantees co-uld be combined to provide the government
Title XI mortgage loan guarantees to secure financing for
conversion of vessels from the NDRF to chemical waste
incinerator ships.
III. ENVIRONMENTAL IMPLICATIONS OF THE PROJECT
As noted earlier, NEPA requires that the environmental
implications of proposed major federal programs be considered
prior to taking action. These implications are set forth in
detail in the final EIS for the project,8/ and are summarized
herein:
A. ENVIRONMENTAL IMPACT OF THE PROJECT
The final EIS properly indicates that the environ-
mental considerations incident to the Chemical Waste
Incinerator Ship Project arise in three principal areas:
8/ Final EIS, Volume 1, §111.
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accidental discharge or spillage; incineration discharge
effects; and ship construction, conversion, repair and
scrapping. In addition, the final EIS indicates certain
minimal adverse environmental effects of the project which
cannot be avoided.
1. ACCIDENTAL SPILLAGE OF THE CHEMICAL
WASTE CARGO
The most serious potential environmental consequence
of the project is the potential adverse environmental effects
of accidental spillage of chemical waste due to a vessel
casualty or during the loading of the ship. In the event of
such a chemical spill, the environmental impact will deptend
on a number of factors including: (1) the environmental
conditions where the spill occurs in terms of the water's
temperature, turbulence, and existing pollution load; (2) the
spill site's marine life population; (3) the spill rate;
and (4) the nature of the chemical involved.
From the foregoing factors it is apparent that an
accidental chemical spill would have a substantial adverse
effect on marine life in the spill site area and could pose
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a threat to human health in recreational water areas. It is,
therefore, the opinion of the Board that prevention of
accidental discharges of hazardous chemical wastes is a
primary goal, although not the only goal, of the MarAd Chemical
Waste Incinerator Ship Project. As such, we later discuss
various safety and control measures which will be required
in connection with the Chemical Waste Incinerator Ship
Project. These precautions will minimize the potential for
accidental discharge of chemical wastes at sea and in port.
2. INCINERATION DISCHARGE EFFECTS
The safe and relatively non-polluting incineration
at sea of hazardous chemical wastes is an additional goal
of the Maritime Administration's Chemical Waste Incinerator
Ship Project. Incineration necessarily produces combustion
by-products, primarily the emission of gaseous materials.
These products can themselves result in air pollution and
also water pollution when they contact the ocean surface
and become mixed with the ocean water. The effect of these
products can best be judged by observing the actual
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experience of incineration aboard the foreign flag vessel
VULCANUS in both Europe and the United States. This history
has revealed that a high combustion efficiency well in excess
of 99.9% is regularly achieved, and that such combustion
efficiency contributes to minimizing the adverse environ-
mental effects created by the incineration emissions.
3. SHIP CONSTRUCTION, CONVERSION, REPAIR
AND SCRAPPING
As noted earlier, MarAd's Chemical Waste Incinerator
Ship Project may include support for the conversion and
repair of existing vessels or the construction of new vessels
to incinerate chemical waste at sea. The construction or
conversion process itself may have an environmental impact.
Principally three aspects of the ship construction
industry have an effect on the environment: expansion of
shipbuilding capacity; actual ship construction, alteration,
conversion or repair; and the use of various raw materials.
The Board has had occasion in the past to consider the
environmental impact of the ship construction industry
generally in its decisions in Docket No. A-75 — MarAd
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Tanker Construction Program 9/ and in Docket No. A-93 — The
MarAd Bulk Chemical Carrier Construction Program. 10/ The
Board finds that the environmental impact created by the
ship construction industry in connection with the MarAd
Chemical Waste Incinerator Ship Project will be substantially
the same as that considered by the Board in the foregoing
decisions. The Board notes that the Chemical Waste Incinerator
Ship Project is of small proportion compared to the general
ship construction industry activity and will have minimal
effect on the environment. Additionally, the building of
these few new ships will not require the expansion of any
existing shipbuilding facilities. Thus, the small acale of
the MarAd Chemical Waste Incinerator Ship Project and the
minimal use of shipyard facilities combine to lessen any
potential environmental impact which might flow from the
shipbuilding aspects of the execution of the project.
9/ 13 SRR 1117 (MSB 1975).
10/ Final Opinion and Order of the Maritime Subsidy Board
served December 13, 1974 (unreported).
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4. UNAVOIDABLE ADVERSE ENVIRONMENTAL EFFECTS
Some unavoidable adverse environmental impact will
most likely occur under the MarAd Chemical Waste Incinerator
Ship Project in the mining and processing of raw materials
associated with ship construction, conversion and repair. As
noted earlier, the potential for accidental polluting spills
also exists notwithstanding the strict observance of pre-
cautionary safety measures. Additionally, the incineration
exhaust will be deposited on the ocean surface and mixed with
the ocean waters. However, the high incineration flame
temperature, the residence time for. the atomized waste in the
incinerator, and the burn efficiency rate in excess of 99.9%
combine to minimze adverse effects from incineration. Finally,
small amounts of air, water, noise and solid waste pollution
will undoubtedly result from the construction, operation and
utilization of the project vessels. It is noted that these
sources of pollution are minimal in their impact and will be
kept within the limits of local, state, national and inter-
national standards for such forms of pollution.11/
11/ Final EIS, Volume 1, §V1.
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B. RELATIONSHIP BETWEEN LOCAL SHORT TERM
USE OF THE ENVIRONMENT AUD THE MAINTEN-
ANCE AND ENHANCEMENT OF LONG TERM
PRODUCTIVITY AND THE IRREVERSIBLE AND
IRRETREIVABLE COMMITMENT OF RESOURCES
The Chemical Waste Incinerator Ship Project will have
a beneficial effect upon the long term productivity of the
oceans since incineration at sea is a viable alternative to
the direct ocean dumping of hazardous chemical wastes. The
adverse environmental impacts of ocean dumping are obvious,
The implementation of the Chemical Waste Incinerator Ship
Project will greatly lessen these adverse environmental
impacts. The vessels built or converted under this project
are to be designed, constructed and operated in accordance
with the most stringent national and international standards.
The Board concludes that the useful function to be performed
by the vessels coupled with the minimal adverse environmental
impact of the vessels' construction and operation combine
to produce an overall beneficial environmental effect which
will enhance the long term productivity of the ocean.12/
12/ Final EIS, Volume 1, §VII.
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In carrying out this project, it is expected that
certain irreversible and irretrievable commitment of re-
sources will be experienced. Such experience, however, will
be minimal.13/
IV. ALTERNATIVES TO THE PROJECT AND ENVIRONMENTAL
IMPLICATIONS
NEPA declares as national environmental policy not
only commonly understood conservation oriented goals, but
also fulfillment of social, economic and other requirements
of our nation and its people. To carry out this policy
NEPA requires federal agencies to use "all practical means,
consistent with other essential considerations of national
policy," to protect and enhance the environment.14/ The
emphasis upon federal decisions that weigh both environmental
considerations and other national policy considerations is
essential to NEPA. The statute expressly provides that,
"the policy and goals set forth in this chapter [NEPA] are
supplemental to those set forth ih existing authorizations
of federal agencies."15/ Only two alternatives to the project
13/ Final EIS, Volume 1, §VIII.
14/ 42 U.S.C. 4331(b).
15/ Id. at §4335.
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are available: discontinuing the project or disposition
of chemical wastes on land or at sea.
A. DISCONTINUING THE PROJECT
An alternative to the Chemical Waste Incinerator
Ship Project is for the Board to provide no federal assistance
at all with respect to chemical waste disposal. Ue beilieve
that such action would be counter to the spirit of the Act
and would not serve to lessen existing pollution problems
of chemical waste disposal. It is clear to the Board that
the benefits to be derived from this project, a project
designed to reduce pollution, will vastly outweigh the
relatively negligible adverse environmental impact which
flows from the implementation of the project. Thus, dis-
continuance of the project would not be in the national
interest.
B. OTHER TYPES OF CHEMICAL WASTE DISPOSITION
The EIS addresses various forms of chemical waste
disposal, including disposal processes on land, dumping at
sea and incineration aboard foreign flag ships.16/ Land
based disposal could consist of physical treatment, chemical
16/ Final EIS, Volume 1, §V.
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treatment, thermal treatment, or biological treatment. Each
of these methods provides an environmental impact of its
own which, in certain circumstances, can be substantial, and
in many instances is believed greater than for incineration
at sea with U.S.-flag vessels. It is the Board's view that
disposition of certain types of chemical wastes by incineration
at sea provides a highly desirable alternative to many
existing methods of disposal. Thus, it is anticipated that
incineration at sea will add another viable method to safe
disposal of hazardous chemical wastes.
V. DECISION ON PROJECT
It is decided to pursue the MarAd Chemical Waste
Incinerator Ship Project since it is found that the project
will further the purposes of NEPA. Such approval will be
conditional on safeguards to protect the environment.
As noted earlier in this opinion, the chief environ-
mental impact of the project would result from the accidental
spillage of hazardous chemical wastes. Various local, state,
federal and international regulations and programs presently
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exist which bear on the avoidance of such accidental dis-
charges. 17/ In addition, extensive safety and pollution
abatement regulations exist which are administered by the
U.S. Coast Guard, the U.S. Environmental Protection Agency,
the American Bureau of Shipping, and the Intergovernmental
Maritime Consultive Organization. These regulations are
discussed below. The incinerator type ships proposed in
this project will be required to comply with such regulations
and various other regulations and standards established to
protect the environment. Also discussed below are further
specific actions to be taken by MarAd to protect the environment
17/ The federal regulations and standards were promul-
gated pursuant to national laws including: (i) NEPA,
(ii) Oil Pollution Act of 1961 (P.L. 87-167), (iii) Oil
Pollution Act Amendments of 1973 (P.L. 93-119), (iv)
Marine Protection, Research and Sanctuaries Act of 1972,
(v) Federal Water Pollution Control Act Amendments of
1972 (P.L. 92-500), (vi) Clean Water Act of 1977
(P.L. 95-217), (vii) Ports and Water Safety Act of 1972
(P.L. 92-340), (viii) The Port & Tanker Safety Act of
1978 (P.L. 95-474), (ix) Coastal Zone Management Act of
1972 (P.L. 92-583), (xi) Resource Conservation & Recovery
Act of 1976 (RCRA) (P.L. 94-580). The last statute,
RCRA, does not extend to incineration at sea. It re-
quires the EPA to promulgate regulations establishing
performance standards for storage, transportation, treat-
ment and land disposal of hazardous wastes. As a
practical natter, it has been a major catalyst for
incineration at sea because of the stringent regulation
thereunder cf land-based alternatives.
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with respect Co the project in the form of standard speci-
fications for ship construction, incinerator ship system
safety analyses, and training support.
A. U.S. COAST GUARD DESIGN, CONSTRUCTION
AND OPERATION REQUIREMENTS
The federal agency principally responsible for
maritime law enforcement, safety at sea and pollution
avoidance from ships is the U.S. Coast Guard. Among its
regulatory duties, the Coast Guard is responsible for the
safe transportation of hazardous materials in the marine
mode. The transportation of chemical waste by the vessels
of this project falls within the purview of Coast Guard
regulation.
The Coast Guard would become involved in ship con-
struction of vessels for this project once initial plans and
specifications are submitted for approval by the agency.18/
During construction, each ship would be visually inspected
by Coast Guard personnel to insure that the approved plans
were followed. Additionally, throughout a vessel's operating
life the vessel would be inspected periodically. The Coast
Guards regulations are designed to insure that pollution
18/ ' Final EIS, Volume 1, §IV A.
A-17
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from chemical carriers is minimized or eliminated to the
highest degree practicable through the enforcement of
standards, regulations and procedures for design and con-
struction, cargo containment, fire protection, navigation,
cargo transfer and spill notification.
The Coast Guard requires that vessels be designed to
minimize collision effects in a manner appropriate to the
cargo for which the vessel is constructed so that even if
a vessel sustains damage at sea, it will remain afloat with
minimum or no loss of its hazardous cargo. Requirements in-
clude double hull construction; a two-compartment standard
of subdivision and damage stability; collision protection
for cargo tanks, piping and equipment; and special allowances
for localized loading and longitudinal bending. Additionally,
the cargo tanks utilized in these vessels will be designed
specially to accommodate the particular type of cargo which
they will carry. Certain kinds of auxiliary equipment will
be required aboard these vessels to control heating, cooling,
pressurization, pumping and venting along with fire protection.
These auxiliary equipment systems will aid in the prevention
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of leakage, the ability to combat fire and explosion, the
prevention of chemical reaction, and the minimizing of
toxic exposure.
B. U.S. ENVIRONMENTAL PROTECTION AGENCY
INCINERATOR REQUIREMENTS
The Environmental Protection Agency (EPA) has
jurisdiction under the Act over the design and operation of
the at-sea incineration system and related matters. EPA
requirements are based upon international regulations and
technical guidelines on the control of incineration of wastes
at sea. These regulations and guidelines are part of the
International Convention on the Prevention of Marine Pollution
by Dumping of Pastes and Other Matter, 1972. The regulations
and guidelines address a variety of matters including the
following: (1) construction of the marine incinerator system;
(2) approval of the incineration system; (3) wastes requiring
special studies; (4) operational requirements for the
incineration ship; (5) control over the nature of wastes
incinerated; (6) incineration site selection; (7) notification
procedures; <8) incinerator operations; and (9) general
controls on the incinerator ship and its operation.
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EPA considers ocean incineration as an emerging
viable technological alternative, under carefully controlled
conditions, to the direct ocean dumping of various types of
chemical wastes. No significant degradation of air and water
quality has been noted during careful and extensive EPA
monitoring of research burns of organochlorine wastes in the
Gulf of Mexico and the Pacific Ocean.
C. THE AMERICAN BUREAU OF SHIPPING RULES
The American Bureau of Shipping (ABS) prescribes
standards for the design and construction of the hull
structure, main propulsion machinery and vital auxiliary
equipment for all types of merchant vessels. Both, the U.S.
Coast Guard and MarAd along with various private corporations
and foundations, participate in the formulation of the ABS
rules.
D. INTERGOVERNMENTAL MARITIME CONSULTATIVE
ORGANIZATION
Over the last decades several agreements have been
reached among nations designed to arrest the growing amount
of pollution from ships. Chief among these conventions are
those adopted by the Intergovermental Maritime Consultative
A-20
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Organization (IMCO) . The IMCO Marine Environment Protection
Committee and Maritime Safety Committee are principally
concerned with the abatement of marine pollution and with
marine safety. Various IMCO documents bear on this program
and include:
1. IMCO Code for the Construction and Equip-
ment of Ships Carrying Dangerous
Chemicals in Bulk;
2. 1972 Convention on the Prevention of
Marine Pollution by Dumping of Wastes
and Other Matter;
3. 1973 International Convention for the
Prevention of Pollution from Ships;
4. 1974 International Convention on Safety
of Life at Sea;
5. 1978 Protocol relating to the Inter-
national Convention for the Prevention
of Pollution from Ships;
6. 1978 Protocol relating to the Inter-
national Convention on Safety of Life
at Sea;
7. 1978 International Convention on Training
& Watchkeeping of Seafarers.
It is the Board's opinion that the execution of the
MarAd Chemical Waste Incinerator Ship Project will be in
compliance with IMCO regulations and standards and in furtherance
of IMCO pollution abatement and safety goals.
A-21
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- 22 -
E. MARITIME ADMINISTRATION STANDARD SPECI-
FICATIONS FOR MERCHANT SHIP CONSTRUCTION
Over the years MarAd has developed standard speci-
fications to provide guidance to naval architects, ship
owners and shipyards in the construction of various kinds of
merchant vessels. On a continuing basis, MarAd has in-
corporated sections into the standards relating to pollution
abatement and ship safety which are relevant to this project.
These standard specifications include sections for: (1) in-
voking compliance with regulatory body requirements; (2) con-
tributing to the overall physical safety potential of the
vessel; (3) enhancing the safe navigation and/or operation
of the vessel; and (4) mitigating water and air pollution.
Additionally the MarAd specifications provide for colLision
avoidance radar
F. INCINERATOR SHIP SYSTEM SAFETY ANALYSIS
MarAd considers that the performance of a compre-
hensive System Safety Analysis would enhance the safety of
operating an incineration ship. This System Safety Analysis
should address: (1) the design, construction, equipment,
maintenance, and operation of the incineration ship; (2)
measures to protect the health of the operating personnel and
A-22
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- 23 -
Che pub Lie; and (3) methods Co preserve the environment.
The Analysis would be submitted by the applicant with the
initial plans to MarAd for co-ordination with the Coast
Guard and the EPA. It would assist in assuring that all
safety and pollution control requirements have been met.
G. TRAINING
Recent statistical studies have shown that personnel
errors are responsible for a significant percent o£ marine
casualties. Thus, effective and comprehensive training of
personnel is A necessity for the safe execution of the project.
Various procedures are already extant which combine to pro-
vide effective and thorough training of personnel aboard
vessels such as those proposed to be used in this project.
Such training will contribute to reduction of potential
accidental spillage. IMCO standards, U.S. Coast Guard
regulations and MarAd training support should contribute
to minimize adverse environmental effects Resulting from
personnel deficiencies.
A-23
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- 24 -
VI. CONCLUSION
In summary, upon careful review and consideration of
the Final Environmental Impact Statement - Maritime
Administration Chemical Waste Incinerator Ship Project,
issued on July 2, 1976, as NTIS Report No. MA-EIS-7302-76-041F,
and alternatives thereto, and for the reasons set forth in
this decision, the Maritime Subsidy Board and the Assistant
Secretary for Maritime Affairs take the followinc actions
regarding the MarAd Chemical Waste Incinerator Ship Project
pursuant to the National Environmental Policy Act of 1969,
The Marine Protection, Research, and Sanctuaries Act of 1972
and the Merchant Marine Act, 1936, as amended, including the
Merchant Marine Act of 1970:
1. Find and conclude that the aforesaid Final
Environmental Impact Statement presents adequate information
in accordance with the National Environmental Policy Act of
1969, on the environmental implications of the MarAd
Chemical Waste Incinerator Ship Project and the alternatives
thereto;
2. Find and conclude that contracts of sale of
obsolete National Defense Reserve Fleet vessels and Title XI
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loan guarantees in connection with construction or conversion
of vessels to incinerator ships will require shipyard
compliance with government (local, state and federal)
environmental standards for actual ship construction under
contract and any expansion of yard facilities necessary to
perform such work;
3. Find and conclude that the MarAd Chemical
Waste Incinerator Ship Project will be pursued;
4. Find and conclude that contracts of sale for
obsolete National Defense Reserve Fleet vessels to be con-
verted to incinerator ships and granting of Title XI loan
guarantees will require compliance with the applicable
national and international requirements for safety and
pollution control, including those of the Maritime Admini-
stration Standard Specifications for Merchant Ship Con-
struction and the provisions of said Specifications
pertaining to collision avoidance radar;
5. Find and conclude that the Board will continue
to work cooperatively with the U.S. Coast Guard and the U.S.
Environmental Protection Agency in ongoing efforts to
minimize or end ocean dumping of chemical wastes.
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- 26 -
6. Find and conclude that a System Safety Analysis,
as described herein, should be submitted by each applicant
for participation in the MarAd Chemical Waste Incinerator
Ship Project with the initial plans to MarAd for coordination
with the U.S. Coast Guard and the U.S. Environmental Protection
Agency.
SO ORDERED BY THE
MARITIME SUBSIDY BOARD and
MARITIME ADMINISTRATION
Dated: February 16, 1979
Assistant Secretary
Maritime Subsidy Board
Maritime Administration
A-26
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APPENDIX B
to
REPORT OF THE INTERAGENCY
AO HOC WORK GROUP FOR THE
CHEMICAL WASTE INCINERATOR
SHIP PROGRAM
-------
DESIGN RECOMMENDATIONS FOR A SHIPBOARD AT-SEA
HAZARDOUS WASTE INCINERATION SYSTEM
FINAL REPORT
by
R. J. Johnson, D. A. Ackerman, J. L. Anastasl
C. L. Crawford, B. Jackson, and C. A, Zee
TRW. Inc.
One Space Park
Redondo Beach, California 90278
Contract No. 58-03-2560
Work Directive No. T5017
EPA Project Officer: 0. A. Oberacker
Incineration Research Branch
Industrial Environmental Research Laboratory - Cincinnati
U. S. Environmental Protection Agency
Cincinnati, Ohio 45268
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
B-i
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ABSTRACT
This report summarizes the results of an engineering study assessing
the key aspects of at-sea Incineration, Including the total shipboard
Incineration system, 1n several alternative forms, and all phases of waste
disposal from waste selection to final disposition of any effluent, ash, or
residues produced. Evaluation of basic incinerator devices potentially
applicable to shipboard operation resulted In the selection of liquid
injection incinerators for routine destruction of pumpable wastes. A rotary
kiln is recommended for shipboard experimental evaluation of solid waste
Incineration. Fluidlzed bed, molten salt, multiple hearth, multiple chamber,
and starved air Incinerators are all limited in operating temperatures and
waste type handling capacity compared to the rotary kiln.
Emisston control devices* although commonly used with land based
Incinerators, have many limitations for at-sea operation. A high energy
venturf scrubber utilizing sea water should be considered for shipboard
evaluation. The molten salt bath should be considered for experimental
evaluation as a scrubber for trace metal emissions.
Estimated cost of a rotary kiln incinerator designed for shipboard
application Is $900,000 or $1,119,000 installed. Cost of each liquid
injection incinerator is estimated to be $2,500,000 or $3,812,000 Installed.
One rotary kiln and three liquid Injection Incinerators are recommended for
the ship of approximately 8,000 metric tons waste capacity under considera-
tion. Required sampling, monitoring, and analysis equipment 1s estimated
to cost approximately $261,000.
This report was submitted in partial fulfillment of Contract No. 68-03-2560,
Work Directive No. T5017, under the sponsorship of the U.S. Environmental
Protection Agency. This report covers the period from March 26, 1980 to
September 18, 1980.
B-11
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EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA) has estimated that 1n
1980 at least 57 million metric tons of industrial hazardous wastes will be
produced nationally. Many of these wastes, particularly organic chemical
wastes, are incinerable; however, there are only a limited number of commer-
cially available land based hazardous waste incinerators in the United States.
Thermal destruction of liquid chemical wastes at sea has been shown to be
an environmentally acceptable means of disposal. The EPA, Office of
Research and Development, 1s considering a demonstration project for at-sea
Incineration of hazardous wastes 1n cooperation with the U.S. Department of
Commerce, Maritime Administration, which will provide the required vessel.
EPA has recommended that a U.S. Incinerator ship be built to extend the
capabilities of at-sea incineration to destruction of solid and semi-solid
materials, as well as to perform operational destruction of liquid wastes.
This engineering study was undertaken to assess the key aspects of a
total shipboard incineration system. Major characteristics of incinerator
types evaluated for at-sea application are compared in Table A. Liquid
injection incinerators, which have been proven for shipboard destruction
of pumpable wastes, are recommended for the proposed vessel. A rotary
kiln is recommended for solid waste incineration because of its versatility
in incinerating all waste types and its high temperature capability. Modi-
fications to the standard kiln mounting and seals are required for ship-
board operation. The molten salt reactor, because of its potential for
retaining particulate and contaminants in the melt, should be considered
for further evaluation and development testing on land, but is not suffi-
ciently proven commercially to be selected as a solids Incinerator for
shipboard application. Also, the risk of molten salts spills onboard
ship must be assessed.
Emission control devices commonly used with land based Incinerators
have many limitations for shipboard operation including size, weight, and
B- Hi
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TABLE A. COMPARISON OF CANDIDATE INCINERATOR TYPES
FOR SHIPBOARD AT-SEA APPLICATION
liquid
Injection
Rotary
Kiln
Fluidlzed
Bed
Molten
Salt
Mult1ple
Hearth
Multiple
Chamber
Starved
Air
Waste Types
Pumpable liquids
X
X
X
X
X
X
X
Slurries, sludges
X
X
X
X
X
Tars
X
X
X
Sol Ids
granular
X
X
X
X
X
Irregular
X
X
containerized
X
X
Maximum Operating
Temperature, *C
1600
1600
980
980
1100
1000
820
Maintenance
lot.'*5
med<'><<"
high'*'
¦ed(*>
high'*'
Commercial
Appl1 cations
widely used'f'
liquid wastes
widely used,
all wastes
limited use
sludges and
organic
wastes
, demon- widely
stratlon sewage
tests only sludge
used, widely used,
refuse
limited
use,
rtsourcc
rtcovtry
TIT
(b)
(c)
(d)
No moving parts 1n high tavperature zone
Bearing and seal modifications required
Ash removal and bed replacement required
Salt recycle or replacanent required
7*1
(f)
Moving parts 1n high temperature zone
Liquid Injection Incinerators are the only
type that have been successfully utilized
for shipboard at-sea operation.
fresh water requirements. A high energy venturl scrubber utilizing sea
water 1s recommended for Initial shipboard evaluation. Marine environmental
effects of a single-pass sea water scrubber will require evaluation.
A shipboard waste feed system is required to retrieve the waste from
storage and transport 1t to the incinerator without spillage under oper-
ating conditions of pitch, roll, and vibration. Liquid wastes and some
slurries can be transported to the incinerator by conventional pumps,
piping, and valves. Gas blanketed storage tanks with corrosion-resistant
linings and waste feed flowmeters are recomnended for liquid wastes.
Solids should be loaded Into sealed containers on land: either smaller
fiber containers to be fed directly Into the incinerator or larger stan-
dard bulk material containers to be discharged directly into a sealed
hopper. Handling of 55 gallon drums, particularly potential leakers, and
shredding operations involve too much risk onboard ship.
Environmental monitoring during at-sea Incineration should be conducted
to ensure personnel safety and protection of the environment. All require-
ments of the Marine Protection, Research, and Sanctuaries Act (MPRSA)
B- iv
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and the Convention on tfie Prevention of Marine Pollution by Dumping of
Wastes and Other Matter (London Convention) will be met. A shipboard
laboratory should be provided for analysis and identification of effluent
waste samples and verification of destruction efficiency.
The ship layouts shown in Figure A indicate some of the ways that
incineration systems can be integrated onboard ships to provide desired
incineration capacity and operational time at sea. Optimization studies
to determine tJie number of incinerators and incineration time versus
ship loading and transit times can be made for each ship size under
consideration.
liquid incinerators (2)
DECK
HOUSE
4000 MT
WASTE STORAGE
100 At
ROTARV KILN ,
¦ rsu i nri t iv11
rsg
LIQUID
INCINERATORS (3)
8000 MT | DECK
WASTE STORAGE I HOUSE
D>
130 M
LIQUID
INCINERATORS (91
ROTARY
'KILNS <2}
12000 MT
WASTE STORAGE
i<
DECK
HOUSE
tMM
Figure A. Incineration System/Ship Integration.
A U.S. frtci Aeration ship can serve two broad functions: first, it
can be used for the destruction of hazardous wastes 1n a location minimiz-
ing the risk to public health; second, 1t would provide a safe site to con-
tinue EPA's research and development efforts In hazardous waste incinera-
tion. An incineration vessel would expand the experience 1n the large
B- v
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scale processing of hazardous waste materials. The effects of process
variations in a commercial scale incinerator on hazardous waste destruc-
tion efficiencies need to be further investigated, including many types
of wastes not yet tested. In addition to performing operational destruc
tion of hazardous wastes, the proposed incineration vessel could be
effectively utilized for development testing of incinerator designs,
emission control concepts, and improved sampling/monitoring equipment
and methodology.
B- vi
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CONTENTS
Page
1. INTRODUCTION B- 1
1.1 Background 1
1.2 Objectives 1
2. FINDINGS, CONCLUSIONS, RECOMMENDATIONS, AND COSTS 3
2.1 Findings and Conclusions 3
2.2 Recommendations 4
2.3 Estimated Costs 5
3. CONCEPTUAL DESIGNS 6
3.1 Fundamentals of Waste Incineration 6
3.1.1 Combustion of Liquids and Solids 7
3.1.2 Waste Properties Affecting Combustion ... io
3.1.3 Combustion Air • 13
3.1.4 Temperature, Residence Time, and
Mixing 14
3.2 Waste Types 18
3.2.1 Sources and Characteristics 18
3.2.2 Suitability for Incineration 19
3.3 Incinerator Types 26
3.3.1 Liquid Injection 26
3.3.2 Rotary Kiln 31
3.3.3 Fluldlzed Bed 35
3.3.4 Molten Salt 38
3.3.5 Other Incinerator Types 40
3.3.6 Design Discussion 45
3.4 Waste Feed Systems 51
3.4.1 Liquids 51
3.4.2 Slurries 52
3.4.3 Bulk Solids 52
3.4.4 Containerized Solids 52
3.4.5 Recommendations 55
3.5 Emission Control Devices 56
3.5.1 Electrostatic Precipitators 56
3.5.2 Fabric Filters . 59
3.5.3 Molten Salt Bath 63
3.5.4 Wet Scrubber 67
3.5.5 Conclusions and Recommendations 71
B-v11
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CONTENTS (Continued)
Page
3.6 Shipboard Laboratory B- 75
3.6.1 Recommended Analytical Capability 76
3.6.2 Required Instrumentation 81
3.6.3 Required Laboratory Support 81
3.6.4 Recommendations 82
4. INCINERATION SYSTEM/SHIP INTEGRATION 84
5. COST AND SCHEDULE ANALYSIS 86
5.1 Incinerators 86
5.2 Waste Feed Systems 87
5.3 Emission Control Devices 87
5.4 Sampling, Monitoring, and Analysis Equipment 89
5.4.1 Sampling Equipment 89
5.4.2 Monitoring Equipment 89
5.4.3 Analysis Equipment 90
6. ENVIRONMENTAL MONITORING 91
6.1 Initial Incineration Monitoring 91
6.2 Routine Incineration Monitoring ... 92
7. OPPORTUNITIES FOR R&D EVALUATION 94
REFERENCES 96
BIBLIOGRAPHY 98
B- viii
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ILLUSTRATIONS
Page
1. Schematic of Energetic Relationships between Waste
and Product MoTecuIes in Combustion 3-8
2. Schematic of Combustion of Solids 9
3. General Electric Liquid Injection Incinerator 27
4. Dimensional Sketch of Vulcanus Incinerator 27
5. M/T Vulcanus Incinerators 29
6. M/T Vulcanus - Incineration Vessel 30
7. Incineration System - Burner Locations 31
8. Schematic of Rollins Environmental Services Incinerator. . . 33
9. Fluidized Bed Facility Schematic 36
10. Atomics [ritemation Div., Molten Salt Reactor 3B
11. Multiple Hearth Incineration System 40
12. Multiple Chamber Incinerator 43
13. Relative Sizes and Thermal Capacities of Currently
Used Incinerator Types 47
14. Bulk Material Container 53
15. Bulk Material Container and Unloading Device 54
16. Electrostatic Precipitator 57
17. Fabric Filter 60
18. Molten Salt Scrubber 64
19. Wet Scrubber Types 69
20. Flow Chart Showing Situations Requiring Onboard Analysis . . 77
21. Preliminary Shipboard Laboratory Design 83
22. Incineration System/Ship Integration 84
B~ 1 x
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TABLES
Page
1. Waste Characteristic arid Appropriate Thermal
Destruction Process B- 21
2. Matrix for Matching Wastes and Incinerators 25
3. Comparison of Candidate Incinerator Types for
Shipboard At-Sea Application 46
4. Advantages and Limitations of Selected Emission
Control Devices . 72
5. Incinerator Cost Estimates 86
6. Comparisons of Suitable Gas Cleaning Devices Applicable
to Hazardous Waste Incineration Aboard Ship 88
B- x
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1 . INTRODUCTION
1.1 BACKGROUND
The U.S. Environmental Protection Agency (EPA), Office of Research and
Development, is considering a research and demonstration project for at-sea
incineration of hazardous wastes. This project is a joint venture with the
U.S. Department of Commerce, Maritime Administration (MarAd), which will
provide the required vessel. EPA will undertake the design and installation
of the incineration system, and operate the ship for one year intermittently
over more than one calendar year period. The intent 1s then to turn the
ship over to a commercial operator.
Thermal destruction of chemical wastes at sea has been shown to be an
environmentally acceptable means of disposalHowever, all currently
operating Incinerator ships are limited to destruction of homogeneous pump-
able liquid wastes only. EPA has recommended that a U.S. Flag incinerator
ship be designed and constructed to not only dispose of the accumulation of
hazardous materials by present state-of-the-art technology, but also to
extend the capabilities of at-sea incineration to include destruction of
solid materials, slurries, metal-containing wastes, and low energy content
wastes. Research and development tests, as well as operational destruction
of wastes to show proof of concept, are intended as part of the demonstra-
tion project.
1.2 OBJECTIVES
The objectives of this task are to conduct an engineering study assess-
ing the key aspects of at-sea Incineration, and to prepare a study report
on these findings. An engineering evaluation was performed of the total
shipboard incineration system, 1n several alternative forms, including all
phases of waste disposal from waste selection to final disposition of any
effluent, ash, or residues produced. Areas of consideration were limited
to handling and processing of wastes on the ship itself, and did not include
land-based activities such as waste collection, transportation and storage,
or loading of wastes onboard the ship.
B- 1
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This report presents the results of a conceptual design study, includ-
• Assessment of basic incinerator devices potentially applicable
to shipboard incineration of liquids, slurries, solids
• Selection of wastes suitable for incineration at sea
• Discussion of destruction efficiency requirements and combustion
characteristics of different waste types
• Description of alternative waste feed systems for liquids,
slurries, and solids onboard ship
• Evaluation of candidate emission control devices
• Requirements for shipboard laboratory support
• Integration of incineration systems onboard ships of various
sizes and waste capacities
• Projected costs and delivery times for incineration and feed
system components; and for sampling, monitoring and analysis
equipment
a Requirements for environmental monitoring
• Opportunities for shipboard R&D evaluations of waste
destruction efficiency and incineration system components.
B- 2
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2. FINDINGS, CONCLUSIONS, RECOMMENDATIONS, AND COSTS
The following findings, conclusions, and recommendations have been
developed from this engineering study of the key aspects of at-sea
incineration.
2.1 FINDINGS AND CONCLUSIONS
1) Liquid injection incineration represents the only technology
well proven at sea for destruction of hazardous wastes.
2) Rotary kilns are the most universal incinerators available,
capable of destroying liquids, slurries, tars and solids,
separately or combined.
3) Although widely utilized on land, rotary kilns have not been
used on ships, and would require modifications for shipboard
operation.
4) The rotary kiln in conjunction with a liquid injection inciner-
ator is the most versatile combination for thermal destruction
of a wide variety of hazardous wastes.
5) Fluidized bed and molten salt reactors are both susceptible to
bed material shifting due to ship motion; spills of molten salt
would be dangerous onboard ship.
6) Fluidized bed, molten salt, multiple hearth, multiple chamber,
and starved air incinerators are all limited in operating
temperatures and waste type handling capability compared to
the rotary kiln.
7) Emission control devices which may be necessary for incineration
of certain wastes, although commonly used with land based
incinerators, have many limitations for shipboard operation.
8) A dedicated shipboard laboratory is required to provide opera-
tional safety through analysis to detect waste constituents in the
shipboard environment, and for verification of waste destruction
efficiency.
9) Environmental monitoring during at-sea incineration is required
to ensure personnel safety and to protect the environment.
10) A U.S. incineration ship offers many opportunities for research
and development in hazardous waste incineration.
B- 3
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1,1 RECOMMENDATIONS
1) The recommended system for incineration of both solid arid
liquid hazardous wastes at sea is a rotary kiln coupled to
a liquid injection incinerator.
2) Two or more identical liquid injection incinerators, depending
upon the size of the ship selected, should be utilized for
destruction of liquid wastes.
3) A single rotary kiln should be installed in combination with
one of the liquid injection incinerators for R&D evaluation
before additional kilns are added.
4) Liquid wastes should be stored in gas blanketed, lined tanks.
Flowmeters are recommended for monitoring liquid waste feed
rate to each incinerator burner.
5) Solid material should be processed on land and loaded into
sealed bulk material carriers or incinerable containers
compatible with shipboard safety requirements to minimize
hazards of waste handling onboard ship. Use of 55 gallon drums
and shredding operations onboard ship are not recommended.
6) The molten salt bath should be considered for R&D evaluation
either as a scrubber or combination incinerator/scrubber because
It requires no pre-quench1ng, while removing high levels of
particulate and gaseous emissions, including trace metals.
Risks associated with spills of molten salt onboard ship must
be evaluated.
7) A high energy venturi scrubber with a pre-quench and a mist
eliminator tower should be considered utilizing sea water,
flarine environmental effects of a single-pass sea water scrub-
bing system must be evaluated.
8) A shipboard laboratory should be provided for analysis of
organics. Equipment should include a gas chromatograph with
flame ionization and electron capture detectors.
9) Space should be provided on the ship for research and develop-
ment of additional incinerators and emission control devices.
B-4
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ESTIMATED COSTS
1) Estimated cost of a rotary kiln incinerator specially
designed to withstand the pitch and roll of shipboard
operation is $900,000 or $1,119,000 installed. Design
and fabrication would require 12 to 18 months.
2) Estimated cost of each liquid injection incinerator
designed for shipboard application is $2,500,000 or
$3,812,000 installed. Design and fabrication would
require 18 to 24 months.
3) Waste feed system costs include $300 for each liquid
waste pump, $5,500 for each liquid waste ultrasonic
flowmeter system, $1000 for each bulk material con-
tainer for solid wastes, and $18,000 for a remote
operated container lifting and discharge fixture with
vibrator. All of these components could be delivered
in less than 6 months.
4) Estimated installed costs of emission control devices
applicable to hazardous waste incineration aboard ship
are $600,000 for a dry electrostatic precipitator and
$1,050,000 for a fabric filter. Delivery times would
be 12 to 18 months.
5) Estimated installed costs for other emission control
devices include over $1,000,000 for a molten salt
scrubber and from $83,000 to $441,000 for various
types of wet scrubbers. Wet scrubbers could be de-
livered in 6 to 12 months. An experimental molten
salt scrubber would require 12 to 18 months delivery
time.
6) Sampling equipment (traps, probes) is estimated to
cost $78,000 and require 8 to 12 weeks for delivery.
7) Monitoring equipment (analyzers, regulators, recorders)
will cost $108,280 and require an average of 6 to 8
weeks for delivery.
8) Analysis equipment (chromatographs, benches, hoods,
glassware) is estimated at $75,027 with 6 to 8 weeks
for delivery.
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3. CONCEPTUAL DESIGNS
3.1 FUNDAMENTALS OF WASTE INCINERATION
Incineration is a deliberate, controlled combustion process in which
organic wastes (including inorganic constituents) are reacted with oxygen
at high temperature to produce water, carbon dioxide, and other partial
and ultimate oxidation products. Incineration is applicable to virtually
all organic compounds if sufficiently high temperature, oxygen concentra-
tion, mixing, and residence time are provided and maintained. Under pro-
per operating conditions, organic wastes can be totally converted to
oxidized gases, and inorganic substances are converted to ash. In any
real incinerator system, trace quantities of products of incomplete com-
bustion (PICs) will be formed. If proper operating conditions are not
maintained, the combustion gases will contain excessive amounts of PICs
such as smoke, carbon monoxide, gaseous hydrocarbons, tars, and other
compounds. Further, the ash will also contain unburned and partially
converted organic compounds.
It is the unavoidable presence of PICs (or daughter products) and
unburned waste constituents in incinerator process effluent streams that
necessitates monitoring of these streams. Monitoring is described in
Section 6.
Two generally used performance measures for incineration are destruction
efficiency (an equivalent term gaining in use 1s destruction and removal
efficiency, DARE) and combustion efficiency.
• Destruction efficiency has conventionally been defined (1,2) as:
00 r(Fed) - (Enmedlj (],
L (Fed) J
where: DE = destruction efficiency in percent.
(Emitted) = Emission rate (e.g., mg/sec) of a waste species near
the exit plane of the stack and in other process effluent streams,
e.g., scrubber water and solid residue stream.
(Fed) = Feed rate of a waste species expressed as a rate (e.g.,
mg/sec).
B- 6
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• Combustion efficiency is defined (3) as:
(C02)
CE " 100 t(C02) + (CO)^
where: {C02) = Concentration of C02 in the stack gas near the exit plane
of the stack.
(CO) = Concentration of CO in the stack gas near the exit plane
of the stack.
Gaseous, liquid, and solid wastes can all be disposed of by incinera-
tion if the system is properly designed for these waste forms. This sec-
tion, however, covers only incineration of liquid and solid wastes. Mech-
anisms involved in combusting these waste forms and how they relate to
achieving adequate destruction and combustion efficiency are described in
the following subsections.
3.1.1 Combustion of Liquids and Solids
Combustion, the high temperature reaction of organic materials with
oxygen, occurs only in the vapor phase. Therefore, before combustion can
occur, the waste constituents must be vaporized. Conceptual models of
combustion of liquids and solids are described below.
3.1.1.1 Combustion of Liquids
When liquid waste is introduced into the combustion chamber, consti-
tuents are vaporized by radiative heat transfer from hot combustion gases.
The rate of vaporization depends on the diffusion rate of a constituent
from the bulk liquid to the surface and from the surface to the combustion
chamber environment where the oxidation reaction process of the constituent
can be completed. The diffusion rates are dependent on temperature, which
1s a function of the heat transfer rate, and the surface area of the liquid.
Surface area is typically maximized by atomizing the waste into droplets.
The smaller the droplet size, the greater the surface area. Smaller drop-
let diameters also increase heat transfer and vaporization rates, thus
reducing the required combustion chamber volume for a given waste feed
rate.
B- 7
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In the gaseous state, waste constituent molecules mix with oxygen in
the air supplied to the process and continue to gain in temperature by
exposure to hot combustion gases. When the waste molecules reach ignition
temperature, chemical bonds break, and reaction with oxygen begins. In
fundamental terms, ignition occurs when the necessary activation energy
(that energy necessary to initiate bond breaking) has been supplied.
The entire combustion process occurs because the energy of the com-
bustion products is lower than the energy of the reactants. Thus, heat is
released during combustion (i.e., reactions are exothermic). The amount
of heat released by the combustion reactions must exceed the heat re-
quired for vaporizing the waste and the heat required for activation energy,
or the process will not be self-sustaining. If the combustion reactions
are not sufficiently exothermic, auxiliary fuel must be fired with the
waste to supply the additional needs. These energetic relationships are
illustrated in Figure 1 for the simple reaction
A z K' ? B
(3)
where A is a waste molecule
X' is the activated complex in which bonds are breaking
B is the product
cACT ¦ ACTIVATION ENERGY
Ev
-------
diffuse to the surface of the solid and then diffuse out into the
combustion chamber environment for combustion to occur. Conceptually,
combustion of solids involves a series of repetitive stages^*^) :
1) diffusion and burnout of volatiles near the surface, and 2) burnout of
residual surface and exposure of fresh surface. The larger the solid
particles, the greater the number of times this sequence is repeated,
and the longer the residence time required to complete the combustion
process. Figure 2 (adapted from Figure 68 of Reference 5) 1s a schematic
illustration of the combustion of a solid.
PYROLYSIS
OXIDATION
SOLID
PHASE
^ GAS
^PHASE
NON-REACTING
SOLID
CONDENSED PHASE
REACTION ZONE
GAS PHASE
REACTION
ZONE
PRIMARY
COMBUSTION
ZONE
K#— PRIMARY.
I SECONDARY
u
AIR
POST FLAME
REACTIONS.
EFFLUENT
Figure 2. Schematic of combustion of sol Ids
When exposed to high temperatures in an incinerator, organic solids
are converted to gases by a variety of processes, including cracking,
destructive distillation, pyrolysis, and partial oxidation. Volatile
species, either originally present in the solid or formed by the above
processes, volatilize from the solid and then burn in the vapor phase.
The rates at which these processes occur depend on the temperature and
heat release in the incinerator, the composition of the solid waste, the
heat transfer to the solid, the diffusion rates, and the exposed surface
area. Mechanical agitation is usually supplied to a sol Ids incinerator to
provide continuously fresh unreacted surface.
Retention time must be sufficiently long that the sol Ids reach
ignition temperature. Residence time 1n the gas phase 1s also Important,
so that volatilized species can be completely combusted.
B- g
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3.1.2 Waste Properties Affecting Combustion
Physical-, chemical, and thermal properties of a waste affect combus-
tion. These properties are discussed in this section.
3.1.2.1 Composition
Chemical properties which should be determined in order to Incinerate
a waste Include:
• Elemental composition - C, H, N, 0, S, CI, and P.
• Ash content and fusion temperature.
• Moisture content.
The elemental composition (I.e., C, H, N, 0, S, CI, and P) should be de-
termined 1n order to calculate stoichiometric combustion air requirements
and to predict combustion gas flow rate and composition. Determination of
sulfur, halogen, and phosphorous contents is important in evaluating air
pollution and environmental impacts. If the waste contains insufficient
hydrogen to form water and hydrogen halides, auxiliary fuel or steam In-
jection 1s needed to supply the necessary hydrogen.
The ash content of the waste must be known in order to determine if
the ash handling capability of the system is sufficient and to assess par-
ticulate removal requirements of an air pollution control system. Some
generic types of Incinerator systems cannot handle high ash content wastes
(e.g., liquid Incinerators). Also, some types of incinerator designs
cannot handle fusible ash (e.g., fluldlzed bed types).
The moisture content of the waste affects the heat balance in the
combustion chamber. When halogens are present, water serves as a hydrogen
source; otherwise, water is inert. Energy is consumed in heating and vapor-
izing moisture in the waste, and moisture contributes to gas handling
requirements on the system. High aqueous content wastes will not normally
sustain combustion without cofirlng auxiliary fuel or high heat content
waste. Existing incinerator ships have multiple liquid burners and can
evaporate water through one burner while burning wastes through the other
burners.
B- 10
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Other chemical characteristics of the waste also affect the design and/
or operation of an incinerator. These include metals content and the
presence of toxic organic compounds. Metals are not usually present in
organic wastes at concentrations high enough to affect stoichiometric air
requirements. Metals do contribute to particulate formulation, and many
metals, including some toxic heavy metals, are concentrated in smaller partic-
ulates. EPA's Ocean Dumping regulations (40 CFR 227.6 (a)) prohibit ocean
dumping (or transportation for dumping) of wastes containing organohalogen
compounds, mercury and mercury compounds, and cadmium and cadmium compounds
in quantities above trace levels. Trace levels are defined as levels which
will not cause significant undesirable effects. Alkali metals (e.g.,
sodium, potassium) can cause degradation of refractory linings. (The M/T
Vulcanus will not evaporate large quantities of sea water because this
causes a glazing of the refractory linings of her incinerators.)
3.1.2.2 Heat Content
The heat content, or heating value, of a waste Is the quantity of heat
released when the waste is burned and is expressed as kcal/kg or Btu/lb.
All organic compounds have a finite heat content. Knowledge of the heat
content of the wastes to be burned is important in designing and operating
an incineration system and in determining the need for auxiliary fuel.
Normally, a minimum heating value of 4400 to 5540 kcal/kg (8,000 to
10,000 Btu/lb) is necessary to sustain combustion. However, this is only a
rule of thumb. Some materials with heat contents of 5540 to 6090 kcal/kg
(10,000 to 11,000 Btu/lb) will not support combustion without supplemental
firing, while materials with heat contents as low as 2490 to 2990 kcal/kg
(4,500 to 5,400 Btu/lb) have been burned in high performance boilers.
Below about 4,400 kcal/kg, auxiliary fuel firing is normally required.
The moisture content of a waste, as described earlier, reduces the
heat content. Also, the heat content of a waste decreases as the chlorine
(or other halogen) content Increases. Wastes with chlorine contents
greater than about 70 percent normally require auxiliary fuel. The M/T
Vulcanus has burned organochlorine wastes with chlorine content as high as
63% and heat content as low as 3,860 kcal/kg (6,950 Btu/lb) without firing,
auxiliary fuel (1).
B- 11
-------
The heat contents of various wastes vary tremendously. In order to
reduce the adverse effects (e.g., flame flickering, flame outs) of varying
heat content, It is customary practice to provide some mlnumum value. For
example, the heat content Is determined for wastes going into each of the
15 covered tanks onboard the M/T Vulcanus. Feed rates from the tanks are
metered and adjusted in proportion to heat content to achieve stable incin-
erator operation.
3.1.2.3 Physical Properties
In addition to the chemical composition and heat content of a waste,
Information about its physical form and properties 1s necessary to deter-
mine if it is compatible with a particular incinerator design. As discussed
in Section 3.3, each generic incinerator type 1s limited In terms of the
physical form of waste 1t can handle or tolerate. Feed systems and mate-
rials handl4' are discussed in Section 3.4.
Both t 1ze and form of solids must be considered. For example,
feed system, retention time, Incinerator type, and ash disposal require-
ments differ for powdered, granular, pelletized, bulk, or containerized
wastes. For a shipboard incineration system, It would be desirable to have
wastes of minimal ash content. The system should be designed so that high
ash solids do not pass Into the liquid incineration or afterburner sections
of the system. If ash 1s not collected before the liquid injection or
afterburner sections, these sections would have to be sized accordingly.
Further, the ash would have to be nonfusible at the higher temperatures of
these parts of the system. If ash is collected before the liquid injection
system, the temperature and retention time would have to be sufficient to
render the ash devoid of organic compounds.
If the waste 1s a slurry, sludge, or sem1-sol1d, it is necessary to
decide whether 1t should be handled as a liquid or a solid. Treating the
waste as a liquid would involve determining whether Its viscosity would
allow 1t to be pumped and whether solids could be kept in suspension. The
particle size, abrasiveness, and viscosity are considerations 1f the waste
1s to be Injected through an atomizatlon burner.
Kinematic viscosity 1s the chief physical property to be considered
in the incineration of liquids. Kinematic viscosities of less than about
B- 12
-------
750 Saybolt Seconds Universal (SSU) are required for proper atorm'zation
although liquids with kinematic viscosities as high as 10,000 SSU can be
pumped. Viscosity is strongly dependent on temperature, and it
should be determined at the expected injection temperature. The levels of
solids in a liquid must be determined because they can cause plugging and
erosion of injection nozzles, as well as ash buildup and incomplete burn-
out in the combustion chamber.
Other characteristics such as extreme toxicity, corrosiveness, odor,
thermal stability, chemical stability, pyrophoric properties, shock sensi-
tivity, etc., need to be considered. However, because these properties are
highly waste-specific, they can only be treated here 1n the most general
way. Wastes that are pyrophoric, shock sensitive, or chemically or ther-
mally unstable should probably not be considered for at-sea incineration
because of the potential hazards of the extra handling and harsh shipboard
environment involved. Materials of construction of the ship (i.e., tanks
and pipes) need to be evaluated for their ability to withstand corrosive
wastes. Extremely toxic or odorous wastes can be burned at sea if adequate
attention 1s given to handling, personnel protection, etc.
3.1.3 Combustion A1r
The most basic requirenent of any combustion system Is sufficient air
to oxidize the feed material completely. The stoichiometric or theoretical
air requirement is calculated from the chemical composition of the feed
material. Carbon dioxide, water, and HC1 are the major products formed
from the combustion of organochlorlne wastes. Nitrogen (which is nonreac-
tlve) 1s the major component of the combustion effluent. In any actual
system, however, trace quantities of carbon monoxide, free chlorine (ClgK
nitrogen oxides, and other PICs will also be formed. Because these
species are formed only at trace levels, 1t is not necessary to consider
them in calculating combustion air requirements and gas flow rates. If
the waste contains significant concentrations (e.g., 5% or higher) of sul-
fur or phosphorous, 1t is necessary to consider these elements.
All Incineration systems need to be operated with some excess air (air
in excess of stoichiometric requirements) because in actual system opera-
tion air and waste are not perfectly mixed and are not instantaneously
B- 13
-------
burned. The mandatory regulations of the London Dumping Convention (11)
require a minimum excess oxygen level of 3%. Required levels of excess
air depend on the type of incinerator (Section 3.3) and on the type of
waste being burned. In practice, excess air levels vary from 20 to 300%,
and levels of 50 to 10Q£ are most common.
The amount of excess air required depends on the degree of air/waste
mixing achieved In the combustion zone (a function of Incinerator type and
design), secondary combustion requirements, and the desired degree of
combustion gas cooling. In general, excess air requirements vary Inversely
with the degree of mixing achieved 1n the Incinerator and the surface-
volume ratio of the waste particles or droplets. If there is a secondary
combustion zone (e.g., in a rotary kiln - liquid injection system), excess
air requirements are higher. Because excess air 1s chiefly a diluent, 1t
absorbs heat and reduces the temperature 1n the incinerator. Temperature
reduction may be desirable when high heat content, readily combustible
wastes are incinerated in order to reduce degradation of refractory linings.
Conversely, when a lower heat content waste 1s burned, reduced excess air
levels should be used In order to help Increase the Incinerator tempera-
tures. In general, 1t is desirable to minimize excess air feed rates
(consistent with adequate combustion and destruction efficiency) in order
to minimize gas handling requirements of downstream equipment and minimize
fan size and power requirements.
Combustion air requirements are used in incinerator system design to
size the induced draft fans that are the prime gas movers 1n the system.
3.1.4 Temperature, Residence Time, and Mixing
Temperature (a function of heat release), residence time, and mixing
are three of the four primary variables affecting incineration efficiency.
They are described In this section. The fourth primary variable, oxygen,
was described 1n Section 3.1.3.
3.1.4.1 Temperature
In designing, evaluating, or operating an incineration system, there
are four aspects or questions about temperatures that should be considered:
• Is the temperature high enough to raise all waste components
above their Ignition temperatures?
B- 14
-------
• Is the temperature high enough for complete destruction to
occur at the residence time of the system? (For a fixed
volume system, temperature and residence time are inversely
proportional.)
• Is the required temperature within normal limits for the
type of incineration system?
• At what locations in the system is the temperature to be
measured?
As discussed 1n Section 3.1.2, waste combustion requires a temperature
(and a heat release rate) sufficiently high to raise waste component tem-
peratures above their ignition level. It was also described in Section 3.1.2
that heat transfer, mass transfer to the vapor phase by diffusion, and
mixing all required finite time. Thus, temperature requirements must be
evaluated with respect to the residence in the incinerator. Heat transfer,
mass transfer, and mixing rates all Increase with increasing temperature,
thereby lowering the required residence time. If the residence time of the
Incinerator type 1s extremely short, temperatures well in excess of those
required for Ignition may be required. In general, incinerator types used
for hazardous waste operate well in excess of waste ignition temperatures.
The current state-of-the-art combustion theory does not allow a
theoretical calculation of temperature-residence time requirements for
complete waste destruction. However, there are certain laboratory experi-
ments which can produce accurate measurements of temperature-residence time
requirements. Duvall and Ruby (12) used a quartz tube reactor in which
both temperature and residence time could be controlled and varied to study
destruction requirements for PCBs. This system has been further refined
under EPA sponsorship Into the Thermal Destruction Analysis System (TDAS).
The most practical means'of assessing adequate temperature-residence time
requirements 1s an examination of these parameters found to be satisfactory
1n the destruction of the same or similar waste on the same or similar type
and size of Incinerator. Although the TDAS provides guidelines, trial
burns will be necessary for some wastes, including many solids.
After determining temperature requirements, it 1s necessary to deter-
mine whether or not they are within normal limits for the Incinerator type
and whether or not they can be attained with possible firing conditions.
In general, Incinerator temperatures range from about 800°C (combustion
B-15
-------
stage of multiple hearth Incinerator or a fluidized bed) to about 1650°C
(certain special liquid Injector Incinerators).
After determining that the Incinerator system can withstand the
required temperatures, 1t 1s necessary to specify the locatlon(s) at which
temperatures will be measured. Specifying the temperature measurement
locatlon(s) directly affects the residence time because residence time 1s
specified at a particular temperature (see Section 3.1.4.2 for further dis-
cussion). There 1s great variation 1n temperature 1n an incineration
system. It 1s highest in the flame zone, lower at the walls of combustion
chambers, and decreases toward the gas exit after the combustion chamber(s).
Ideally, temperature would be measured 1n the bulk gas flow at a point
after which the gases have traversed the combustion chamber volume that
provides the specified residence time for the Incinerator. For a multiple
unit system (e.g., rotary kiln coupled with a liquid Injection burner),
temperature 1n both units should be measured. In practice, most operators
establish a correlation between flame temperature (optical pyrometer) and a
wall temperature (thermocouple) and thereafter monitor wall temperatures.
3.1.4.2 Residence Time
Residence time (dwell time or retention time) is defined as the length
of time the waste and combusting gases are exposed to and maintained at the
high or specified temperature necessary for complete destruction.
The usual method of calculating residence time is to specify the com-
bustlon gas flow rate, e.g., m /sec, at the desired'operating temperature
(measured at the combustion chamber outlet) and to divide by the combustion
chamber volume, V.m . Residence time can be calculated from:
t (sec) • (4)
Q (m /sec)
Where V * Volume traversed by combustion gases
at the required temperature, and
« _ (0.79) ( T ) (Stoichiometric A1r) „ (1 + % Excess Air)
Q \ x 273 * Flow at O'C x TTO 1 '
2
In actuality, the volume through which the combustion gases flow (V)
after they have been heated to the required temperature is smaller than the
B- 16
-------
total combustion chamber volume (Vy). Thus, the chamber volume used in the
residence time calculation above 1s smaller than the total chamber volume.
However, it is difficult to determine the proper volume, and this is why
thermocouple location 1s Important as discussed In Section 3.1.4.1. The
combustion gas flow rate 1s the sum of flow rates of combustion products
(calculated from waste stoichlometry) and excess air. An upper bound on
residence time can be calculated using the total combustion chamber volume
(Vy) and the combustion gas flow rate, Q:
t (sec) = — (6)
Q (m /sec)
Residence times calculated from equations 4 or 6 will not be rigorous
and should be used only for comparison purposes.
In solid waste incineration, the retention time of the solids as well
as the gases, must be considered in order that residual hazardous compounds
in the sol Ids be destroyed as completely as possible.
3.1.4.3 Mixing
Temperature, oxygen, and residence time requirements discussed 1n
preceding sections all depend to some extent on the degree of waste-air
mixing achieved 1n the combustion chamber. The degree of mixing is diffi-
cult to express In absolute terms because of limitations in state-of-the-
art combustion theory.
In liquid waste Incinerators, the degree of mixing is fixed largely
by: 1) the specified burner design which determines how the waste and pri-
mary combustion air are mixed, 2) the gas flow patterns in the combustion
chamber, and 3) turbulence. In general, liquid injection burners are
designed to produce droplets as small as possible. This Increases the sur-
face-to-volume-ratio which enhances the rate of heat transfer to the waste,
the rate of volatilization of the waste, and the mixing of waste vapor and
air. Mixing 1n the combustion chamber is enhanced by making the gas change
directions and by designs which promote turbulence.
B- 17
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3.2 WASTE TYPES
3.2.1 Sources and Characteristics
The sources of chemical wastes are extremely widespread and the volume
of Industrial hazardous waste expected to be produced 1n 1930 has beeri
estimated to be at least 57 million metric tons» of which 6056 1s estimated
to result from the chemical Industry.* Much of the chemical Industry
waste can be assumed to be 1nc1nerable. Thus the volume of waste produced
annually, along with waste currently stockpiled or from clean-up of old
dump sites, appears to be more than adequate to support the operation of
an incineration ship. Chemical wastes may originate from the routine
operations of manufacturing processes, Intermediate manufacturers and end
product users, as well as nonroutlne events such as spills and accidents.
Chemical wastes which are most likely to be destroyed by incineration
are organic chemicals. The manufacturing sources of these wastes will
largely follow the location pattern of the chemical Industry. Thus it is
expected that the major concentration of primary sources will be along the
Gulf Coast and the eastern seaboard. Sources of wastes Involving specialty
chemicals and pesticides manufacture can also be readily pinpointed because
of the relatively small number of manufacturers. Wastes from intermediate
or secondary sources will be much more widely dispersed but will still tend
to follow the location pattern typical of the chemical and petrochemical
industry. Source of wastes from end product users (e.g., PCB-conta1ning
electrical capacitors) can also be expected to be widely dispersed.
In classifying chemical wastes for thermal destruction, it has been
found useful to categorize them on the basis of their elemental chemical
composition ^ . Within each class of compounds with the same elemental
composition, subclasses may be developed based on properties (e.g.,
physical form, chemical composition, heat content, viscosity, etc.)
which are related to specific burning characteristics. Examination of
+ "Everybody's Problem: Hazardous Waste*" EPA/SW-826, 1980, pp 1*14,15.
8- 18
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chemical waste streams shows that those suitable for thermal destruction
fall into one of the following four classes:
1) C-H and C-H-0 compounds, yielding C0£ and HgQ on complete
combustion
2) C-H-N and C-H-O-N compounds, yielding C02, HgO and
nitrogen oxides
3) C-H-Cl and C-H-0-C1 compounds, yielding C02. HgO and
HC1 (gas)
4) Other wastes including organic wastes containing both
nitrogen and chlorine, organic wastes containing sulfur,
organic wastes containing bromine, organic wastes
containing fluorine, organic wastes containing phosphorus,
organic wastes containing silicon, and varied wastes
not included in the first three major classes
Typical waste streams in each of these four waste classes are listed
ir Table 1. The heating value for each waste stream has been denoted
either low (less than 2800 kcal/kg), medium (2800 to 5600 kcal/kg), or
high (greater than 5600 kcal/kg), as the precise heat content of most
waste streams is not well-defined or consistent. It is important to
recognize that waste stream descriptions obtained from the literature,
or supplied by a plant, cannot be considered reliable until an actual
sample of the waste stream which is to be delivered has been obtained and
analyzed. For example, still bottoms (i.e., residues from distillation
towers used in chemical manufacturing) may be liquids or tars, depending
upon the stage at which distillation is stopped. This, in turn, may be
entirely at the discretion of the operator.
3.2.2 Suitability for Incineration
Assuming that the wastes listed in Table 1 might be destructed in
any of four candidate destruction processes (i.e., liquid injection,
rotary kiln, molten salt, or fluidized bed), the processes and wastes were
matched according to the following criteria:
• Physical form of waste: gas, liquid, slurry, sludge or
solid
• Temperature range required for destruction: above 1090°C
(2000°F), 1090° to 760°C (2000° to 1400°F), 760° to 370°C
(1400 to 700*F), or below 370*C (700*F)
B- 19
-------
• Ash: nonfusible, fusible, and/or metallic
• Waste heating value: Less than 2800 kcal/kg (5000 Btu/lb),
2800 to 5600 kcal/kg (5000 to 10,000 Btu/lb), or above
5600 kcal/kg (10,000 Btu/lb).
No attempt was made in this waste suitability matching to consider the
appropriateness of the candidate processes for the at-sea application.
This consideration is discussed elsewhere in this report (see Section 3.3.6).
A comparison of the characteristics of each waste with the candidate des-
truction processes was performed previously (fi) using detailed forms as
Illustrated by the example given in Table 2. The results of this compar-
ison are summarized, along with the waste descriptions, in Table 1. The
degree of suitability is indicated on a scale of 0 to 2 with "0" being
totally unsuitable, "1" being slightly suitable (i.e., suitable only if
waste is mixed, diluted, heated, etc.), and "2" being totally suitable.
B- 20
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Table 1. WASTE CHARACTERISTICS AND APPROPRIATE THERMAL DESTRUCTION PROCESSES
Haste
Class
Waste Stream Characteristics
Potentially Applicable Candidate
Destruction Processes
Hazardous Haste Stream
Constituents
Physical
Form
Heating
Value
Liquid
Injection
Rotary
Kiln
Fluidized
Bed
Molten
Salt
1
Ethylene glycol manufacturing
wastes
Mixture of water and glycols
Liquid
Low
2
2
2
2
Off-specification isoprene
Unstable oxidizable liquid
containing isoprene
Liquid
High
2
.. _t.j
2
2
Off-specification phenol
90 to 92t or 82 to 84X phenol
containing some cresols and
water
Liquid
High
2
2
2
2
Evaporator residue from the
cuMene process for phenol
manufacture
Polymeric matter containing
acetophenone (1.68 wt X),
phenol (0.66 wt X), and
cunylphenol (0.75 wt X)
Tar
Medium
0
2
0
1
Ethylene Manufacturing tastes
Water separable oil containing
heavy polymeric oils with
traces of aromatics
Liquid
High
2
2
2
2
Organic peroxide Manufacturing
wastes (from dicumyl peroxide
Manufacture)
Organic waste stream contain-
ing dicunyl peroxide and other
aromatic diacyl peroxides In a
mixture of alcohols, phenols,
cumene alcohol derivatives and
other unknown reaction by-
products. High sodlu* content.
Liquid
High
1
1
2
2
Still bottom from acetaldehyde
production and by-product
recovery operation
Liquids containing various
aldehydes
Liquid
High
2
2
2
2
2
Steam still bottoms from
aniline and alkylated phenol
production
Mixture of phenolic compounds
and aniline derivatives
Tar
Mediin
0
2
0
1
Catch basin grease, nitrile
pitch fro* production of
surface active agents
Fatty alkyl acids, nitriles,
and amines (C-S to C-18 chain
lenqth), water (20X)
Solid
Medium
0
2
0
1
Carbamate pesticides
(carharyl)
Naphthol residues containing
approximately IX b-naphthol
Liquid
High
2
2
2
2
Reactor tar bottoms from
adiponitrile Manufacture
Tars containing phosphoric
acid (4.8 wt X) and
adiponitrile
Tar
Medium
0
2
0
1
Rating Scale: 0 - Totally Unsuitable
1 - Slightly Suitable (I.e., with dilution, heating, etc.)
2 - Totally Suitable
-------
Table 1. (Continued)
—
Waste
Haste Streaa Characteristics
Potentially Applicable Candidate
Destruction Processes
Out
Hazardous Haste Streaa
Constituents
Physical
Form
Heating
Value
Liquid
Injection
Rotary
Hi In
F1u1d1zed
Bed
Hoiten
Salt
2
Acrylon1tr1le Manufacturing
Wilts
Heavy ends containing
acrylonltrlle (CH, «
CHCN), acetonltrlfe
(UUCN), HCN and probably
pol^aerlc Material
Tar
Hedlua
0
2
D
1
TDI Manufacture reactor
tar bottom
Hastes In tar are cyclic
blureates and a coaplex
aixture of heavy organic!;
no analysis available. However,
effluent gas froa Incinerator
has the fallowing composition:
CO., 33.31; H.0, 261; N,, 36.81
02f 51; HC1, twll aaouhts
Tar
Hedliaa
0
2
0
1
01 phenylaailne (DPA) unufacture
Tars containing cyclic
blureates (SOS) and heavy
organlcs (SOS)
Tar
Hedlua
0
2
0
I
Haste froa toluenedlaalne (IDA)
production froa dinitrotoluene
fan)
Refining still residue contain-
ing TM and other Isomers
of TOft
Thick
Liquid
Ned 1M
0
2
2
2
DNT/HHT alx from DNT production
Sludge containing HHT
(aononltrotoluene), DOT and
other organic sol Ids
Sludge
Hedlua
0
1
1
2
Phenylaalne tar wastes
Tars containing aniline (301),
nitrobenzene (SI), cyclic
blureates (331) and heavy
organlcs (321)
Tar
Hedlua
0
2
0
1
Hastes froa polyaer polyol
production fro« polyaerl- -
zation of styrene with
acrylonltrlle
Liquid containing unreacted
styrene and acrylonitrile
Liquid
High
2
2
2
2
3
Organic chenical capacitor,
transformer production wastes
containing PCI's and alpha
¦ethylstyrene
Waste containing PCB's and
alpha "ethylstyrene, In
capacitors
Solid
Low
0
2
0
1
Eplchlorohydrln manufacturing
wastes
Heavy ends froa fractionation
coltam containing dlchloro-
hydrln, eplchlorohydrln, allyl
chloride, and polyaerlc aateria'
Tar
Hedlua
0
2
0
1
Rating Scale: 0 - Totally Unsuitable
1 - Slightly Suitable (I.e., with dilution, heating, etc.}
2 - Totally Suitable
-------
Table 1. (Continued)
Haste
Class
...... .
Haste Stream Characteristics
Potentially Applicable Candidate
Destruction Processes
Hazardous Haste Stream
Constituents
Physical
Form
Heating
Value
Liquid
Injection
Rotary
Kiln
Fluidized
Bed
Hoi ten
Salt
3
Hastes from perchloroethylene
production
Still bottoms containing
perchloroethylene, carbon
tetrachloride, hydrocarbons
and other chlorinated
hydrocarbons
Liquid
Medium
2
2
2
2
Hexachlorocyclopentadiene
Manufacturing wastes
Mixture of chlorinated
toluenes, pentanes, and
benzenes
Liquid
Medium
2
2
2
2
Phenolic tar from 2,4-D
Manufacture
Typical composition: 2,4-
dichlorophenol (81), 2,6-
dichlorophenol (2%), 2,4,6-
trichlorophenol (35X),
phenolic resins (55X)
Tar
Medium
0
2
0
1
Organic pharanaceut1cal
wastes
Liquid wastes containing mix-
ture of organics such as
phosgene, chlorobenzene,
toluene. Methanol methylene
dlchloride, tetrachloroethane
Liquid
Medium
2
2
2
2
Chlorotoluene production
wastes
Tars containing benzoyl
chloride residues
Tar
Medium
0
2
0
1
Phenolic tar fro* MCPA
manufacture
Typical coMposltion: 4-HCPA
(20X); 6-MCPA (201), phenolic
resins (60S)
Tar
Medium
0
2
0
1 '
4
N1troch1orobenzene
Manufacturing wastes
Heavy ends and tars from
orthochloronltrobenzene
vacuuM distillation
Tar
Medium
0
Z
0
1
Anlben Manufacturing wastes
Mixture of 90X water, 5X
Isoaier, and 51 NaCI and
«a2S04
Liquid
Low
0
1
2
Z
Dlchloroanlllne still
bottom
Mixture of iscmers; containing
25X chlorine
Solid
Medium
0
2
2
2
Alkyl and aryl sulfonic acid
Manufacturing wastes
Emulsified oil and sulfones
Liquid
Medium
2
2
2
2
MercaptobenzotM azol e
(MBT) Manufacturing
Tarry Mixture of 75X organic
sulfur containing heterocy-
clics, 15X sulfur and 10X water
Tar
Medium
0
2
0
1
Rating Scale: 0 - Totally Unsuitable
1 - Slightly Suitable (I.e., with dilution, heating, etc.)
2 - Totally Suitable
-------
Table 1. (Continued)
Waste
Class
1
Uaste Stream Characteristics
Potentially Applicable Candidate
Destruction Processes
Hazardous Uaste Stream
Constituents
Physical
Form
Heating
Value
Liquid
Injection
Rotary
Kiln
Fluidiied
Bed
Molten
Salt
4
Dodecyl nercaptan manufacturing
wastes
High viscosity liquid
Liquid
High
2
2
2
2
Fluorinated herbicide
wastes
Liquid containing aroaatic
fluorides
Liquid
Hedium
2
2
2
2
Halogenated aliphatic
funigants (ethylene broalde)
Mixture of broalnated organic
liquids containing 10-201
dlbronopropanol fro* ethylene
bromide Manufacture
Liquid
Medium
2
2
2
2
lire thane manufacturing wastes
Mixture of potyols and
phosphate esters
Liquid
Low
2
2
2
2
Organophosphorus
pesticides (Malathion)
Off-specification technical
grade aalathlon
Liquid
High
2
2
2
2
Tetraethyl orthos11i ca te
wastes
Tetraethylorthosi1Icate
liquid with traces of iodine,
alcohol, "genesolu" D
Liquid
Medium
2
2
2
2
Organonetallic Hastes
Complexes of various heavy
metals in organic Matrices
Liquid
Medina
2
2
2
2
Contaminated soils from spill
and old dump site clean-up
Hater and mineral natter mixed
with various hazardous organic
compounds
Solid
Low
0
2
0
2
¦•ting Scale: 0 - Totally Unsuitable
1 - SMghtly Suitable (I.e.. Mitti dilution, heating, etc.)
2 - Totally Suitable
-------
TABLE 2. MATRIX FOR MATCHING WASTES AND INCINERATORS
WASTE STREAF
CLASSIFICATION: H-C and H-C-0
DESCRIPTION: Evaporator residue from the
cumene process for phenol manufacture
HEATING VALUE (CIRCLE ONE)
1Q,Hnn »
100Q0 Btu/f
eiow 5UD0 Btu/)
FACILITY TYPE
GAS
Low Viscosity (Below 500 SSU)
H-fgh Viscosity (Above 500 S5UJ
z
UJ
o
o ~-«
si z
—t t—
(—
z? <_>
1— OS
or lu
—'
-------
3.3 INCINERATOR TYPES
Assessments and preliminary sizing and design selections were made of
the basic incineration devices potentially applicable to shipboard at-sea
incineration of liquids, slurries, and solids. Incinerators commonly used
for land-based destruction of hazardous waste - liquid injection, rotary
kiln, and fluidized bed - were evaluated first, along with molten salt,
a developing technology with potential advantages for shipboard at-sea
incineration. All of these incinerators are continuous feed units, rather
than batch feed, which provides maximum waste throughput for the size and
weight of the unit. Other continuous feed incinerators considered were
multiple hearth, multiple chamber, and starved air. Each of these incin-
erator types are described in the following subsections, and their advant-
ages and limitations for shipboard operation are discussed.
, , i l4 .. r • 0.2,7,8,9,10)
3.3.1 Liquid Injection 1
Liquid injection waste incinerators are furnaces fired with liquid
fuels which can be the waste itself or an auxiliary fuel, or a combination
of both, depending on the heat content and combustion characteristics of
the waste. A variety of liquid injection incinerators are commercially
available and used widely throughout the manufacturing arid processing
industries. The units are generally classified as being either horizontal
or vertical. The vertical chamber has an advantage in that the Incinerator
acts as its own stack. Horizontal incinerators can be easily connected to
tall stacks. A typical land-based industrial liquid injection horizontal
incinerator system operated by General Electric in Pittsfield, Massachu-
settes is shown in Figure 3. This incinerator is used to destroy poly-
chlorinated biphenyls (transformer oil waste) and chlorinated hydrocarbons
from various G.E. plants where they cannot be burned in on-site steam
boilers. Figure 4 is a sketch of a vertical liquid injection incinerator,
one of two units onboard the M/T Vulcanus,^ *^'^an incineration vessel
chartered by Ocean Combustion Services, B.V., Rotterdam, the Netherlands.
This ship has been incinerating European waste in the North Sea since 1972.
The Vulcanus has also bedn successfully used under permit from EPA to
B- 26
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Figure 3. General Electric Liquid Injection Incinerator
(Manufactured by John Zink Co.)
STACK
COMBUSTION
CHAMBER
Figure 4. Dimensional Sketch of Vulcanus Incinerator
B- 27
-------
destroy organochlorine wastes in the Gulf of Mexico and Herbicide Orange
in a remote area of the Pacific Ocean. Each incinerator has a capacity of
40 MM kcal/hr. Location of the incinerators onboard the ship is shown in
Figures 5 and 6
Liquid injection incinerators are flexible units which can be used to
dispose of virtually any combustible liquid waste with a viscosity less
than 10,000 Saybolt Seconds Universal (SSU), the maximum practical for pump-
ing. Viscosity can be controlled by solubilizing the waste in a lower-
viscosity liquid on shore before transferring the waste to the ship, or
by heating the waste feed with in-line heaters on-board ship. However,
200-260°C (400-500°F) is normally the limit for heating to reduce viscosity
due to pump limitations. Heating of hazardous materials to higher temp-
eratures may also increase risk onboard ship.
Before a liquid waste can be combusted, it must be converted to the
gaseous state. This change from a liquid to a gas occurs inside the
combustion chamber and requires heat transfer from the hot combustion
product gases to the injected liquid. The heart of any good liquid incin-
erator is the atmomization device or nozzle (burner). Efficient and
complete combustion is obtained only if the waste is adequately divided
or atomized and mixed with the oxygen source. To achieve fine enough
atomization, the wastes should have a viscosity of 750 SSU or less. Atom-
ization is usually achieved mechanically using rotary cup or pressure
atomization systems. Since rotary cup burners can usually accommodate
more viscous wastes and some solid material in suspension in the liquid
waste, they are used on the Vulcanus. Each incinerator on the Vulcanus
has three vortex type rotary cup burners, located as shown in Figure 7.
Steam or air pressure can also be used for atomization; however, separate
systems to supply pressurized air or steam would have to be provided on-
board ship.
The major components of an incineration system include one or more
liquid and/or auxiliary fuel burners, a primary air blower, one or more
secondary air blowers, and an emergency relief stack, in addition to the
refractory lined combustion chamber itself. Liquid waste incinerators
B- 28
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ro
i
ro
Each Incinerator:
120 IS3 VOlUiiU:
-",.3 nt diameter * H
12.5 metric ton ,/iif
feed rate
Figure 5. M/T Vulcanus Incinerators
-------
UJ
I
CO
o
Length: 102 m
Beam: 14.4 in
Dead Weight: 4768 mt
—" -.c •
Figure 6. M/T Vulcanus - Incineration Vessel
-------
Figure 7. Incineration System - Burner Locations
operate at temperatures ranging between 820 and 1,600°C (1,500 and 3,000°F),
depending on the requirements of the process. Residence times normally
range from 0.5 to 2 seconds.
Advantages and limitations associated with liquid injection inciner-
ation are:
Advantages
Incinerates wide variety of liquid wastes
Presently utilized for shipboard incineration;
well developed technology and equipment for
both land-based and shipboard incineration
Ability to operate over a wide feed range (high
turndown ratio)
Fast temperature response to changes in the waste
fuel flow rate
Operating temperature up to 1600°C
No moving parts, except for rotating cup burners,
therefore low maintenance
imitations
Wastes must be capable of atomization
Burners susceptible to plugging by solids (problem
minimized by use of rotary cup burners)
3.3.2 Rotary Kiln (6'8'9'10>
Rotary kiln incinerators are versatile units capable of handling
liquid wastes, bulk solids, and containerized waste, separately or combined,
B- 31
-------
Rotary kilns are long, horizontal cylindrical rotating furnaces lined with
firebrick or other refractory in which solids are heated by combustion of
an auxiliary fuel or liquid waste. A typical commercial rotary kiln/after-
burner system operated by Rollins Environmental Services in Deer Park, Texas
is shown in Figure 8. This incinerator system has been used to destroy PCBs
and nltrochlorobenzene production wastes; it can also handle solid wastes
packed in fiber drums^.
A rotary kiln is an efficient incinerator of solids, liquids, sludges,
and tars because of its ability to attain thorough mixing of unburned waste,
fuel and oxygen as it revolves. The waste feed is introduced at the upper
end of the kiln and tumbled by the rotation of the kiln. The kiln is
mounted at a slight angle from the horizontal. The hot products are dis-
charged at the lower end. Fuel and air inlets are located either at the
lower end, resulting in a countercurrent gas/solids flow, or at the upper
end, yielding a cocurrent flow. Cocurrent flow is usually used in incin-
erators. Ash is discharged from the lower end of the kiln into a conveyor
trough containing quench water. High temperature gas seals between fixed
and rotating parts at the discharge end of the kiln are difficult to main-
tain. Therefore, rotary kilns operate at subatmospheric pressure to avoid
combustion gas release. Adjustable and replaceable gas seals are available
for special applications.
The major components of the rotary kiln incineration system include
the kiln, an external mechanical drive mechanism that rotates the kiln,
a ram feed mechanism for solid wastes, an ash quench tank, an afterburner
equipped with an emergency relief stack, and primary/secondary air blowers
for the kiln and afterburner. If only solid wastes are being burned,
auxiliary fuel burners are required in the kiln and the afterburner. Com-
plete combustion of the solids in the kiln is difficult to achieve. The
tumbling action in the kiln results in fine particle entrainment in the
gas stream. Therefore, an afterburner is almost always required for com-
plete combustion. This provides increased gas mixing and additional
residence time for the combustion reactions to occur. Liquid wastes can
be burned concurrently with the solids in the kiln and afterburner, thus
eliminating the need for auxiliary fuels 1n some cases.
B- 32
-------
CONVEYOt
DISCHARGE
SatUMCR WATH
Figure 8. Schematic of Rollins Environmental Services Incinerator
-------
Rotary kiln incinerators are used by industry to destroy both solid
and liquid wastes. Rotary kilns are no longer generally used for muni-
cipal waste disposal. They have been replaced by multiple hearth or by
landfill because of the cost of pollution control. Rotary kilns are also
used by the military to incinerate chemical warfare agents and explosives
such as obsolete munitions. Rotary kilns can be designed to handle con-
tainerized wastes, and are especially effective when the size or nature
of the waste precludes the use of other types of incineration equipment.
Combustion temperatures range from 870° to 1600°C (1600° to 3000°F) de-
pending on the waste material combustion characteristics. Required
residence times vary from seconds to hours {for solids) depending on the
type of waste. Shipboard operation of rotary kilns would require special
mounting and seals to withstand the pitch, roll, and vibration' imposed by
the vessel.
Advantages and limitations associated with rotary kiln incineration
are:
Advantages
0 Incinerates a wide variety of liquids, slurries, tars
and solids, separately or combined
• Feed capability for containerized wastes
• Long residence time for slow burning solids
• Good mixing of unburned waste with air
• Operating temeprature up to 1400°-1600°C
• No moving parts within high temperature area of kiln
• Minimal waste preparation required
• Rotational speed control allows for variations in
feed rate
• Continuous ash discharge
• Wei 1-developed technology and equipment for land
application
B- 34
-------
Limitations
• Higher maintenance costs associated with refractory
maintenance and replacement
• Rotating parts require maintenance and may cause
downtime
t Airborne particles may be carried out of kiln before
complete combustion; therefore, a secondary combustion
chamber is usually required
• Spherical or cylindrical items may roll through kiln
before complete combustion
• Some fusible material may remain in kiln
• Leakage past end gas seals
• Not previously used for shipboard application - special
mounting and gas seals required with shipboard evaluation
necessary
3.3.3 Fluidized Bed (6»8.9,10)
Fluidized bed incinerators can be used to dispose of solid, liquid,
and gaseous combustible wastes. The technique is a relatively new method
for waste disposal and was first used commercfaHy in the United States
in 1962. Fluidized bed incinerators are refractory-lined reactors in which
a bed of inert particulates (usually high silica sand) is supported by a
distribution plate through which air is blown. The upward flow of air
through the sand bed results in a dense turbulent mass which exhibits the
characteristics of a fluid. Figure 9 is a schematic of a commercial flu-
idized bed incineration system built by Dorr-Oliver and operated by Black
and Clawson in Franklin, Ohio^. This incinerator is capable of receiv-
ing light or viscous liquids as well as liquids with high solids content.
Liquid wastes successfully destructed in this incinerator include off-
specification phenol, paint sludge and paint thinners, and oil sludges
from oil reclaimers and oil processors.
Waste material to be incinerated can be injected into the bed with
a pump, a screw feeder, or pneumatically. The strong agitation of the
bed particles by the air promotes rapid and relatively uniform mixing of
the waste material within the fluidized bed.
B- 35
-------
STACK
GAS DUCT
EXPANSION
JOINT
VENTURI
SCRUBBER
Figure 9. Fluidized Bed Facility Schematic (manufactured by Dorr-Oliver)
-------
The mass of the fluidized bed is large in relation to the injected
material. The large thermal heat sink formed minimizes temperature var-
iations. Heat is transferred from the bed to the waste materials. Upon
reaching ignition temperature (which takes place rapidly) the materials
combust and transfer heat back to the bed. Continued bed agitation by
the fluidizing air allows larger waste particles to remain suspended until
combustion is completed or until they become small and light enough to be
carried out of the bed with the flue gases as particulates. These gases
are scrubbed before they are discharged to the atmosphere.
Gas velocities which are a function of particle size are typically
low, from 1.5 to 2.4 m/s (5 to 8 ft/s). Bed depths range from about 40 cm
to a few meters (16 inches to several feet). Variations in bed depth
affect waste particle residence time and system pressure drop. Solids have
a longer residence time than gases or liquids. Bed temperatures are quite
uniform and are in the range of 760° to 870°C (1400° to 1600°F). Bed
temperatures are restricted by the softening point of the bed material
to avoid agglomeration of the bed particles. In addition, formation of
fusible ash can agglomerate the bed.
Advantages and limitations associated with fluid bed incineration
are:
Advantages
• Incinerates granular solids, slurries, liquids, and gases
• Uniform temperatures, high heat transfer rate to waste
• High volumetric heating rates
• ho moving mechanical parts, low maintenance
• Relatively low excess air requirements
• Solids remain in bed until combusted
• Fluctuations in feed can be tolerated because of the
large heat sink available
B- 37
-------
Limitations
• Not suited for bulky, irregular wastes or tarry solids
which may plug bed
• Waste selection must avoid bed damage such as the
formation of an eutetic
• Operating temperature in bed limited to 870°C to avoid
agglomeration of particles (free board may be 980°C)
• Difficult to remove residuals from bed
• High power consumption for blower, high operating costs
• Additional equipment needed for removal of fine entrain-
ed particles
• Bed material replacement required due to attrition
3.3.4 Molten Salt*8'9'10)
Molten salts have long been used in the metallurgical industry to
recover metals, especially aluminum, and in the heat treating of metals.
Molten-salt systems (Figure 10) have only recently been developed to pilot-
plant and demonstration scale for the destruction of organic waste com-
pounds by the Atomics International Division of Rockwell International.
Rockwell's test units have demonstrated that the process 1s capable of
destroying chlorinated organics (such as PCBs), pesticides, and chemical
warfare agents.
Figure 10, Atomics International Div., Molten Salt Reactor
B- 38
-------
In the basic molten salt concept for waste disposal tine waste is in-
jected below the surface of a molten salt bath. Usually the molten salt
bath is cpmposed of approximately 90 percent sodium carbonate and 10 per-
cent sodium sulfate and_ is designed for operation in the range of 620° to
980°C (1,500° to 1,800°F). Substitution of other salts, such as potassium
carbonate, allows for even lower incineration temperatures. The use of
reactive salts, such as the eutetlc mixtures NaOH-KOH and l^COj-^CO^-
K2C03, produces the additional benefit of entrapping potentially toxic
or objectionable offgas constituents such as heavy metals (mercury, lead,
cadmium, arsenic, selenium}. This reduces or eliminates the need for
pollution-abatement equipment.
Wastes such as free-flowing powders and shredded materials may be
directly fed to molten-salt incinerators. Waste liquids may be sprayed
into the combustion air and fed to the unit. The chemical reactions of
the waste with salt and air depend on the waste composition. The carbon
and hydrogen of the waste are converted to CO2 and steam; halogens form
their corresponding sodium halide salts; phosphorus, sulfur, arsenic, and
silicon (from glass or ash in waste) form oxygenated salts; and the iron
from metal containers forms iron oxide. Any char is completely consumed
in the melt. The ash 1s trapped in the melt. The products of destruction
build up in the melt and must be removed. On land, the spent salt
can be regenerated or may be land disposed. However, at-sea handling of
the high temperature, caustic spent salt may pose a safety problem. The
advantages and limitations of molten salt incineration are:
Advantages
• Incinerates liquids, slurries, and shredded solids
• Particulates and contaminants remain 1n the melt
• Rapid and complete destruction of carbonaceous material
• Compactness and potential fuel efficiency predicted
Limitations
• Not commercially used - only pilot scale demonstration
unit
B- 39
-------
• Operating temperature in bed limited to 820°-980°C
• Safety problem associated with accidents 1n handling of
molten salts onboard ship
3.3.5 Other Incinerator Types(7'8,9)
Three other Incinerator types, multiple hearth, multiple chamber, and
starved air, were reviewed with regard to their potential for at-sea incin-
eration of hazardous wastes. The multiple hearth incinerator (Figure 11)
has been utilized to dispose of sewage, sludges, tars, solids, gases, and
liquid combustible wastes. It is most commonly used for sewage plant
sludge disposal. The multiple hearth furnace consists of a refractory-
lined circular steel shell with refractory hearths located one above the
other. Sludge and/or granulated solid combustible waste 1s fed through
the furnace roof by a screw feeder or belt and flapgate. Liquid and gas-
eous combustible wastes may be injected into the unit through auxiliary
burner nozzles. A rotating air-cooled central shaft with air-cooled
rabble arms and teeth plows the waste material across the top hearth to
drop holes. The waste falls to the next hearth and then the next until
WASTE AIR TO CLEAN GASES TO
ATMOSPHERE ATMOSPHERE
Figure 11. Multiple Hearth Incineration System
B- 40
-------
ash discharges at the bottom. The waste is agitated as it moved across
the hearths to make sure maximum surface is exposed to hot gases. Air
from the main blower follows a path countercurrent to the solids, flowing
up from the bottom and across each hearth. Before it is injected at the
bottom hearth, however, this air is passed through the central shaft and
preheated while cooling the shaft.
The multiple hearth incinerator is usually operated so that the top
hearth temperature is in the 315° to 540°C (600° to 1000°F) range, the
combustion hearths are in the 760° to 980°C (1400° to 1800°F) range, while
the ash cooling hearths are maintained in the 200° to 315°C (400° to 600°F)
range. Solid retention times in multiple hearth furnaces typically range
from 15 to 90 minutes. Scrubbers are required for most applications, and
afterburners are used following some mu-ltiple hearth furnaces.
Advantages and limitations associated with multiple hearth incinera-
tion are:
Advantages
• Incinerates sludges and granular solids
• Long solids residence time
• Air preheated by passage through central shaft before
injection into hearth
• Large quantities of water can be evaporated
• Well-developed technology and equipment for sludge
disposal
Limitations
• High maintenance cost because of moving parts in
combustion zone
• Grates plugged by fusible ash
• Internal mechanical parts 1imit operating temperature
to 1000° - 110Q°C
• Less solids/air contact compared to rotary kiln and
fluidized bed
• Possibility of some bypassing due to the closeness
of the inlet and output ports
B- 41
-------
Another incinerator system reviewed with regard to at-sea incinera-
tion of hazardous wastes was the multiple chamber incinerator (Figure 12).
Multiple chamber incinerators are used industrially for the disposal of
bulky, solid wastes such as refuse, scrap wood, and paper, and chemical
wastes such as resins and PVC plastics. They are usually not suitable for
handling slurries, sludges, or flowable solids which fall through the
grate without special modifications. It is also possible to burn liquid
wastes by injecting the liquid with the auxiliary fuel.
Multiple chamber incineration takes place in two stages: primary or
solid fuel combustion occurs in the ignition chamber, followed by secondary
or gaseous-phase combustion. Solid wastes are either manually or auto-
matically fed into the incinerator through charging doors onto grates at
the bottom of the ignition chamber. Here, the wastes are dried, ignited,
volatilized, and partially oxidized into gases and particulates. As more
waste is charged to the system, the pile of burning waste is pushed farther
along the hearth toward the ash pit. The moisture and volatile components
of the fuel pass from the ignition chamber through the flame port to the
mixing chamber. Here, the gases are mixed with secondary air, heated by
auxiliary fuel firing (if necessary), and subjected to abrupt changes in
direction to promote turbulent mixing. After expansion and contraction
through a series of ducts, the gases pass into the upflow secondary com-
bustion chamber where the oxidation reactions go to completion. Fly ash
is also collected in this chamber by wall impingement and settling and is
removed through ports in the chamber wall.
There are two basic types of multiple chamber incinerators, both of
which are shown in Figure 12. The first is the retort type, where the
arrangement of the chamber causes the combustion gases to flow through
90° turns in both lateral and vertical directions. This arrangement per-
mits the use of a common wall between the primary and secondary combustion
chambers. The retort type is used for the small capacity systems because
of its simple box-like construction and reduced exterior wall length. It
performs more efficiently than its in-line counterpart in the capacity
B- 42
-------
SECONDARY
AIR PORTS MIXING
a. Retort Type
IGNITION
CHAMBER
FUME
PORT
CHARGING DOOR
WITH OVERFIRE
AIR PORT
SECONDARY
AIR PORT ^CURTAIN WALL
GRATES
SECONDARY
COMBUSTION
CHAMBER
CLEANOUT DOORS WITH
UNDERGRATE AIR PORTS
LOCATION OF
SECONDARY
BURNER
MIXING
CHAMBER
CLEANOUT
DOORS
CURTAIN
WALL PORT
b. In-Line Type
Figure 12. Multiple Chamber Incinerator
B- 43
-------
range from 23 to 340 kg (50 to 750 lb) per hour. The other type of multi-
ple chamber incinerator is the in-line type, where the flow of the com-
bustion gases is straight through the incinerator with 90° turns only in
the vertical direction. The in-line arrangement gives a rectangular plan
to the incinerator and is readily adaptable to installations which require
variation in sizes of either the mixing or the combustion or ignition
chambers. All ports and chambers extend across the full width of the
incinerator and are as wide as the ignition chamber. It is the more
efficient multiple chamber incinerator at capacities greater than 450 kg
(1000 1b) per hour.
Advantages and limitations associated with multiple chamber inciner-
ation are:
Advantages
• Incinerates a wide variety of wastes including bulky solids
• Extensive waste preparation not required
• Considerable flexibility in feed rates depending
on type of multiple chamber incinerator used
• Operating temperature up to 1000°C
• Well-developed technology and equipment for solid
disposal
Limitations
• Less solids/air contact compared to rotary kiln and
fluidized bed
• Auxiliary fuel firing generally needed when moisture
content of wastes exceeds 2055
• High excess air rates required for good air/waste
mixing
• Grates and drive mechanisms exposed to high tempera-
ture and abrasion, increasing maintenance costs
The final Incineration system considered was a starved air combustion
system. Starved air combustion uses equipment and process flows similar
to incineration except that substolchiometrlc amounts of air are fed. The
process combines pyrolysis and oxidation reactions. One application of
B- 44
-------
starved air combustion is the multiple hearth reactor used in a starved
air mode. The reactor gasifies the solid or sludge feed, producing a
combustible gas which is burned in an afterburner. Starved air systems
have high thermal efficiencies; however, the insufficient oxygen supply
can increase the probability of forming hazardous byproducts. Combustible
gaseous emissions are undesirable and must be treated in an afterburner.
Advantages and limitations associated with starved air combustion
are:
Advantages
• Potential for byproduct recovery
• High thermal efficiency and capacity/unit size
Limitations
• Not tested on hazardous chemical wastes
• Use of substoichiometric quantities of oxygen in-
creases the probability of hazardous byproduct
formation
t Afterburner required to burn combustible effluents
3.3.6 Design Discussion
Major characteristics of the incinerator types evaluated for ship-
board at-sea application as described in the previous sections are com-
pared in Table 3. Capability of each incinerator to destroy different
types of waste material is noted in the table, along with maximum opera-
ting temperature, relative maintenance requirements, and present commer-
cial application. Relative sizes and capacities of existing units for
most of these incinerator types are shown in Figure 13.
The liquid injection incinerator can be used only for pumpable
liquids; however, it is the most effective means of incinerating liquid
wastes at high feed rates, and is capable of attaining the temperature
required (up to 1600°C) for highly efficient destruction of toxic mater-
ials. It can also be utilized as an afterburner for a solid waste incin-
erator. Maintenance of this incinerator is low because there are no
B- 45
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TABLE 3. COMPARISON OF CANDIDATE INCINERATOR TYPES FOR SHIPBOARD AT-SEA APPLICATION
Liquid
Rotary Fluidized Molten Multiple
Multiple
Starved
Injection
Kiln
Bed
Salt
Hearth
Chamber
A1r
Waste Types
Pumpable liquids
X
X
X
X
X
X
X
Slurries, sludges
X
X
X
X
X
Tars
X
X
X
Sol ids
granular
X
X
X
X
X
irregular
X
X
containerlzed
X
X
Maximum Operating
1600
1600
980
980
1100
1000
820
Temperature, °C
Maintenance
low(a>
Md(b'
¦Kdt'Xc)
med(a)(d)
high^
»ed
h1gh*e)
Applications
widely used^
widely used,
limited use
, demon-
widely used, widely used,
resource
liquid wastes
all wastes
sludges and
stration
sewage
refuse
recovery
organic
tests only sludge
wastes
*a^No moving parts in high temperature zone
(b)
Bearing and seal modifications required
^Ash removal and bed replacement required
(d)
Salt recycle or replacement required
Til
(f)
Moving parts in high temperature zone
Liquid injection incinerators are the only
type that have been successfully utilized
for shipboard at-sea operation.
-------
S.5 MO X 10.4M HIGH
STACK
/
u
SECONDARY
COMBUSTOR
\
COMBUSTION
CHAMKR
LIQUID INJECTION - VULCANUS
(EACH OF 2 INCINERATORS)
40 MM KCAL/HR
3.2 M0 X 4.9M LONG
SCALE: I I I I I I t I I I I
5M
10M
4.0 M X 4.3M X 10 7M LONC
AFTERBURNER
E
2.0 M0 X 8.2M HIGH 1 & M0 X 4.9M LONG ROTARY KILN - ROLLINS
n
2t MM KCAL/HR
Y
MOLTEN SALT
ROCKWELL INTERNATIONAL
0.1« MM KCAL/HR 5.5 M0 X 9.1M HIGH
JL
REACTOR
1.9 M0 X 10.1M HIGH
-/ v v '¦*
AFTERBURNER /
4.9 X 4.6MHIGHf—
t ~
MULTIPLE HEARTH - ENVIROTECH
20 MM KCAL/HR
2.1 M0 X
6.1M LONG
FLUIDIZED BED - SYSTEMS TECHNOLOGY
16 MM KCAL/HR
THERMAL REDUCTION SYSTEM - CINCINNATI
I KCAL/HR
2.7M0 X
8.1M LONG
Figure 13. Relative Sizes and Thermal Capacities of Currently Used
Incinerator Types
-------
moving parts within the high temperature zone (except for rotary cup
atomizers, which are cooled by the waste feed). Liquid injection incin-
erators are widely used in commercial applications, including shipboard
at-sea incineration of hazardous materials.
Rotary kilns are the most versatile incinerators available, capable
of handling any combination of liquids, slurries, tars, or solids, includ-
ing containerized wastes. Temperatures as high as 1600°C can also be
attained in the kiln. Rotary kilns represent well proven technology for
land based incineration; however, use at sea would be a new application.
Shipboard operation would require special mounting and seal modifications
to withstand pitch, roll, and vibration conditions at sea. The kiln can
be mechanically locked in place during storms. Maintenance would be higher
than for a liquid injection system without a rotating drum and seals.
Flu1d1zed bed incinerators are more limited than rotary kilns 1n range
of feed materials* as Indicated 1n Table 3, and are not suited for Irregular
solids or tarry substances which may plug the bed. Maximum operating
temperatures are limited to 980°C to avoid fusion of the silica sand bed
material. Higher temperatures of 1200°C are possible using alumina refractory
particles as the bed material. Maintenance Includes ash removal and replace-
ment of the bed when necessary. Pitch and roll of the ship, particularly
during storms, would cause shifting of the large mass of bed material both
during Incineration and when shut down. The bed will retain heat for restart
during shutdowns up to one day duration, then gradual reheating of the bed
is required for start-up. If the bed should become fused or plugged, the
unit must be shut down for cleanout and bed replacement.
Molten salt reactor pilot and demonstration units have been used to
destroy liquid, slurry, and granular solid waste materials; however, no
commercial units are presently in operation. Operating temperature of
the salt bed is limited to 980°C. Pitch and roll of the ship will cause
sloshing of the molten salt within the reactor. A potential advantage of
this system is that it can serve as a combined incinerator/scrubber by
retaining particulates and contaminants in the bed; however, this neces-
sitates salt recycle or replacement. The salt bed must also be removed
B- 48
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from the reactor before solidification during shutdown. A spill of the
hot, caustic salt containing toxic contaminants would be dangerous to
shipboard personnel.
Multiple hearth incinerators are widely used for sewage sludge dis-
posal, but can also destroy granular solids and liquids (injected through
the auxiliary fuel nozzles). Operating temperatures are limited to 1100°C
because of the internal mechanical components (rotating shaft, rabble arms,
etc.). Maintenance of internal moving parts would be high because of ship
motion as well as thermal stress. Also, the presence of any fusible ash
may render the system inoperable until cleaned out.
Multiple chamber incinerators are used extensively for industrial
disposal of bulk solid wastes. Liquid wastes can be injected with the
auxiliary fuel. Slurries and sludges would fall through the incinerator
grates and are not suitable for this incinerator. Solids/air mixing is
not as thorough as in rotary kilns, and high excess air rates are required,
resulting in reduced operating temperatures of approximately 1000°C.
A number of incinerator designs, including multiple hearths, can be
operated as "starved air" combustors by restricting air input less than
the amount required for stoichiometric conditions. Starved air systems
have high thermal efficinecies; however, hazardous byproducts may be
formed without sufficient oxygen for complete reaction, and an afterburner
is required to burn combustable emissions. Use of this mode of incinerator
operation is usually limited to byproduct recovery from sludges or solids.
Based upon this engineering study, the incinerator design recommenda-
tions for shipboard at-sea application are:
1) The liquid injection incinerator, which has been proven
for at-sea shipboard operation and can dispose of liquid
wastes at high feed rates, is recommended for the pro-
posed vessel. This incinerator will also serve as an
afterburner for the solids incinerator.
2) A rotary kiln is recommended as the most versatile
incinerator, capable of disposing of all waste types at
high temperature. A standard commercially available
B- 49
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kiln should be installed for evaluation tests. Mod-
ifications to the standard kiln mounting and seals are
required for shipboard operation.
The molten salt reactor, because of its potential for
retaining particulate and contaminants in the melt,
should be considered for further evaluation and development
testing on land. This system is not sufficiently proven
commercially to be selected as a solids Incinerator for
shipboard at-sea application. Also, a spill of molten salt
would be dangerous onboard ship.
Fluidized bed, multiple hearth, multiple chamber, and
starved air incinerators are all limited in operating
temperature and waste type handling capability compared
to the rotary kiln. None of these incinerator types
are recommended for shipboard application.
B- 50
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3.4 WASTE FEED SYSTEMS
The function of the shipboard waste feed system is to retrieve the
waste from its storage hold and transport it at a steady rate to the
incinerator without spillage. This must be accomplished safely under
the vibration, roll, pitch, and heave conditions encountered during
shipboard operations. The type of feed system required will depend on
the characteristies of the waste material, the nature of the storage,
and the type of incinerator.
3.4.1 Liquids
Liquid wastes with a viscosity less than approximately 10,000 SSU,
the maximum usually allowable for pumping, can be transported aboard
ship and fed to the incinerator(s) by conventional pumps, piping, and
valves. Higher viscosity liquids can be pumped by adding heat; however,
this method would be more complex and potentially hazardous onboard
ship than on land. A preferred method of reducing waste viscosity
would be to solubilize the waste in a lower viscosity liquid, such as
fuel oil or waste solvents.
Gas blanketed storage tanks should be utilized to contain the
wastes prior to incineration. Lined tanks, piping, and pumps should be
considered for compatability with corrosive materials. Coatings which
might peel or flake off and plug pumps and burners must be avoided.
Some particles can be crushed by masticating-type pumps. Solid
particles up to 5 cm. in diameter can be crushed by "gorators" such as
those in the feed system of the M/T Vulcanus ^>2,7) ^
Incinerator burners should be designed for cleanout while the
incinerator is operating. This requires multiple burners in each
incinerator, so that one burner can be retracted and cleaned while
others are maintaining required waste destruction temperatures.
Flowmeters are available for monitoring liquid feed rates onboard
ships. Two types of meters, vortex and ultrasonic, have been successfully
tested onboard the M/T Vulcanus^ during incineration of hazardous
materials. Either of these meters is suitable for incineration vessels.
B- 51
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3.4.2 SI lories
Slurries and sludges can be transported like liquids If pumpable.
Only those slurries which do not settle out to compact cakes or whose
settled cakes can be readily redlspersed should be considered suitable
for shipboard transit. All other slurries should be handled in a
fashion similar to solids. In fact, 1t would be safer to regard all
questionable slurries as solid materials rather than risk clogging up a
feed system, with the resultant down time and cleanup requirement.
3.4.3 Bulk Sol Ids
Waste sol Ids can be expected to be of any size, shape, and hardness,
and to be wet with volatile, hazardous liquids. Enclosed screw feeds and
conveyors, which work well on land with dry, granular solids, cannot be
expected to handle Irregular, wet sol Ids 1n rough seas without clogging.
Such sol Ids should be loaded Into sealed, transportable containers which
can be lifted Individually to a charging port on the incinerator and
dumped through a sealed connection. Ash from the Incinerator can be loaded
into the empty containers for land disposal.
Standardized containers, as shown in Figure 14, are commercially
available. These containers each hold the same volume as 10 standard
55 gallon steel drums, and are transportable by truck or rail car. Auto-
mated systems can be provided to move these containers from the ship's
hold and lift them to a sealed unloading device (Figure 15) mounted on
the incinerator charging port.
3.4.4 Containerized Sol ids
Irregular, nonhcmogeneous solIds or slurries which tend to settle
into compact cakes can be pre-packaged into containers small enough to
be charged whole Into a rotary kiln incinerator. Standard fiber drums,
with metal rims, of approximately 30 gallons capacity are commonly used
for land based incineration operations. Drum liners are available to
seal wet wastes within the container. Automated systems can also be
developed to transfer fiber drums from storage holds to Incinerator
charging ports. Care must be exercised to prevent puncturing and
resultant leakage from fiber drums.
B- 52
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Figure 14. Bulk Material Container
B- 53
-------
Figure 15. Bulk Material Container and Unloading Device
B- 54
-------
3.4.5 Recommendations
The recommended feed system for liquid wastes is similar to that
presently used onboard the M/T Vulcanus, consisting of tanks, pumps
(including masticating devices capable of crushing reasonably-sized
solids), and plumbing enabling any burner to be fed by any tank onboard
the ship. In addition, gas blanketed storage tanks and lined tanks should
be used. Liquid waste flowmeters are also recommended^. Some
slurries, which are pumpable and do not settle out, may be handled as
liquids; however, 1t 1s safer to treat any questionable slurries as
solids to avoid system plugging and costly downtime and cleanup.
Solids can best be handled by loading wastes into sealed containers
on land. These containers may be small enough to be fed directly into
the incinerator, or bulk containers may be used which can be fed into
the charging door through a sealed connection. These bulk containers can
be used to store and transport ash for disposal on land. Handling of
55 gallon steel drums, particularly potential leakers, and shredding
operations Involve too much risk to be performed onboard ship.
Proposed technical guidelines for incineration at sea^11^ state that
damaged containers should not be taken on board. Liquids or vapors from
leaking containers present danger of fire or explosion onboard ship or
during loading.
B- 55
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3.5 EMISSION CONTROL DEVICES
In this section emission control systems suitable for removing gaseous
and particulate contaminants from incineration of hazardous wastes at sea
will be identified. Major advantages and disadvantages of each system will
be discussed.
Control equipment commonly considered suitable for the reduction of
particulate and gaseous emissions from combustion sources includes wet
scrubbers, electrostatic precipitators, and fabric filters. These systems
can also be applied to control emissions from hazardous waste incineration.
In addition, molten salt scrubbers offer some unique advantages for at-sea
incineration of hazardous wastes aboard ship although their use is not as
common as the other three scrubber types. To date, the use of wet venturi
and packed bed scrubbers has been predominant in controlling emissions
from combustion of solid and liquid wastes in hazardous waste incineration
facilities. Aboard ship, a different set of criteria will govern selection
of the most appropriate scrubber system. These criteria will be reflected
in the following discussion of the four most applicable types.
3.5.1 Electrostatic Precipitators (13}
Electrostatic precipitators (ESPs) have been widely used in control-
ling particulate emissions from utility boilers. They are not generally
used for the more corrosive gas streams associated with hazardous waste
incineration. Both wet and dry operation is possible with ESPs. Dry ESPs
remove only particulate emissions, while wet ESPs are also capable of
removing some gaseous emissions.
Figure 16 depicts a typical dry ESP. The dimensions shown are for an
inlet gas flowrate of 140,000 actual m^/hr (83,000 ACFM) at 177°C (350°F)
3
and an inlet grain loading of 300 mg/m assuming 95 percent removal .
Electrostatic precipitation is a process by which particles suspended
in a gas are electrically charged and separated from the gas stream. In
this process, negatively charged gas ions are formed between emitting and
collecting electrodes by applying a sufficiently high voltage to the
emitting electrodes to produce a corona discharge. Suspended particulate
natter is. charged as a result of bombardment by the gaseous ions and
B- 56
-------
OUTER DIMENSIONS
WIDTH =6.4 m (21 ft)
HEIGHT {inc. hoppers) = 13.1m (43 ft)
LENGTH = 13.4 m (44 ft)
ELECTROSTATIC FIELD
COLLECTION ELECTRODES
PARTICULATES
EXPLODED VIEW
DIRTY AIRSTREAM
CLEAN AIRSTREAM
^ \
DISCHARGE ELECTRODES
Figure 16. Electrostatic Precipitator
B- 57
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migrates toward the grounded collecting electrodes due to electrostatic
forces. Particle charge is neutralized at the collecting electrode where
subsequent removal is effected by periodically rapping or rinsing the
electrode. A majority of industrial ESPs used today are the single-stage,
wire and plate type; charging and collection take place in the same section
of the ESP. Two-stage ESPs, often called electrostatic filters, utilize
separate sections for particle charging and collecting, and are not gener-
ally employed for controlling particulate emissions from combustion sources.
The wet ESP is a variation of the dry electrostatic precipitator de-
sign. The wet ESP overcomes some of the limitations of the dry ESP. The
operation of the wet ESP is not influenced by the resistivity of the
particles. Further, since the internal components are continuously being
washed with liquid, buildup of tacky particles is controlled and there is
some capacity for removal of gaseous pollutants. In general, applications
of the wet ESP fall into two areas: removal of fine particles, and removal
of condensed organic fumes. Outlet particulate concentrations are typically
3
m the 2 to 35 mg/m range.
The two major added features in a wet ESP system are: 1) a precon-
ditioning step, where inlet sprays in the entry section are provided for
cooling, gas absorption, and removal of coarse particles, and 2) a wetted
collection surface, where liquid is used to continuously flush away
collected materials. Particle collection is achieved by introduction of
evenly distributed liquid droplets to the gas stream through sprays located
above the electrostatic field sections, and migration of the charged
particles and liquid droplets to the collection plates. The collected
liquid droplets form a continuous downward-flowing film over the collection
plates, and keep them clean by removing the collected particles. To con-
trol the carryover of liquid droplets and mists, the last section of the
wet ESP is often operated without continuous sprays, so that electro-
statically charged liquid droplets cannot penetrate and mists can be
collected by baffles.
Although dry ESPs have been in operation for a long time, wet ESPs
are relatively new and are not commonly used.
B- 58
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Advantages and limitations of ESPs as applied to hazardous waste
incineration at-sea are listed below:
Advantages
» High removal efficiency for particles < lym in diameter
• Potential removal of heavy metals
• No waste sludge generated by dry ESP
• Low pressure drop (<2.5 kPa or 1.0" H-0)
• Low power requirement (0.4-0.7 KW/m /sec}
• Some commercial incinerator applications, but not with
corrosive gas streams
• Wet ESPs remove some gaseous components .
• Wet ESPs control tacky particle buildup.
• Wet ESPs not affected as significantly by particle re-
sistivity
Limitations
• Separate primary collection required for removal of particles
> 1pm in diameter
• Low resistivity materials not readily removed
• Most efficient at constant conditions (10* increase in flow
yields 50% increase in emissions for 99% efficient ESP)
• Corrosive gases may deteriorate electrodes, shell, rapper
rods, high voltage frame, and gas distribution plates
• Anti-corrosion materials very costly
• Demister may be required for wet ESP
• High capital costs compared to wet scrubbers
• Extensive pilot testing required for hazardous waste incin-
eration application
• Constant motfon and vibration of shfp could cause electrical
shorting to occur frequently
• Dry ESP has no capability for removing corrosive gases; wet
ESP has limited capability
• Very heavy 100 metric tons)
3.5.2 Fabric Filters (13)
In general, fabric filters are capable of removing only particulate
emissions; however, by incorporating dry sorption principles into the
design of fabric filter systems, some gaseous pollutants can also be re-
moved. Figure 17 depicts a typical fabric filter. The dimensions shown
B- 59
-------
Figure 17. Fabric Filter
B- 60
-------
are for the same baseline conditions given in Section 3.5.1, except that
greater than 99 percent particulate removal can be expected.
Fabric filter systems consist of a filter surface made of woven natural ,
synthetic or glass fibers through which the flow of dust laden gas is
directed. Particles are collected on the upstream filter surface and in
the interstices of the fabric, by inertial impaction, interception and
diffusion, while the cleaned gas passes through. The collected dust layer
also acts as a filter medium although periodic removal 1s required to
maintain an acceptable unit pressure drop and flow rate. The filter surface
is generally a system of tubular bags although rectangular envelopes are
also used. Dust retained on the fabric is periodically shaken or blown
off and falls into collection bins for subsequent disposal. Fabric filters
are high efficiency particulate emission control devices and typically
provide removal efficiencies exceeding 99 percent with pressure drops
ranging from 0.5 to 2 kPa (2 to 8 in ^0).
Dry sorption as discussed here Involves contacting the gas stream
with a solid phase that has the property of selectively removing one or
more of the gaseous contaminants. Two types of dry sorption process have
potential application for gaseous emission control in hazardous waste
incineration facilities: 1) adsorption, and 2) adsorption followed by
chemical reaction.
Adsorption--For gaseous emission control by adsorption devices, physical
adsorption is the primary mechanism for contaminant removal. Characteristi-
cally, the adsorbate molecules diffuse from the gas phase across a boundary-
layer to the surface of the adsorbent, where they are held by fairly weak
physical (van der Waals) forces. Commercially important adsorbents include
activated carbon, and simple or complex oxides typified by aluminum oxide,
silica gels, fuller's, diatomaceous, and other siliceous earths, and
molecular sieves. Activated carbon is effective 1n adsorbing organic
molecules. The oxygenated adsorbents, on the other hand, show much greater
affinity for polar than for nonpolar molecules, and therefore, will not be
effective in adsorbing organic contaminants.
B- 61
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Adsorption devices are riot currently used for gaseous emission control
at hazardous waste incineration facilities. This can be attributed to
several limitations of adsorption processes. At high concentrations of
gaseous contaminants, the accumulated heat of adsorption may raise the
temperature of the adsorbent bed to a level that impairs its adsorbent
capacity. Additionally, high gaseous contaminants levels will lead to
rapid saturation of the adsorbent. Particles and water vapor act as
obstructants to adsorption of gaseous contaminants. Gas stream tempera-
tures above 38°C (100°F) may cause significant reduction in adsorbing
capacity. Incinerator exhaust gases must therefore be pretreated and pre-
cooled for removal of the major portion of gaseous and particulate
contaminants, along with lowering of gas stream temperature and humidity,
before adsorption processes can be considered. Conceivably, at a dedicated
facility for incineration of highly toxic materials, adsorption can be
added as the last polishing stage of a gas cleanup system to remove any
possible last traces of contaminants.
Adsorption with chemical react1on--A much more promising method for simultan-
eous gaseous and particulate emission control is to inject solid reagents,
or fine sprays of solutions or slurries containing the reagents into the
gas stream, followed by collection of the reacted dry sorbent material on
fabric filters or electrostatic precipitators. When fabric filters are
used, an added advantage is that, the amount of reagent required can be
based on average emission levels, since surges In emission levels can be
handled by unreacted reagents retained In the bags. Although there are no
hazardous waste incineration facilities that currently employ this method
to control gaseous and particulate pollutants, similar experiences with
treating effluents from coal-fired boilers, glass furnaces, secondary
aluminum smelters, and municipal Incinerators, as discussed here, are
directly applicable.
Advantages and limitations of fabric filters as applied to hazardous
waste incineration at-sea are listed below:
6-62
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Advantages
• High particulate collection efficiency, >99%
• Up to 95% removal of particles <0.1 vm in diameter
• Removal of heavy metals
• No sludge or liquid wastes
• No liquid freezing problems
• Low pressure drop (0.25 to 2 kPa or 1 to 8" HgO)
• Can include dry sorbent injection to remove gaseous pollutants
Limitations
• Gas cooling required prior to f&bric filtration; maximum
temperature of 290°C although more practical limit for
halogenic contaminants is about 95°C
• High efficiency demisting required after prefiltration cooling
with water
• Fabric life reduced by acid or alkaline particles
• Fabric blinding caused by acid mists, condensed moisture,
tars, tacky particlest and deliquescent organics
• Not capable of appreciable removal of gaseous pollutants
without extensive modification
• Removal of damaged filters may require protective clothing
and respirators for personnel
• Relatively large system, high costs
• If dry sorbent reactant used, storage required; storage and
disposal required for waste cake and spent materials
• No commercial experience with hazardous waste Incineration
• Very heavy Vl 50 metric tons
3.5.3 Molten Salt Bath (14, 15)
A relatively new entry Into scrubber technology is the molten salt
scrubber as shown in Figure 18. Currently, only Anti-Pollution Systems,
B- 63
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DIRTY GAS IN
Inc. (APS) offers a molten salt scrubber for emissions from hazardous
waste incinerators. A pilot scale combined molten salt incinerator/scrub-
ber has been developed and commercialized by Atomic International Div. of
Rockwell International, Inc. (AI). AI no longer offers a molten salt
scrubber.* APS has also pilot tested a combined incinerator/scrubber unit
on chlorinated hazardous wastes with, reportedly, excellent results. APS
further reports that five units are currently in operation.' In this
section, only the APS molten salt scrubber unit is discussed.
The APS molten salt scrubber is capable of removing high levels of
particulate and gaseous emissions in a single bath. In choosing the bath,
it is important that the salts do not themselves chemically interact with
any of the waste gases. In that way the salts that are used become a
permanent part of the system and need never be replaced. Since hazardous
Telephone conversation between TRW and Dr. Gehri, Rockwell International,
Inc., Canoga Park, CA, 4/8/80.
4.
Telephone conversation between TRW and Dr. Jacob Greenberg, APS Inc.,
Pleasantville, N.J., 4/21/80.
B- 64
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wastes may contain a variety of reactive materials 1t is necessary, 1n such
an uncontrolled situation, to find a salt bath of high thermodynamic
stability. In these instances mixtures of alkali sulfates are used. In
order to lower the melting point of the mixture, lithium sulfate is
included. This addition not only forms a melt at 477°C but also Inhibits
the adsorption of water under ambient conditions. The reason for this 1s
that the lithium sulfate forms a stable monohydrate that does adsorb
continuously. It is important that the salts be dry upon rapid heating In
order to prevent some hydrolysis from occurring. In other salt media the
adsorption of water 1s obviated by simply keening the salts at a tempera-
ture above ambient.
Although the initial salt charge 1s a permanent part of the system
and is never changed, the salt has to be cleaned periodically of carbon,
inert materials and compounds that have been formed 1n removing noxious
products. There 1s a paucity of Information on scrubber bath operation,
regeneration times and regeneration steam requirements. At least 10 hours
of continuous scrubbing would be required aboard ship for this process to
be feasible.
During regeneration, carbon may be removed mechanically or by fl^jino
steam through the molten salts. Steam reacts with carbon 1n the bath at
593°C to form carbon monoxide and hydrogen (the water gas reaction). Inert
materials, such as aluminates and silicates, are insoluble and sink to the
bottom where they can be removed mechanically.
In those Instances where the salt bath 1s used as a reaction medium
in which sulfur or nitrogen oxides are combined with a metal oxide there
1s a continuous removal of reaction product. (15)
In the design of the system it has been found easier to bring materials
to the salt bath rather than to spray or circulate the molten salts. The
system 1s a simple bubbler constructed of stainless steel. It 1s a simple
matter to convert such a scrubber assembly to an all-purpose (liquid or
solid) Incinerator. This 1s done by placing a box into another box. The
Inner box or trough floats on a 7.6 cm (3 1n) depth of salt. Such a
layer of alkali sulfates has a heat capacity at S93°C equivalent to a 38 cm
(15 in) bed of cast iron. Liquids (containing water 1n any concentration)
B- 65
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or sol Ids are Introduced into the center box where they are exposed to a
flame. All resulting gases are then sucked through the scrubber baffles 1n
the side walls before exiting. This bubbling action is made to occur by
means of an induced draft fan. When the fan fs turned on it creates a
negative pressure on the exit side of the diffuser baffle. This causes a
rise in the liquid level with a concomitant drop in the liquid level on
the other side of the baffle. In this manner a liquid front is created
into which exhaust gases are made to impinge. The reason for inserting
the floating Inner trough 1s to make ash removal simple and to preclude any
problems associated with the introduction of water directly into the
molten salts.
The ability to scrub submicron particles has been demonstrated by APS
and by others. Using less than 15 cm (6 in) of water vacuum on the Induced
draft fan (and less than 2.5% of the weight of liquid that would be needed
in a water scrubber), they have been able to remove particulates in the
submicron range.
Since the gases that are introduced into the liquid are both rapidly
heated and also distorted by the presence of the electrostatic field in
the molten salts, rapid ignition at lower-than-expected temperatures is
observed for unburned organic substances.
The reaction of sulfur dioxide with calcium oxide occurs in milli-
seconds in a molten salt. The reaction is stoichiometric not only for
sulfur oxides but for nitrogen oxides. Gas flows containing 4700 ppm
sulfur dioxide were reduced to 3 ppm sulfur dioxide. In trapping sulfur
dioxide by combination with a metal oxide, It 1s desired that the resultant
compound be economically viable. Aluminum sulfate has major value in its
use 1n settling sewage solids, and in pharmaceutical products. Aluminum
oxide, although an inert material in aqueous media at ambient temperature,
is chemically active in a molten salt bath. It is the active ingredient
for the extraction of aluminum in the Hall process at 7009C.
From a conversation with Dr. Greenburg, of APS, Inc., a unit capable
3
of treating a 90,000 m /hr gas stream would occupy a cubical space of
*
The Hall process is an electrolytic process for manufacturing metallic
alLffninum.
B- 66
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approximately 6 m per side. One-half or 3/8" 300 series stainless steel
would be used. The total installed cost'of this system would lie within
the $200,000 to $500,000 range.
Advantages and limitations of molten salt baths as applied to hazard-
ous waste incineration at sea are listed below:
Advantages
• One molten salt scrubber system is commercially available.
• Incineration and scrubbing of particulate matter and gaseous
contaminants in a single device
• Excellent thermal contact between heat source and hazardous
material
• Handles liquid or solid wastes
• Heavy metals can possiblv be removed.
• Hot incinerator gases can be used to preheat the salt bath.
• Molten, caustic salt bath is stable, nonvolatile, relatively
inexpensive, non-toxic, and recyclable.
• Salt bath operates as afterburner.
• Chlorinated hydrocarbon wastes have been treated in the APS
system.
Limitations
• One developer, AI, has dropped scrubber process because of
complexity
• Demonstration testing needed - at least slip-stream testing
• Process 1s batch - after saturation, molten salts must be
regenerated or disposed of
t System reliability cannot be assessed due to limited com-
mercial experience
• Operating costs are not available
• In an accident salts are highly reactive and pose grave
danger to personnel onboard ship.
3.5.4 Wet Scrubber (13, 15, 16)
Wet scrubbers can be used to remove both gaseous and particulate
pollutants. Wet scrubbers are very commonly used in controlling emissions
from incineration of hazardous waste and municipal solid waste. As control
devices, wet scrubbers represent old, well-established technology.
B- 67
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The removal of gaseous contaminants in wet scrubbers 1s a gas absorp-
tion process that depends on intimate gas/liquid contact. The unit
mechanisms for particle collection from gas streams depend upon one or
more of the following basic particle deposition phenomena: inertial
impaction, interception, gravitational force, Brownian diffusion, electro-
phoresis, diffusophoresis, and thermophores is.
Following the classification system developed by Calvert, wet scrubbers
suitable for gaseous emission control can be categorized into four generic
groups: plate, massive packing, preformed spray and gas-atomized spray.
Figure 19 illustrates typical examples and dimensions for each type based
on an inlet gas flowrate of 140,000 actual m3/hour (83,000 ACFM) at 177*C
(350*F) and an inlet grain loading of 300 mg/m . Specific designs can be
conducted for each type of scrubber except the spray tower to Insure high
removals of halogens and particulate matter.
Plate towers are vertical, cylindrical solumns with a number of plates
or trays inside. The scrubbing liquid 1s introduced at the top plate and
flows successively across each plate as it moves downward to the liquid
outlet at the tower bottom. Gas comes in at the bottom of the tower and
passes through openings in each plate before leaving through the top. Gas
absorption is promoted by the breaking up of the gas phase into little
bubbles which pass through the volume of liquid in each plate.
Packed bed scrubbers are vessels filled with randomly oriented packing
material such as saddles and rings. The scrubbing liquid is fed to the
top of the vessel, with the gas flowing 1n either cocurrent, countercurrent,
or crossflow modes. As the liquid flows through the bed, 1t wets the
packing material and thus provides interfaclal surface area for mass
transfer with the gas phase.
In preformed spray scrubbers, the scrubbing liquid is atomized by
high pressure spray nozzles Into small droplets, and then directed Into
a chamber which gases pass through in either countercurrent, cocurrent, or
crossflow direction. In this case, the scrubbing liquid 1s the dispersed
phase and gas is the continuous phase. Since mass transfer occurs at the
liquid droplet surface, gas absorption is enhanced by finer droplets.
However, there is a practical limit below which the droplets become en-
trained.
B- 68
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GAS OUT
OAS OUT
liquid
DOWNCOMER
PLATES
GAS IN
LIQUID IN
LIQUID OUT
PLATE COLUMN
GAS OUT
10.7m 436 ft]
GAS IN
LIQUID OUT
STRAY TOWER
Urn
OAS OUT
=¦ LIQUID IN
PACKING
LEMENTS
OAS DISTRIBUTOR
ANO PACKING
SUPPORT LIOUID IN
"I
LIQUID OUT
PACKED BED
CYCLONIC
PARATOR
LIQUID OUT
VENTURI SCRUBKR
WITH MIST SEPARATOR
Figure 19. Wet Scrubber Types
B- 69
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Gas-atomized spray scrubbers utilize the kinetic energy of a moving
gas stream to atomize the scrubbing liquid into droplets. Typical of
these devices are the venturi scrubbers and orifice scrubbers. In the
venturl scrubber, liquid is injected into the high-velocity gas stream
either at the inlet to the converging section or at the venturi throat.
In the process, the liquid is atomized by the formation and subsequent
shattering of attenuated, twisted filaments and thin cup-like films. These
initial filaments and films have extremely large surface areas available
for mass transfer. The spherical droplets formed later have less surface
area per unit volume of liquid than do the attenuated films and filaments.
Because of the enhancement of mass transfer by the presence of these
attenuated films and filaments, venturi scrubbers provide higher efficiency
for noxious gases removal than preformed spray scrubbers.
Advantages and limitations of wet scrubbers as applied to hazardous
waste incineration at-sea are listed below:
Advantages
• Particle removal efficiency >99% for particles >0.5 um
in diameter (high pressure drop venturi scrubber)
• Gas quenching and cooling
• High gas flowrate variability (or turndown capability)
• High removal efficiencies for gaseous pollutants such as SOg,
HC1 and HF (tray tower and packed tower)
• Heavy metals removal
• Effective scrubbing with fresh water or sea water
• Some types not subject to plugging (Venturis)
• Corrosion resistant materials available such as FRP and
resin coatings
• Relatively low capital costs
i Commercial experience with hazardous waste and municipal
solid waste incineration
Limitations
• Large settling pond and neutralization equipment required
for closed loop system
• Waste sludge generated if closed loop system used
• Lime slurry or caustic solution needed onboard ship
B- 70
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• Single pass sea water system nay concentrate pollutants in
local area of ocean
• Multiple units generally required for removal of both parti-
culate and gaseous pollutants
• Not generally effective for particle sizes <0.5 um in
diameter
• Some scrubber types (packed beds, sprays, and tray towers)
high susceptable to plugging, especially with salt water
• Additional corrosion problems with sea water
• In tray towers, motion of ship will result in uneven weir
heights.
t Pilot testing required if sea water to be used
• Heavy metals will be discharged to the ocean, thereby
converting an air pollution problem to a water pollu-
tion problem.
• High energy cost for particulate collection
3.5.5 Conclusions and Recommendations
In summary, Table 4 lists major advantages and limitations for all
the scrubber types suitable for at-sea incineration of hazardous wastes
aboard ship which were discussed in the previous four sections.
Based on advantages and limitations listed for the four most appli-
cable scrubbers systems for control of particulate and gaseous pollutants
from hazardous waste incineration aboard ship, the following recommendations
are made:
1) A high energy venturi scrubber and mist eliminator tower
should be considered utilizing sea water due to its high
removal efficiency for particulate matter and expected
moderate removal efficiency for gaseous pollutants 1n a
once through system. Medium cost resin-coated FRP vessels
with teflon nozzles are available for halogenlc gaseous
pollutants.
2) A once-through wet scrubber using sea water should be con-
sidered If a method can be found for dispersing the effluent
stream 1n the ocean.
3) Closed loop wet scrubber systems cannot be considered using
fresh water because large quantities of water and a large
settling pond would be required aboard ship.
B- 71
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TABLE 4. ADVANTAGES AND LIMITATIONS OF SELECTED EMISSION CONTROL DEVICES
Device
Advantages
Limitations
Dry electrostatic
precipitator
Wet electrostatic
precipitator
Dry dust collection inc. heavy metals
Low pressure drop and power requirement
Efficient removal of fine particles
No waste sludge generated
Simultaneous gas absorption and dust removal
Low energy consumption
No dust resistivity problems
Efficient removal of fine particles
Control of tacky particles buildup
Relatively high capital cost
Sensitive to change in flow rate
Particle resistivity affects removal 4 economics
Not capable of removing gaseous pollutants
Fouling potential with tacky particles
Primary collection of large particles required
Electrical shorting possible aboard ship
High corrosion damage expected with halogens
Limited commercial experience for hazardous waste
incineration
Relatively high capital cost
Low gas absorption efficency
Sensitive to changes in flow rate
Oust collection is wet
Demister possibly required
Electrical shorting possible aboard ship
High corrosion damage expected with halogens
Limited commercial experience for hazardous waste
inci neration
Fabric filter
• Dry dust collection inc. heavy metals •
• High efficiency at low to moderate pressure
drop •
• Efficient removal of fine particles •
• No sludge or liquid wastes
• No liquid freezing problems •
• Dry sorbent injection for removal of gaseous •
pollutants possible •
Gas temperatures cannot exceed 290°C although
practical maximum is 95°C
Fabrics may be susceptible to chemical attack
Not capable of removing gaseous pollutants without
nodi ficatlon
Demister required after pre-quench
Relatively large system size and costs
Storage required for dry sorbent. waste cake and
spent materials; disposal required for waste
cake and spent materials
No commercial experience with hazardous waste
incineration
- Continued -
-------
TABLE 4. (Continued)
Device
Advantages
Limitations
Molten salt scrubber
Incineration and scrubbing of gaseous and
particulate emissions possible in a
single device
Heavy metals removal
Hot incinerator gases can serve to preheat
salt bath
Salt bath operates as afterburner
Pilot experience with chlorinated hydrocarbon
wastes
Limited commercial experience
Sftp-stream testing needed
Batch process with limited information on cycle
times
Budgetary capital costs and operating costs not
available
Relatively large space requirement
Oanger potential 1n case of molten salt accident
High energy venturi
scrubber with mist
eliminator tower
Spray Tower
Plate type scrubbers
and packed bed
Simultaneous gas absorption and dust removal
Suitable for high temperature, high moisture
and high dust loading applications
Cut diameter of 0.5 um is attainable
Collection efficiency may be varied
Commercially proven with hazardous waste
incineration
Resin-coated FRP materials available for
halogenic gases
Effective scrubbing with fresh water or sea water
Relatively low weight and capital cost
Simultaneous gas absorption and dust removal
Suitable for high temperature, high moisture
and high dust loading applications
Collection efficiency may be varied
Simultaneous gas absorption and dust removal
High removal efficiency for gaseous and
aerosol pollutants
Low to moderate pressure drop
Commercially proven with hazardous waste
incineration
Corrosion and erosion problems with metallic construction
Additional corrosion problems with sea water
Dust is collected wet
Moderate to high pressure drop
Only moderate removal of gaseous pollutants
Settling pond required for closed loop operation
High efficiency may require high pump discharge
pressures
Dust is collected wet
Nozzles are susceptable to plugging
Requires downstream mist eliminator
Design based on experience and experimental testing
Settling pond required for closed loop operation
Low efficiency for fine particles
Not suitable for high temperature or high dust
loading applications
Requires downstream mist eliminator
Corrosion and erosion problems with metallic construction
Additional corrosion problems with sea water
Settling pond required for closed loop operation
For tray towers, motion of ship results in uneven
weir heights
-------
4) The molten salt bath should be considered either as a
scrubber or combination incinerator/scrubber because it
requires no pre-quench1ng, while removing high levels of
particulate and gaseous emissions, including trace metals.
Also, the unit does not require recirculation of molten
salts for scrubbing purposes, although it does require peri-
odic regeneration of the salt bath.
5) Since the molten salt scrubber has little commercial experi-
ence, demonstration testing of the unit should be conducted
in the harsh environment expected at sea by treating a slip-
stream in a sub-scale unit.
6) A spray tower should not be used due to its predicted low
removal efficiencies for both gaseous and particulate
removal for comparable size equipment and power requirement.
7) Neither a tray tower nor a packed tower should be considered
unless 1t is used in conjunction with a highly efficient
primary particulate removal device.
8) Fabric filters would not be appropriate since they cannot
handle very hot halogenlc inlet gas streams or remove
gaseous pollutants.
9) The dry electrostatic precipitator would not suffice due to
its inability to remove gaseous pollutants, quench the inlet
gas stream, or handle corrosive gases. Also, electrostatic
precipitators may short out because of motion and vibration
aboard ship.
10) The wet electrostatic precipitator would not be adequate,
either, due to its inability to remove high levels of
gaseous pollutants.
B- 74
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3.6 SHIPBOARD LABORATORY
In order to determine whether or not a U.S. Flag incinerator ship
should have onboard chemical analysis capability, it is necessary to ask
and answer several questions:
» Research and development phase:
- Types and amounts of R&D information desired
- Types of wastes to be burned
• Long-term operations phase:
- Regulatory requirements for sampling and monitoring
- Nature of wastes (special wastes might require some
onboard analysis)
• Costs and benefits
This section will attempt to resolve these questions in relation to appropri-
ate types of analyses, instrumentation required for these analyses, and re-
quired support in terms of manpower and facilities. The nature of the ship-
board environment, manpower availability, personnel hygiene, and costs and
benefits will be factors.
The shipboard environment is a harsh one from the viewpoint of perform-
ing chemical analyses. The air contains high levels of sodium chloride,
other corrosive salts, and water vapor. Ships are subject to continuous
relatively high amplitude, low wavelength vibration from onboard rotating
machinery. Ships also are in continuous three dimensional motion: roll,
pitch, and heave. Ship's electrical systems are noisy. The radio and radar
communications gear onboard causes excess noise in instruments. Lastly,
ships generally do not have much room for laboratories.
Many of the adverse effects of the shipboard environment listed above
can be ameliorated or eliminated. For example, air to the laboratory could
be filtered and conditioned. Instruments could be shock mounted or mounted
on gimbals to reduce the effect of vibration and motion. Electrical noise
can be reduced through employment of motor generators, isolation transformers,
or filters. A ship's Generating capacity could certainly be altered to pro-
vide the power required by instrumentation. Appropriate shielding could be
provided to reduce instrument pickup of RF noise. Space is a problem that
could be solved by careful choice of instrumentation and design.
B- 75
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Persons possessing certain analytical chemistry expertise (e.g., in
gas chromatography - mass spectrometry) are in short supply. Also, extended-
duration shipboard living is not an appealing prospect to many persons. Con-
sequently, manpower availability for onboard analysis might be a problem.
Laboratories and chemical analysis and support equipment are expensive.
An instrument such as a gas chromatograph - mass spectrometer (GC/MS) costs
from $150,000 to $200,000. An additional $50,000 to $75,000 might have to
be spent to provide a suitable environment for a GC/MS (high quality filter-
ed air, large volume cooling water system, extra floor support, and spares).
An instrument as sophisticated as a GC/MS is difficult to maintain on land
much less on a ship, although Scripps Institute of La Jolla, California, has
operated a GC/MS on an ocean-going research vessel.
To justify the capital cost of onboard analysis, there needs to exist
either or both: 1) a requirement for more rapid analysis turnaround than
can be achieved by holding samples for land-based analysis, or 2) a suffi-
cient volume of samples to keep the onboard laboratory busy. The more ex-
pensive the instrumentation, the more important these justifications become.
Given the technical difficulties and cost and personnel considerations
relative to establishing an onboard laboratory, it is concluded that only a
limited capability should be provided. This capability should be sufficient
to support permit compliance and R&D objectives through determining destruc-
tion efficiency for major organic components of the waste. It is then neces-
sary to determine what kinds of analysis really must be performed onboard
in order to support an R&D effort or routine incineration operations. The
next section considers this question.
3.6.1 Recommended Analytical Capability
Figure 20 is a flow chart illustrating one type of decision-making
process regarding an onboard analysis capability. In general, the decision
as to whether or not to perform sampling and onboard or land-based analysis
will be based on the following considerations:
• Information about and characterization of the waste
• New or existing regulatory requirements
• Characterizing incinerator performance on previously untested
wastes (either R&D or routine operations phase)
B- 76
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Figure 20. Flow chart showing situations requiring onboard analysis
-------
• Characterizing incinerator performance with new system components
(primarily R&D phase)
Discussion of recommended onboard analytical capability is conveniently
divided into organic and inorganic analysis, and these are discussed below.
3.6.1.1 Organic Analysis Capability
As described in Section 1, MPRSA does not specifically preclude at-sea
incineration of any organic waste. Mandatory regulations under the London
Convention permit at-sea incineration of organochlorine wastes and petroleum
products when permitted by signatories to the London Convention 01).
As shown in Figure 20, four cases relating to onboard analysis can be
distinguished for organic wastes. If the waste contains an unusually hazard-
ous substance (e.g., chlorinated dioxins or PCBs), the ocean dumping permit
would probably require onboard analysis to demonstrate in semi-real time
that destruction efficiency requirements were being achieved. During the
at-sea incineration of Herbicide Orange, daily reports of destruction effi-
ciency were required by the permit. It is expected that onboard determina-
tion of destruction efficiency will be required for the proposed at-sea in-
cineration of liquid silvex herbicides.
The second case illustrated in Figure 20 involves a previously untested
but not unusually hazardous waste. For this type of waste, the at-sea incin-
eration permit probably would not require onboard determination of destruc-
tion efficiency. During routine operations, sampling should be performed,
but onboard analysis would not be necessary. During the R&D phase, however,
onboard analysis would be appropriate. Additionally, the R&D phase ought
to make provision for advancing the state of the art of onboard analysis.
The third case illustrated in Figure 20 involves the R&D phase of test-
ing new incinerator components. In this case, onboard analysis would proba-
bly be required in the permit. Further, even if not required by the permit,
onboard analysis would be appropriate when new incinerator components are
being tested.
The fourth case illustrated in Figure 20 involves routine operations
when routine wastes are being burned. Neither sampling nor analysis (on-
board or land-based) Is necessary.
B- 78
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Perhaps the most generally applicable analytical technique for deter-
mining organic compounds is gas chromatography (GC). This is a technique
for vapor phase separation and detection of organic compounds. There is a
variety of detectors available for quantifying compounds after separation
in the GC column. The two most popular and applicable detectors are flame
ionization (FID) and electron capture (ECD). The FID is virtually a univer-
sal detector which "sees" carbon-hydrogen bonds. It lacks sensitivity to
highly chlorinated compounds. The electron capture detector "sees" electro-
negative atoms or moieties in organic compounds. It is particularly sensi-
tive to halogens and lacks sensitivity to organics containing only carbon
and hydrogen. A gas chromatograph equipped with these detectors was oper-
ated onboard the M/T Vulcanus during the at-sea incineration of Herbicide
Orange (2).
Gas chromatography is applicable to organic compounds which are thermal-
ly stable at the temperatures employed and which have sufficiently high
vapor pressures. Polychlorinated biphenyls having vapor pressures as low
_5
as 6 x 10 mm of mercury can be analyzed by GC.
GC provides quantitative but only semiqualitative Information about
organics. The retention time of a compound is characteristic, but several
compounds may have the same retention times. There are several means of
gaining additional information on identity. One is to analyze the sample on
columns of different polarity and compare retention times with those of
authentic standards. Another is to use columns of higher resolving power.
The limitations of GC with respect to compound identification are not
expected to be a problem in shipboard analyses. The recommended goal of
onboard analysis is detection of major waste components. Thus, chromato-
grams of stack samples can be compared with chromatograms of the waste being
burned. Matching the chromatographic patterns should be sufficient for
determining permit compliance with destruction efficiency requirements.
However, a full complement of columns should be available; and standards,
if available, should be carried onboard.
B- 79
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Many organic compounds are thermally labile or of too low volatility
to be analyzed by GC. There is a complementary technique termed high per-
formance liquid chromatography (HPLC) which is used under these conditions.
In NPLC, separations are carried out with a liquid mobile phase. Two detec-
tors are widely used in HPLC: the ultraviolet and the refractive index. The
ultraviolet detector is considerably more sensitive than the refractive in-
dex detector but is sensitive only to compounds that absorb in the ultra-
violet. Many pesticides absorb UV radiation. The initial waste character-
ization will provide information to decide whether GC or HPLC is the method
of choice.
Versatile GC and HPLC systems should, therefore, be purchased for use
during the porgram. On any particular Incineration voyage, only one need
be installed in the shipboard laboratory and the other could be used in an
EPA laboratory on land.
3.6.1.2 Inorganic Analysis Capability
The situation for onboard analysis of inorganic species is quite dif-
ferent than for organic species. The difference is primarily because in-
cineration does not destroy inorganics. Therefore, there will be no loss
of inorganics as a result of incineration. Inorganics present in the waste
may be converted to different compounds, but all inorganics fed to the incin-
erator will be emitted. Trace metals may be emitted as oxides, chlorides,
or sulfates, the latter compound types depending on the chlorine or sulfur
content of the waste.
Onboard inorganic analysis is not necessary for the following reasons.
First, IMCO and MPRSA regulations prohibit absolutely ocean dumping (or
at-sea incineration) of wastes containing mercury or cadmium or their com-
pounds unless they are present as trace contaminants. Second, other metals
can be present in wastes only below certain concentrations for the waste to
be permitted for at-sea incineration. Third, because trace metals are not
destroyed by incineration, environmental impacts can be estimated from the
initial analysis of the waste and plume dispersion modeling. Therefore,
the initial analysis of the waste will determine whether or not the waste
can be incinerated. If it can be incinerated, it will be known that harm-
ful inorganic emissions w^ll not occur. Therefore, onboard inorganic analy-
sis is unnecessary.
B- 80
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3.6.2 Required Instrumentation
The recommended instrumentation is a gas chromatograph equipped with
flame ionization and electron capture detectors. This instrument should be
interfaced to a suitable electronic integrator. A variety of standard
columns should be available. Generalized system components are:
• Dual column, temperature programmable gas chromatograph with
flame ionization and electron capture detectors
t Microprocessor controlled electronic integrator
• Variety of standard columns
• Vibration mounting for GC and integrator
• Carrier gas supplies (K-bottles) - helium or nitrogen
(argon-methane for certain models of ECD)
• Combustion gases for FID (K-bottles) - hydrogen and high
purity air
• Regulators and flow controllers for gases
• Isolation transformer for GC and integrator
• Miscellaneous tubing, fillings, syringes, and wiring.
3.6.3 Required Laboratory Support
Perhaps the simplest generally useful stack sampling train utilizes a
series of liquid filled impingers to absorb organic compounds emitted from
the stack. In many situations, the impinger contents could be analyzed
directly by injecting a few microliters into the chromatograph. This ap-
proach was used to measure destruction efficiency during the at-sea inciner-
ation of Herbicide Orange (2). The train used to provide samples for on-
board analyses consisted of benzene filled impingers. The benzene samples
were analyzed directly.
The most generally applicable sampling train uses a porous polymer
bed, such as XAD-2, to trap organic vapors. The sorbent is then extracted
with a solvent, such as pentane or methylene chloride, and the extract is
then concentrated and analyzed. (Note that halogenated solvents cannot be
used if an electron capture detector is to be employed in the analysis.)
B- 81
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The onboard laboratory will require the following capabilities:
• Equipment for extractions and concentrations
- Hood
- Glassware
- Glassware mounting rack in hood
- Sand or steam bath, heating mantels
• Solvent storage cabinet
• Standard laboratory benches
• Sink for glassware cleaning
0 Gas cylinder storage rack
• Under counter explosion-proof refrigerator.
A conceptual laboratory design is presented in Figure 21. It is a room
approximately 6.2 m x 5.0 m (20'2" x 19'4") consisting of a standard chemical
fume hood, standard laboratory benches, gas cylinder storage, solvent stor-
age, and a sink. There is sufficient bench top area for other instruments
to be installed for special testing.
3.6.4 Recommendations
Only preliminary considerations for laboratory support and design can
be presented at this time. These basic recommendations include:
t Onboard analysis for organic compounds only
t Shipboard gas chromatograph with flame ionization and electron
capture detectors or high performance liquid chromatograph with
ultraviolet and refractive index detectors.
• Laboratory space of approximately 6.2 m x 5.9 m
t Laboratory/monitoring storage space approximately 6.1 m x 6.1 m.
B- 82
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Figure 21. Preliminary shipboard laboratory design
B- 83
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4. INCINERATION SYSTEM/SHIP INTEGRATION
Potential Integration of Incineration systems and ships of various
sizes and capacities is illustrated by Figure 22. For these examples,
liquid injection incinerators of the dimensions and feed rates of those on
fl 2}
the M/T Vulcanus ' ' are used. These units are 5.5 m diameter by 10.4 m
high, with a liquid waste incineration rate of up to 12.5 mt/hr. A
standard commercial rotary k1ln 3.2 m diameter and 4.9 m long with a sol Ids
Incineration rate of 1.5 mt/hr 1s shown 1n the ship layouts. Ships of
three different capacities - 4000, 8000, and 12000 mt of waste - are de-
picted In the figure.
LIQUID INCINERATORS (2)
ROTARY KILN
LIQUID
INCINERATORS 43)
8000 MT I DECK
WASTE STORAGE j HOUSE
I
130 M
ROTARY
U 160 M
© © Oor
© © ©=~'
12000 MT
WASTE STORAGE
DECK
HOUSE
Figure 22. Incineration System/Ship Integration
-------
The smallest ship shown - TOO m long with 4000 mt waste capacity - is
approximately the size and capacity of the Vulcanus, which has two stern-
mounted incinerators. Liquid wastes are pumped from the tanks to each
incinerator burner. At a waste feed rate of 10 mt/hr for each incinerator,
this ship would require slightly over eight (8) days of continuous burning
to dispose of 4000 mt of waste. The bridge and deck house are shown
immediately forward of the incinerators, as on the Vulcanus. A location
further forward near the bow would be preferable for the environmental
safety of the crew.
In the center of Figure 22 is shown a ship of 8000 mt waste capacity
and 130 m in length. Three liquid incinerators burning 10 mt/hr each would
dispose of 7200 mt of waste in 10 days. A rotary kiln of 1.5 mt/hr solid
waste capacity is shown connected to one of the liquid incinerators, which
is utilized as an afterburner. Deck space is provided for addition of
rotary kilns to the other liquid units, for evaluation of other incinerator
types, and for emission control equipment. Solid wastes are stored in bulk
containers, which are transported by conveyor to the kiln. Automated
equipment lifts the bulk containers and discharges the solid wastes into
the kiln through a sealed hopper. Ash from solids incineration is stored
in the emptied containers and returned to land for disposal. The deckhouse
for this ship 1s located forward of the waste tanks, near the bow of the
ship.
The third and largest ship is 160 m long with a waste capacity of
12000 mt. Layout of equipment is similar to the 8000 mt vessel, except
that six liquid Incinerators and two rotary kiln are provided. About
eight (8) days would be required to dispose of 12000 mt of waste at the
feed rates previously described for each incinerator. Deck space 1s also
provided for additional solids incinerators and/or emission control equip-
ment.
These ship layouts indicate some of the ways that incineration systems
can be integrated onboard ships to provide desired incineration capacit>
and operational time at sea. Optimization studies to determine the number
of incinerators and incineration time versus ship loading and transit times
can be made for each ship size under consideration.
B- 85
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5. COST AND SCHEDULE ANALYSIS
Approximate costs and estimated delivery times for selected incinera-
tion system components and sampling, monitoring, and analysis equipment for
shipboard application were obtained by contacting manufacturers of actual
or similar commercial equipment. Installation costs for incineration
equipment are based upon cost factors received from the Office of Ship
Construction, U.S. Maritime Administration (MarAd).
5.1 INCINERATORS
Estimated costs of the recommended Incinerator types for shipboard at-
sea Incineration of hazardous wastes are summarized In Table 5. The equip-
ment will be specially designed or modified for shipboard application.
TABLE 5. INCINERATOR COST ESTIMATES
Incinerator
Approximate
Costs ($1000)
Wgt
(mt)
Installation^3'
Costs ($1000)
Total
Cost ($1000)
Rotary kfln
9(30^
50
219
1,119
(1.5 mt/hr -
sol 1ds)
2,500^
Lfquid Injection
300
1,312
3,812
O0 mt/hr-1 Iquids
each unit)
^'installation costs/mt provided by MarAd, Office of Ship Construction
^Approximate costs obtained from TR Systems, Inc.
Cost of the rotary kiln Incinerator Is estimated at $900,000, Including
special mounting and seals to withstand the pitch and roll conditions
of shipboard operation. A conservative estimate for the first liquid
injection incinerator is $2,500,000 including 20% design costs. Additional
B- 86
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liquid injection units from the same manufacturer would also cost $2,500,000
each.
Delivery time for a rotary kiln incinerator alone, modified for ship-
board operation, would be 12 to 18 months. However, design and fabrication
of the large liquid injection incinerators for shipboard application would
require 18-24 months from order date. Some lead time could be saved by
providing $100,000 for preliminary design of the incinerator at an earlier
date.
5.2 WASTE FEED SYSTEMS
Waste feed system costs estimated for this study include liquid waste
pumps and flowmeters, bulk material containers for solid wastes, and a
material container lifting fixture. Liquid waste tanks and piping are
dependent upon ship design, and are not included in this estimate.
Liquid waste pumps with electric motor drive,
50 1/min, one pump for each incinerator
burner feed line (Viking Pump Division,
Koudaille Industries, Inc.)
Liquid waste ultrasonic flowmeter systems,
one digital readout for each incinerator
with one flow transducer for each burner
feed line (Controlotron Corporation)
3
Bulk material carriers, 1.7 m (440 gallons)
capacity, S-110 heavy duty Tote bins
(Tote Systems Division, Hoover Ball and
Bearing Company).
Remote operated container lifting and dis-
charge fixture with piston vibrator (Tote
Systems Division, Hoover Ball and Bearing
Company).
5.3 EMISSION CONTROL DEVICES
Estimated costs of emission control devices evaluate for shipboard
application are listed in Table 6. Unit sizes are based upon a design in-
let flow rate of 140,000 actual m^/hr (83,000 ACFM) at 177°C (350°F) and
2
an inlet grain loading of 300 mg/m . Cost of a quench system to reduce
incinerator effluent temperature from 1500°C (2700*F) to 177°C (350°F) is
not included in Table 6.
B- 87
$300 each
2 weeks
delivery
$5,500 each
12 weeks
delivery
$1,000 each
18 weeks
del i very
$18,000 each
24 weeks
delivery
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TABLE 6. COMPARISONS OF SUITABLE GAS CLEANING DEVICES APPLICABLE
TO HAZARDOUS WASTE INCINERATION ABOARD SHIP
Dimensions (m/ft)
Device
W
L
H
WT (Metric Tons)
Installed Cost
Dry Electrostatic Precipitator 6.4/21
13.4/44
13.1/43
86
$600,000
Fabric Filter
12.2/40
15.2/50
12.2/40
145
1,050,000
Do
D1
H
WT
Installed Cost
Molten Salt Scrubber
6.1/20
4.3/14
10*
16.5 +
Over $1,000,000
Material
Do
Dt
H
WT
Installed Cost
Wet Scrubbers*
- High Energy Venturi/
Mist Eliminator Tower
316 s.s.
316 s.s.
2.6/8.5
3.7/12
1.7/5.5
n.a.
4.7/15.5
6.1/20
2.7
6.8
$86,000
230,000
- High Energy Venturi/
Mist Eliminator Tower
lined FRP?
lined FRP
2.6/8.5
3.7/12
1.7/5.5
n.a.
4.7/15.5
6.1/20
0.7
1.7
82,000
219,000
- Tray Tower
316 s.s.
4.3/14
n.a.
7.6/25
10.0#
408,000
- Spray Tower
316 s.s.
4.3/14
n.a.
7.6/25
8.6
441,000
- Packed Tower
316 s.s.
4.0/13
n.a.
10.7/35
17.0**
266,000
Legend
U > width
L - length
H * height, Including, hoppers
WT ¦ weight
Dq « outer column diameter
0i ¦» inner cylinder diameter
Dt * venturi throat diameter
FRP ¦ fiberglass reinforced plastic
n.a. • not applicable
*A height of 10 ft was assumed by TRW for calculatlonal purposes-
height was estimated by TRW based on Information received from APS, Inc.
*316 s.s. would be subject to attack from HF and HCl 1n Incinerator off
gases, however, tynar-llned fiberglass reinforced plastic 1s available
for these conditions up to a temperature of 93°C (200°F). For conparlson,
FRP data are given for the venturi/mist eliminator scrubber.
i
Kynar-llned FRP was assumed.
'Three trays were assumed.
1.8 m (S.9 ft) of 3.8 cm (1.5 1n) polypropylene Rachlg rings as packing (which
can withstand a maximum temperature of 121°C) was calculated for 991 removal
of halogens. If stainless steel packing Is used, total column weight increases
to 33 tonnes. For HF and HCl gases. Teflon packing may be required.
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5.4 SAMPLING, MONITORING, AND ANALYSIS EQUIPMENT
Estimated costs and delivery times for shipboard sampling, monitoring
and analysis equipment are listed in the following subsections.
5.4.1 Sampling Equipment
Method 5 trains: 3-4 weeks, 4 at $5,500 $ 22,000
Sorbent traps: 3-4 weeks, 20 at $55 $ 1,100
Water cooled probes: 8-12 weeks, 10 at $5,000 $ 50,000
Fixed alumina probes: 8-12 weeks, 10 at $40 $ 400
Heat traced lines: 8-10 weeks, 300 ft at $10/ft $ 3,000
Miscellaneous: 8-12 weeks $ 2,000
$ 78,500
5.4.2 Monitoring Equipment
CO analyzers: 6-8 weeks, 2 at $5,250 each $ 10,500
CO2 analyzers: 6-8 weeks, 2 at $4,650 each $ 9,300
O2 analyzers: 6-8 weeks, 2 at $1,525 each $ 3,250
HC analyzers: 6-8 weeks, 2 at $3,640 each $ 7,2B0
Gas conditioners: 8-12 weeks, 2 at $6,000 each $ 12,000
Equipment rack: 6-8 weeks, 2 at $300 each 5 600
Recorders: 6-8 weeks, 5 at $2,000 each $ 10,000
Transformer: 6-8 weeks, 1 at $500 $ 500
Data logger: 6-8 weeks, 1 at $8,000 $ 8,000
Gas cylinder rack: 6-8 weeks, $500 $ 500
Gas cylinders: 6-8 weeks, 4 at $150 $ 600
Regulators: 6-8 weeks, 3 at $350 $ 1,050
Regulators: 6-8 weeks, 4 at $200 $ 800
Shock mounts: 6-8 weeks $ 2,000
S0X analyzer: 6-8 weeks, 2 at $5,000 $ 10,000
N0X analyzer: 6-8 weeks, 2 at $7,500 $ 15,000
Vacuum pump: 6-8 weeks, 2 at $300 $ 600
Miscellaneous fittings: 8-10 weeks $ 5,000
tubing: 8-10 weeks $ 1,000
electrical $ 250
Icemaker: $ 750
Precleaned resin (approximately $85 per test,
20 test batch) $ 1,700
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SampTing containers $ 2,000
Design: 60 manhours $ 2,400
Installation: 80 manhours $ 3,200
r , O « , • r • $108,280
5.4.3 Analysis Equipment
Gas chromatograph (microprocessor controlled, dual
flame ionization and single electron capture
detectors): 6-8 weeks $ 22,000
Data system (with interface for HPLC): 6-8 weeks $ 6,850
GC accessories: . 6-8 weeks $ 1,000
High performance liquid chromatograph (refractive
index and UV detectors): 6-8 weeks $ 24,000
HPLC accessories: 6-8 weeks $ 2,000
Solvent storage cabinet: 6-8 weeks, $300 $ 300
Chair: 6-8 weeks, 2 at $75 $ 150
Desk: 6-8 weeks, $200 $ 200
File: 6-8 weeks, $50 $ 50
Gas cylinder rack: 6-8 weeks, $500 $ 500
Bench: 6-8 weeks, 3 at $454 $ 1,362
Bench: 6-8 weeks, 1 at $264 $ 264
Bench: 6-8 weeks, 1 at $336 $ 336
Bench: 6-8 weeks, 1 at $356 $ 356
Bench: 6-8 weeks, 1 at $302 $ 302
Bench: 6-8 weeks, 1 at $356 $ 356
Hood base: 6-8 weeks, 1 at $354 $ 354
Hood + blower: 6-8 weeks, 1 at $2,083 $ 2,083
Bench: 6-8 weeks, 1 at $302 $ -302
Bench: 6-8 weeks, 2 at $496 $ 992
Bench: 6-8 weeks, 1 at $374 $ 374
•Refrigerator: 6-8 weeks, 1 at $612 $ 612
Wall cabinets: 6-8 weeks, 3 at $288 $ 864
Bench top: 6-8 weeks, 48 feet at $65/ft $ 3,120
Glassware: 8-10 weeks $ 3,000
Rack for hood: 6-8 weeks $ 200
Regulators: 6-8 weeks, 4 at $200 $ 800
Gas cylinders: 6-8 weeks, 6 at $50 $ 300
Miscellaneous: 8-10 weeks $ 2,000
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$ 75,027
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6. ENVIRONMENTAL MONITORING
Requirements for environmental monitoring during at-sea incineration
are imposed by two sources. The first source is regulations pursuant to
the Marine Protection, Research, and Sanctuaries Act (MPRSA) (40 CFR 220-
229) and the mandatory regulations adopted under the London Convention (11)
(the mandatory regulations went into effect in the U.S. in March of 1979).
These regulations impose minimum operational monitoring requirements for
protection of the marine environment. The second source of monitoring
requirements 1s the permit for at-sea incineration. Specific permit re-
quirements were imposed on the at-sea incineration disposal actions for
organochlorine wastes (1) and Herbicide Orange (2).
Two general cases involving different degrees of environmental
monitoring can be distinguished, and these are discussed below.
6.1 INITIAL INCINERATION MONITORING
The London Convention regulations (and thus the MPRSA regulations)
require a survey during the first use of an at-sea incineration facility
to determine compliance with the regulations. The survey requires stack
gas sampling and analysis; monitoring of the stack gas for CO, COg. 02,
total hydrocarbons, and halogenated organics; and combustion and destruc-
tion efficiencies of at least 99.9%. The survey must be repeated every
two years.
It is envisioned that monitoring requirements in excess of the mini-
mum regulatory requirements would be required under the following condi-
tions :
• An unusually hazardous waste (e.g., PCBs) or a waste containing
an unusually hazardous substance (e.g., Herbicide Orange and its
2,3,7,8-TCDD contaminant) is to be incinerated
• The first time a new type of waste 1s to be incinerated unless it
was similar to a previously tested waste
• When a new incinerator, a new type of incinerator, or extensive
system component changes are made
When any of these three situations occur, it is expected that stack
sampling followed by shipboard and/or land based analysis of the samples
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will be required. Additionally, samples of any other incinerator effluents
would be required (e.g., solid residue from a rotary kiln incinerator,
and influent and effluent from a scrubber).
When wastes containing appreciable amounts of sulfur and/or nitrogen
(e.g., greater than 5%) are to be incinerated, stack gases should be
monitored for oxides of sulfur and/or nitrogen. Additionally, during the
R&D phase, provision should be made to monitor oxides of nitrogen to
establish baseline values.
In some cases, sea water sampling could be required to determine
actual impacts of incinerator effluents on sea and marine organisms.
Marine water and organism sampling was performed (1) during the first two
(Research permits) burns of organochlorine waste fn the Gulf of Mexico.
Marine water samples were taken during the first (Research permit) burn
of Herbicide Orange (2). The R&D phase would be a good time to perform
more extensive marine monitoring for long-term impact studies of at-sea
incineration.
6.2 ROUTINE INCINERATION MONITORING
MPRSA and London Convention mandatory regulations do not require
environmental monitoring during routine operations. These regulations do,
however, provide for protection of the marine environment by requiring
operational monitoring. The operational monitoring requirements are:
• Flame temperature not less than 1250°C (unless studies on the
incinerator have shown that a lower temperature will achieve
the required combustion and destruction efficiencies)
• Combustion efficiency 1s at least 99.95 ± 0.05%, based on
CC02 - CC0
CE - 100 x —2 (7)
C02
c c
Where CO2 and CO are, respectively, concentrations of carbon
dioxide and carbon monoxide in the stack gas. Thus, monitoring
of COg and CO are required during routine operations.
• No black smoke or flame extension above the exit plane of the
stack
The London Convention mandatory regulations also direct that Contracting
B- 92
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Parties "take full account of the Technical Guidelines". However, these
guidelines have not yet been adopted by the Contracting Parties, therefore
they do not have the force of law in the U.S.
The Technical Guidelines would impose additional operational require-
ments. Several relevant guidelines are:
• Minimum 3% oxygen in stack gas near the exit plane of the stack.
(This has been a requirement in permits issued by EPA for inciner-
ations in U.S. waters.) It should be noted that this is satis-
factory for a unit-construction incinerator such as those in cur-
rent incinerator ships where there can be no air infiltration.
However, for a combined unit, such as a rotary kiln liquid injec-
tion incinerator, air infiltration could cause a reading of 3%
excess oxygen at the stack exit, while there could be under 3%
excess oxygen in the combustion zone of the rotary kiln.
• Incinerator wall temperature should be not less than 1200°C
(unless tests on the unit have shown that adequate waste destruc-
tion can be achieved at lower wall temperatures).
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7. OPPORTUNITIES FOR R&D EVALUATION
A U.S. incineration ship can serve two broad functions: first, 1t
can be used for the destruction of hazardous wastes in a location mini-
mizing the risk to public health; second, it provides a safe site to
continue EPA's research and development efforts in hazardous waste in-
cineration. Much of the research in hazardous waste destruction is
conducted with laboratory and pilot scale incinerators. An incineration
vessel would expand the experience in the large scale processing of
hazardous waste materials. The effects of process variations in a com-
mercial scale incineration operation on hazardous waste destruction
efficiencies needs to be investigated, including many types of wastes not
yet tested.
Corrosion studies to determine which wastes or their by-products
will deteriorate the commercial scale equipment can be performed with the
shipboard incinerators. Evaluations can be made of corrosion resistant
materials. Investigations into generation of hazardous Intermediate pro-
ducts and destruction optimization studies could be conducted.
A shipboard incineration system can also be used to evaluate the
performance of pollution control equipment. Presently, the effects of
incinerating different hazardous wastes on scrubber performance 1s largely
unknown. Scrubber performance is usually measured in terms of criteria
pollutants, and a shipboard incinerator could be used to study the effi-
ciency of scrubbers on toxic organic compounds which appear in the flue
gas. A shipboard incinerator could also be used for research in process
instrumentation and control as they apply to hazardous waste incineration.
Development testing of improved sampling and monitoring equipment and
methods could be performed onboard an incineration vessel. For example,
particulate sampling is not presently performed on incineration ship
stacks. Sampling probes need to be developed that can carry out this
function under shipboard operational conditions. Marine monitoring will
also be required to determine environmental effects of at-sea incineration.
a- 94
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The following is a list of some of the R&D activities which could be
performed onboard the incinerator ship:
• Conduct incineration tests to establish conditions for safe
disposal of specific wastes.
• Investigate the thermochemistry of many hazardous compounds
not presently characterized.
• Perform mathematical modeling of large-scale incinerators.
• Investigate toxic product generation by incineration and fate
of these products (ash, flue gas, etc.).
• Perform corrosion studies with different types of wastes,
their products, and materials.
• Evaluate the performance of air-pollution control equipment
for toxic organics.
• Perform incinerator instrumentation and process control research,
and systems safety analyses.
• Evaluate sampling and monitoring equipment and methods.
• Collect economic data for incineration of various materials.
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REFERENCES
1. Clausen, J.F., H.J. Fisher, R.J. Johnson, E.L. Moon, C.C. Shih,
R.F. Tobias, and C.A. Zee, "At-Sea Incineration of Organochlorine
Wastes Onboard the M/T Vulcanus," EPA-600/2-77-196, September 1977.
2. Ackerman, D.G., H.J. Fisher, R.J. Johnson, R.F. Maddalone,
B.J. Matthews, E.L. Moon, K.H. Scheyer, C.C. Shih, and R.F. Tobias,
"At-Sea Incineration of Herbicide Orange Onboard the M/T Vulcanus,"
EPA-600/2-78-086, April 1978.
3. USEPA, "Polychlorinated Biphenyls (PCBs), Manufacturing, Processing,
Distribution in Commerce, and Use Prohibitions," 40 CRR 761, 44 RR
31513, May 1979.
4. Shih, C.C., D.G. Ackerman, L.L. Scinto, E.L. Moon, and E.F. Fishman,
"POM Emissions from Stationary Conventional Combustion Processes,
with Emphasis on Polychlorinated Compounds of Dibenzo-p-diox1n (PCDDs),
Biphenyl (PCBS), and Dibenzofuran (PCDFs), EPA Contract No. 68-02-3138,
January 1980.
5. Edwards, J.F., "Combustion: Formation and Emission of Trace Species,"
Ann Arbor Science Publishers, Ann Arbor, Michigan, 1974.
6. "Destructing Chemical Wastes in Commercial Scale Incinerators,
Technical Summary - Volume I," EPA Contract 68-01-2966, July 1975.
7. Ackerman, D.G., R.J. Johnson, E.L. Moon, A.E. Samsonov, and
K.H. Scheyer, "At-Sea Incineration: Evaluation of Waste Flow and
Combustion Gas Monitoring Instrumentation Onboard the M/T Vulcanus,"
EPA-600/2-79-1 37, July 1979.
8. Ottinger, R., J. Blumenthal, D. Dal Porto, G. Gruber, M. Santy, and
C. Shih. "Recommended Methods of Reduction, Neutralization, Recovery
or Disposal of Hazardous Waste, Volume III, Disposal Processes -
Ultimate Disposal, Incineration, and Pyrolysis Processes," EPA-670/
2-73-053-C, August 1973.
9. "Destructing Chemical Wastes in Commercial Scale Incinerators,
Facility Test Plans - Volume II," EPA Contract 68-01-2966, July 1975.
10. Scurlock, A.C., A.W. Lindsay, T. Fields, Jr., and D.R. Huber,
"Incineration in Hazardous Waste Management," EPA-530/SW-141 , 1975.
11. U.S. Department of State and U.S. Environmental Protection Agency,
"Final Environmental Impact Statement for the Incineration of Wastes
At Sea Under the 1972 Ocean Dumping Convention," February 1979.
12. Duvall, P.S. and W.A. Rubey, "Laboratory Evaluation of High-
Temperature Destruction of Polychlorinated Biphenyls and Related
Compounds," EPA-600/2-77-228, December 1977.
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13. Shih, C.C., R.A. Orsini, and D.G. Ackerman, Air Pollution Control
Devices for Hazardous Waste Incineration Permit Writer Guidelines,
TRW, Inc., Redondo Beach, CA, Chapter 5, March 1980.
14. Greenberg, Jacob. The Use of Molten Salts in Emission Control.
APS, Inc., Pleasantville, New Jersey, presented at: 72nd Annual
Meeting of the Air Pollution Control Association, June 1979.
15. Calvert, s~, J. Goldschmid, D. Leith and D. Melita. Wet Scrubber
System Study, Volume I - Scrubber Handbook. Report prepared by
A.P.T., Inc. for the U.S* Environmental Protection Agency.
EPA-R2-72-118a, August 1972.
16. Wen, C.Y. and G. Uchida. Gas Absorption by Alkaline Solutions in
a Venturi Scrubber. Ind. Eng. Chem. Process Des. & Devel. 12 (4):
437-443, April 1973.
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BIBLIOGRAPHY
Ackerman, D.G., "Destruction Efficiencies for TCDD During At-Sea Inciner-
ation of Herbicide Orange," EPA Contract No. 68-02-2660, March 1979.
Ackerman, D.G. and R.F. Maddalone, "Monitoring, Sampling, and Analysis
Plan for the Incineration of Herbicide Orange Onboard the M/T Vulcanus,"
EPA Contract No. 68-01-2966, June 1977.
Baboolal, L. and R. Tan, "Atmospheric Dispersion Analysis of Effluents
from the M/T Vulcanus," TRW Report to EPA, April 1977.
Kiefer, I.G. and R.H. Wyer, "Disposal of Herbicide Orange," EPA Draft
Report, April 1979
Paige, S.F., L.B. Baboolal, H. J. Fisher, K.H. Scheyer, A.M. Shaug,
R.L. Tan, and C.F. Thorne, "Environmental Assessment: At-Sea and Land-
based Incineration of Organochlorine Wastes," EPA-600/2-78-087,
April 1978.
Thomas, T.J., D.P. Brown, J. Harrington, T. Stanford, L. Taft, and
B.W. Vigon, "Land-Based Environmental Monitoring at Johnston Island -
Disposal of Herbicide Orange," Report to U.S. Air Force Occupational
and Environmental Health Laboratory, Brooks AFB, TX, No. OEHL TR-78-87,
September 1978.
A1r Force Logistics Command, "Contingency Plan for Ocean Incineration
of Herbicide Orange," San Antonio ALC, April 1977.
Department of the A1r Force, Final Environmental Impact Statement,
"Disposition of Orange Herbicide by Incineration," November 1974.
"Safety Plan for Incineration of Herbicide Orange Onboard the M/T
Vulcanus," TRW Report to EPA, May 1977.
U.S. Environmental Protection Agency, Draft Environmental Impact State-
ment on the North Atlantic Incineration Site, 1979.
U.S. Environmental Protection Agency, Final Environmental Impact State-
ment, "Designation of a Site 1n the Gulf of Mexico for Incineration of
Chemical Wastes," July 1976.
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APPENDIX C
TO
REPORT OF THE INTERAGENCY
AD HOC WORK GROUP FOR THE
CHEMICAL WASTE INCINERATOR
SHIP PROGRAM
CONCEPT DESIGN OF
U.S. FLAG VESSELS
FOR THE
CHEMICAL WASTE INCINERATOR SHIP PROGRAM
PD-246
September 19, 1980
U.S. DEPARTMENT OF COMMERCE
MARITIME ADMINISTRATION
ASSISTANT ADMINISTRATOR FOR
SHIPBUILDING AND SHIP OPERATIONS
-------
TABLE OF CONTENTS
SUMMARY 2
I. INTRODUCTION 4
II. CONSTRAINTS AND ASSUMPTIONS
A. Materials to be Incinerated 5
B. Incineration Systems 5
C. Operating Scenario 6
D. Regulatory Requirements and International
, Conventions 7
E. Design Alternatives 8
III. CONCEPT VESSEL DESIGN DESCRIPTIONS
A. PD-246A and PD-246B: Two new IMCO Type
Incineration Ships 11
1. Overview 11
2. Hull 13
3. Propulsion and Electrical Machinery 17
4. Incineration Systems 18
B. PD-246C: Converting a National Defense
Reserve Fleet Ship to a Chemical Waste
Incinerator Ship 21
IV. CONSTRUCTION SCHEDULES
A. PD-246 A 23
B. PD-246B 23
V. CONSTRUCTION COSTS
A. Chemical Waste Incinerator Ships 24
B. Incineration System Equipment 24
VI. OPERATING COSTS
A. Chemical Waste Incinerator Ships 25
B. Incineration Plant 25
C-l
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SUMMARY
The concept designs in this report represent alternatives for a U.S.
flag chemical waste incinerator ship, other maritime technologies may
offer equivalent methods for initiating a chemical waste incineration
system in the U.S. Among the commonly available technologies,
integrated tug-barge combinations, standard tug with barge, or
barge-carrying ship designs should also be evaluated as candidates for
a chemical waste incineration at sea system. Separate solid, waste and
liquid waste incinerator ship systems should also be evaluated before
construction of the combination incinerator ship is begun.
The concept designs and cost estimates for two ships were prepared as
part of the Interagency Ad Hoc Work Group for the Chemical Waste
Incinerator Ship Program study to support a FY 1982 funding request
for the conversion or construction of a U.S. flag Chemical Waste
Incinerator Ship. The ship would be part of a hazardous waste disposal
system and would destroy organic chemical wastes generated by U.S.
industries or the federal government. The ship would operate in
EPA-designated incineration zones off the U.S.coasts.
This concept design study presents two new ship alternatives and
discusses alternative technologies for use as an incinerator ship.
Each ship is outfitted with three liquid injection incinerators and
one experimental solid waste rotary kiln incinerator,plus the
auxiliary equipment and the cargo systems needed to support the
incineration plant. The new vessels should be able to burn a total of
7200 metric tons of liquid waste and 360 metric tons of containerized
solid waste during ten days of continuous burning.
Each design must conform to the highest standard of marine chemical
cargo protection and containment. The PD-246A can carry a full load of
the most hazardous chemical cargoes, those rated Type I according to
the IMCO Bulk Chemical Code. Because few chemicals now require Type I
protection, the PD-246A is a more flexible design. The other ship
design, the PD-246B,is a combination Type I/Type II ship, which
carries the same amount of waste cargo in a slightly smaller hull.
Most candidate chemicals for incineration at sea are Type II chemicals
that could be adequately protected by this hull design. The Type I
cargoes could be carried only in the ship's centerline tanks.
A conversion alternative, PD-246C, was evaluated using a Landing Ship
Dock (LSD) as the baseline ship for a Type I hull chemical waste
incinerator ship. However, because the available space for the liquid
cargo tanks is flanked by the existing propulsion plant, the LSD has
been determined to be inappropriate for use as a liquid waste
incinerator ship equivalent to either of the new ships. A different
conversion of a capacity equal to the new ship designs can be done,
however, any conversion would require such estensive modification to
the existing ship that it would not be a likely efficient investment
C-2
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for the program. In addition, the LSD may still be useful as a
research platform for solid waste incineration at sea, as the
containerized solid cargo can be safely handled within the cargo well
space.
The estimated cost and construction schedule for a single ship of each
new ship design, including installing incineration equipment, are
shown below.
DESIGN
NAME
LENGTH
BEAM
DEPTH
COST(millions)
SCHEDULE(mos.)
NEW TYPE I
PD-246A
129 ,5m(425'-0")
25.0m(82'-0")
13,4m(44'-0")
80
30
NEW TYPE I/II
PD-246B
121.9m(400'-0")
23.8m(78 *-0")
12.5m(41'-0n)
75
30
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I. INTRODUCTION
These concept designs of alternative incinerator ships to destroy
hazardous organic chemical wastes were prepared as part of the
Interagency Ad Hoc Work Group for the Chemical Waste Incinerator Ship
Program. These design studies and the accompanying cost estimates
will support an appropriations request for the construction or
conversion of a U.S. flag Chemical Waste Incinerator Ship. Similar
ships have operated in western Europe during the past decade to
destroy liquid industrial organic chemical wastes, but no ship has
been built to serve the U.S. market for chemical waste disposal. The
following report addresses alternative U.S. flag vessels equipped to
carry and incinerate extremely toxic hazardous chemicals, that would
operate in EPA-designated incineration at sea zones off the U.S.
Atlantic, Pacific, and Gulf coasts.
Since the Environmental Protection Agency has the federal regulatory
responsibility for hazardous waste disposal, it is also interested in
advancing the state of the art for hazardous waste disposal
technology. The incinerator ship designs therefore include an
experimental solid waste incinerator and solid waste handling system.
Incorporating both liquid and solid waste incineration systems on a
common platform has complicated the designs in several instances that
are detailed in the remainder of the report.
These designs assume that a landbased collection and delivery system
for hazardous wastes exists to support the chemical waste incinerator
ship. In particular, the ship will require storage terminals,
chemical laboratories and loading facilities separated from other port
facilities. While these facilities have been assumed, no design or
cost estimate for these aspects of the incineration system has been
included in this study.
The following report will present an overview of the major design
constraints and assumptions, the design alternatives which were
available, and the concept designs that were prepared for cost
estimating purposes. For these designs, hull, machinery and
incineration systems are described. Finally, estimates for ship
construction schedules, construction costs, and operating costs for
each design are presented.
Since these designs are intended primarily to provide information for
cost estimating purposes, no final design or estimate is presented.
However, the information provided herein does establish a basis for
discussion and further development of the Chemical Waste Incinerator
Ship Program.
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II. CONSTRAINTS AND ASSUMPTIONS
A., Materials to be Incinerated
The candidate chemicals for at sea incineration are primarily toxic,
hazardous organic chemical residues from petrochemical processes, such
as plastic, pesticide and synthetic textile manufacturing. Because of
their toxicity, these wastes present an extreme pollution hazard.
Many of these are highly chlorinated combustible compounds that are
difficult to incinerate on land because they generate corrosive flue
gases that must be thoroughly "scrubbed" to prevent creating acid
rain. At sea, however, the combustion effluents are neutralized by
the oceanic environment. These wastes may be either pumpable liquids
or slurries, sludges, tars, or discrete solid objects.
The liquids and slurries are highly variable mixtures, with specific
gravities as low as .85 for kerosene-based pesticide solutions to as'
high as 1.3 for some refinery distillation residues. For these
concept designs, a specific gravity of 1.0 has been assumed for the
liquid wastes.
The solid wastes to be incinerated will also be highly variable
mixtures, but they must be known to have properties suitable for
loading into an incinerator without manual contact by the incinerator
operators. That is, either a screw feed or similar automatic
unloading mechanism must successfully empty the solid waste container.
Unidentified "abandoned site" mixtures are not acceptable wastes for
at sea incineration.
No waste chemicals that contain significant amounts of heavy metals
can be accepted for incineration at sea, since the dumping of heavy
metals at sea is strictly regulated by national laws and international
conventions. Likewise, inorganic wastes that have low heating values
are not likely to be accepted for incineration.
These ships therefore are designed to carry and incinerate only wastes
that are combustible, organic hazardous chemicals, including
organohalogens and other petrochemicals whose combustion generates
very corrosive flue gases. In the remainder of this report, the cargo
chemicals will be referred to as simply "liquid wastes" and "solid
wastes."
B. Incinerator Systems
The Ad Hoc Work Group has determined that the chemical waste
incinerator ship should be capable of incinerating both liquid and
solid wastes. Liquid incineration has been successfully demonstrated
at sea and the technology for handling incinerable liquids at sea is
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well developed, since it is similar to standard tanker cargo handling.
Solid waste incineration has never been successfully demonstrated at
sea, however, so that an experimental solid waste incinerator would be
a valuable research and development tool to investigate the technical
criteria for successful solid waste incineration at sea. EPA is
particularly interested in having a solid waste incineration capacity
aboard the vessel, as EPA has regulatory responsibility for hazardous
waste management and is interested in expanding the available options
for responsible, effective waste disposal. Future ship designs may
include a sea water scrubber, or similar device, to remove the acidic
effluent from the airborne incinerator flue gases, though none has
been installed on either of these ships.
As a result, the PD-246 designs each have three liquid injection
incinerators and one experimental solid waste rotary kiln incinerator.
Detailed information about the incinerators and their auxiliary
equipment is available in the report "Design Recommendations for a
Shipboard At-Sea Hazardous Waste Incineration System", which is
enclosed as Appendix B. The same report is independently produced by
TRW, Inc. as EPA contract No. 68-03-2560, August, 1980.
The major information about the incineration systems specified for the
PD-246 designs is presented below.
INCINERATION SYSTEM CHARACTERISTICS
Liquid Waste Incineration System
Incinerators:
Capacity:
Cargo Tanks:
Waste Feed:
Three vertically mounted liquid injection units
Ten metric tons/hour each
Epoxy lined mild steel
From any tank to any incinerator, via a common
pumproom.
Solid Waste Incineration System
Incinerator:
Capacity:
Cargo Storage:
Cargo Stowage:
Waste Feed:
Residues:
Rotary kiln, mounted on centerline of main deck
1.5 metric tons/hour
Two metric ton containers loaded before delivery to
ship, 180 containers per shipset
Main deck container cell guide structure
From deck storage area to kiln, on secured conveyor
Retained in ash pit for shore analysis
C. Operating Scenario
The conceptual designs for the
based on the following design and
*Two week operating cycle, with
first U.S. flag incinerator ship are
operational constraints:
ten days continuous burn "on site".
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*Both liquid and solid wastes accepted;
~No unidentified "abandoned site" wastes to be accepted;
~Solid waste precontainerized before loading onto ship;
~Wastes loaded at terminal by automatic equipment;
~Drifting or slow steaming during incineration operations;and
~Heading into wind maintained by bow thruster during incineration.
The two week operating cycle combined with the specifications for
three liquid incinerators, has determined the size of the ship.
The ship will have two days to load the 7200 metric tons of liquid
cargo and the 360 tons of solid waste containerized cargo, as well as
fuel oil and ship's stores. The vessel will then proceed to a
designated offshore waste incineration site, about 100 miles offshore
and perhaps 175 miles from the loading terminal. The ship will
operate at a service speed of 12 knots, since there is no need for
fast propulsion. The incinerators will be preheated during the last
six to ten hours of this passage so that chemical burning can begin
upon arrival at the burn site. Incineration will continue for ten
days, during which time the vessel will drift and maintain a heading
into the wind (about 60 to 90 degrees), so that the plume from the
incinerators blows away from the ship, rather than falling onto the
ship's deck. A bow thruster will be used to maintain the optimum
heading to the wind. After completing the incineration, the vessel
will return to the loading terminal.
D. Regulatory Requirements and International Conventions
The final PD-246 vessel designs must conform with all U.S. Coast Guard
regulations applicable to incinerator ship design and construction,
such as are listed below:
33 CFR 155 and 157, Pollution Prevention Regulations
33 CFR 159, Marine Sanitation Devices
46 CFR 30 through 35, Tank Vessel Regulations (requirements in 46
CFR 153 take precedence over requirements in 46 CFR 30 through 35)
46 CFR 42, Load Line Regulations
46 CFR 50 through 64, Marine Engineering Regulations
46 CFR 98.30 and 98.35, Handling and Storage of Portable Tanks (for
solid waste containers)
46 CFR 110 through 113, Electrical Engineering Regulations
46 CFR 153, Safety Rules for Self-Propelled Vessels Carrying
Hazardous Liquids (for special requirements for incinerator ships
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use the IMCO Interim Guidelines for the Application of the Code for
the Construction and Equipment of Ships Carrying Dangerous Chemicals
in Bulk to Ships Engaged in Incineration at Sea)
49 CFR 176.76(g)(3) and 49 CFR 176.83, Stowage and segregation of
portable tanks (for solid waste containers).
The PD-246 vessel designs must also comply with the IMCO Code for the
Construction and Equipment of Ships Carrying Dangerous Chemicals in
Bulk (IMCO Resolution A.212(VII)). The IMCO Bulk Chemical Code
identifies three classes of chemicals, based on the fire, health
water or air pollution, or chemical reactivity hazards they present!
These classifications are the basis for ship cargo protection and
survivability standards. The chemical types are:
Type I, products that require maximum preventive measures to
preclude escape of such cargo;
Type II, products that require significant preventive measures to
preclude escape of such cargo;
Type III, products that require a moderate degree of containment to
increase survival capability in a damaged condition.
The PD-246A design further incorporates some proposed amendments to
the IMCO Bulk Chemical Code that address pollution hazards. In so
doing, the vessels have been designed to the highest standards of
marine chemical cargo containment and protection.
The vessel designs must also comply with all the customary U.S.
commercial maritime standards,such as those of the U.S. Public Health
Service. Finally, as a commercial vessel, the chemical waste
incinerator ship would have to satisfy the standards of a
classification society, most likely the American Bureau of Shipping
for the purposes of insurance coverage. '
E. Design Alternatives
In addition to the single-hulled ship developed for this report
several other options may be viable for a chemical waste incineration
at sea system. Any design for this mission must include the
following:
~Precontainerize hazardous waste solids and collect liquid
wastes;
*Load the wastes with no handling that requires contact with
humans;
~Transport the containers and tanks of wastes to the
incineration zone in the open ocean;
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~Provide a suitable, stable platform for the incinerators,
so that incineration can continue under the widest possible
range of acceptable weather conditions;
*Return the empty waste containers and any incineration
residues to land;
*Make it as easy as possible for the waste generator to
deliver wastes to the incineration at sea system.
Among proven technologies of the ocean development industry,
alternative approaches to transport and incinerate waste chemicals
could include:
1. As an alternative to conventional hull incinerator ships,
it is possible to build an integrated tug/barge (ITB) unit.
Typically, an ITB is a ship-shaped barge propelled by a specially
designed pushing tug that is mechanically linked to the barge stern.
The tug-to-barge link is generally rigid, with the two hulls
mechanically joined. Alternatively, the ARTUBAR (articulated
tug/barge) system connects the tug to the barge by large bearing pins
that allow the tug and barge to articulate separately, reducing the
hull stresses. The two units move together in rolling and transverse
motions, however.
As compared to the conventional hull designs presented, a typical ITB
would have the arrangements reversed. With a pushing tug, the
incinerators are at the barge's forward end, to be as far from the tug
accomodation area as possible. The incinerators must also be placed
far outboard to allow clear visibility over the bow on centerline of
the tug.
2. A barge-carrying ship system. Fully loaded waste
containing barges are collected in the terminal area and then loaded
onto the ship. Waste generators adjacent to navigable waterways could
even load waste directly into a tank barge at the generating site and
deliver the waste to the terminal by waterway. The ship, which is the
incinerator platform, would remain outside the heavily trafficked port
while the waste containing barges were delivered by tugs. The
barge-carrying ship need not enter the inner harbor, so long as sea
conditions make it possible to load the barges on the ship.
3. Tethered tug-barge combination. A traditional tug and
tethered incinerator barge design would limit the project costs to the
barge construction and the tug hire fees. As with the inte irated
tug-barge system, the tethered barge has inherent flexibility because
separate barges can be built for solid and liquid waste disposal
systems. The tethered barge also separates the incineration platform
from the propulsion platform that has the crew aboard.
4. A ship conversion. In addition to new construction,
existing ships may be converted for use as an incinerator ship.
However, converting a ship imposes the restrictions of equipping the
incineration plant and auxiliary systems within the existing hull.
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„niiIfl„er convertinq a ship can be significantly less expensive than
However, and fche conversion can be completed much
sooner? provided that incinerators are available. A converted ship
could therefore begin incineration operations earlier than could a
specially built ship. On the other hand, the converted vessel could
™t be expected to stay in service as many years as could a new ship.
An existing tanker may be the most easily converted ship.
5 A tuq/supply vessel. Using either existing vessels or
now vessels a solid waste incineration platform can be developed, a
new vessel of a stock design can be delivered in about 12 months.
Tuq/supply vessels have a large deck area aft of the forward deckhouse
where a solid waste incinerator and material waste canister stowage
wnere a hoja naina this type vessel would allow more than one
SS-S* ti be ^n' operation^ permitting as many as four vessels to
operate from one terminal and burn zone.
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III.CONCEPT VESSEL DESIGN DESCRIPTIONS
A. PD-246A AND PD-246B: TWO IMCO TYPE NEW INCINERATION SHIPS
1. Overview
The concept designs presented here are typical cargo ship hulls
equipped with extensive auxiliary processing systems to handle and
incinerate hazardous chemical waste. The incineration plant, liquid
cargo pumps and unattended ship's electric propulsion motors are
located aft, with the accommodations, laboratory and attended ship's
propulsion diesel-generator machinery spaces located forward, to
achieve the maximum separation between the incinerator plant and the
ship's personnel. This arrangement increases the safety of the people
aboard the vessel, since the separation between the incinerator plant
and the forward deckhouse reduces the chance of chemical contamination
of the crew or the analytic lab that monitors the incinerators'
performance. The enclosed Figures 1 and 2 present the general
arrangement of each vessel.
The two designs, PD-246A and PD-246B, are a Type I hull and a
combination Type I/Type II hull, respectively. Both the designs carry
the same incineration equipment and the same liquid and solid waste
cargo capacity. Both ships have diesel-electric generators that
provide electric power to both the propulsion motors and to the
incineration plant. The PD-246A has five 1,000 kw diesel generators
(GM/EMD MG8E7) and the PD-246B has five 800 kw units (CAT-D399).
Fitting each ship with five generators provides the most flexible
power generating installation to meet the ship's widely varying power
requirements. Selecting the diesel-electric power plant also makes it
possible to use one power plant for both propulsion and incineration
plant loads, rather than the separate power plants which are usually
required. Additionally, a 500 hp bow thruster provided on both vessels
enables the ship to maintain a constant heading into the wind while it
drifts within the burn zone.
The Type I design, the PD-246A, is the more flexible, based on the
most stringent IMCO standards for marine chemical cargo containment.
Though the Type I standards now apply to only a few chemicals, the
IMCO Bulk Chemical Hazards Committee intends to amend the present
hazard rating to include pollution risks involved in any ship
collision or grounding as well. Therefore, many present Type II
candidate chemicals for incineration at sea are likely to be upgraded
to require Type I standard cargo containment.The resulting PD-246A
ship design is also the more expensive of the two new construction
alternatives.
The Type I/Type II combination design, PD-246B, provides the same
cargo capacity in a smaller hull. The centerline tanks provide Type I
protection and the port and starboard tanks provide Type II
protection. Most candidate chemicals for incineration at sea are now
rated as Type II chemicals and some will remain Type II even with the
amended hazard ratings, so this design will be able to accomodate
rating changes. Because of its smaller size and the reduced internal
compartmentation, the combination Type 1/ Type II design is the less
expensive of the two new construction alternatives.
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The principal characteristics, lightship weight summary, and table of
deadweight and displacement, for both the PD-246A Type I ship and the
PD-246B Type I/Type II combination ship concept designs are presented
below.
Principal Characteristics
Item
Length overall
Length bet.perp.
Beam,molded
Depth,molded
Draft, full load
Propulsion,max
Service Speed
Range,naut.miles
Accomodations
IMCO Ship Type Type I
Lightship Weight Summary
Item
Steel
Outfit *
Machinery
subtotal
margin(10%)
LIGHTSHIP
PD-246A
4890
1986
400
7276
728
8004
PD-246A
137,2m(450 *-0")
129.3m(425'-0")
25.0m(82'-0")
13.4m(44'-0")
6.9m(22,-9")
3500HP
12 kts.
5000
40
PD-246B
129.5m(425'-0")
121.9m(400'-0")
23.8m(78l-0")
12.5m(41'-0")
7.5m(24'-7")
3320HP
12 kts.
5000
40
Type I/II combination
PD-246B
4469
1898
320
6767
677
7444
* Outfit includes 1000 tons for incinerators and solid waste stowage
system.
Table of Deadweight and Displacement
Item
Liquid Waste
Solid Waste
Other Deadweight
DEADWEIGHT
DISPLACEMENT
PD-246A
7200MT(7088LT)
36 0MT(355LT)
883 . 8MT(870LT)
8445MT(8313LT)
16,576MT
(16,317LT)
PD-246B
7200MT(7088LT)
360MT(355LT)
883.8MT(870LT)
8445MT(8313LT)
16,007MT
(15 ,757LT)
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2. Hull
General Arrangements
Forward Deckhouse
On both the PD-246A and the PD-246B, the deckhouse is located forward
of the cargo areas and incinerator plant for the purpose of locating
personnel living and working spaces as far away from the incinerator
plume, heat and potential chemical contamination as possible.
The current IMCO and CJSCG regulations state that the accomodations
must be aft of the cargo areas on chemical carriers. However, the
USCG has agreed that a forward deckhouse is reasonable for this
special vessel. It is still necessary for IMCO and the Coast Guard to
formally determine that the house forward arrangement provides
equivalent protection and safety to the present regulations, but it is
likely that a waiver could be granted to locate the deckhouse forward
of the cargo spaces for an incinerator vessel design.
The forward deckhouse contains the accomodations spaces for all ship's
personnel. A chemical analysis lab for plume and waste sample studies
is provided on the main deck level aft of the accomodations spaces.
The lab has a separate entrance to the main deck and to the interior
passageways of the deckhouse, so that chemical samples need not enter
the main deckhouse. Lab storage space is located adjacent to the lab
space.
Showers and clothing change facilities are also provided immediately
aft of the deckhouse on the main deck level. This area includes
lockers for crew clothing and work gear, so that crew members can
leave dirty or contaminated gear at the entryway, rather than having
to enter the accomodations area to disrobe. This also avoids the
crewmembers' storing dirty gear in their own quarters. The shower
facilities also provide emergency first aid washdown for any people
who are accidentally contaminated by the waste chmicals. Medical
equipment and a hospital outfit are provided on board to competently
provide emergency care for chemical-related injuries and illnesses,
such as burns or contamination sickness
Cargo Containment
The cargo containment area is located in the mid-portion of the
vessel. Both liquid waste tanks and the solid waste container storage
area are located in this area.The U.S. Coast Guard regulations and
IMCO require strict isolation of hazardous zones, such as cargo areas,
so that detailed design will have to focus on the methods of
integrating both cargo systems in the same area. However, the
preliminary report will not develop the detailed designs at this time.
The ship is required to dispose of 7200 metric tons of liquid waste
per voyage. The specific gravity of the wastes may vary between 0.85
and 1.30, but for this design, a specific gravity of 1.0 has been
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assumed foe the average liquid cargo. When mote dense cargo is
the vessel's load lines, which indicate the maximum draft
legally' permitted for that ship to sail, will limit the cargo carried
and will prevent the ship from being accidentally overloaded. Since
the actual capacity of the incinerators depends on the waste thermal
characteristics, as Mil as the weight of the wastes, this assumption
was Acceptable. Therefore, 7100 "attic tons of tank capacity ate
provided on both new ships.
The liquid cargo tanks are all stiffened by external structure giving
all tanks a smooth internal surface in order to simplify tank cleaning
and minimize the possibility of contamination and corrosion in the
tanks! Some structural stiffening is in cofferdam spaces between the
tanks. These cofferdams provide the cargo separation which is required
for incompatible cargoes. Vertically corrugated bulkheads were also
used for some tank bulkheads within the cargo areas. The tanks are
specified to be internally epoxy coated, but the epoxy is likely to be
a snecial formulation, since the broad spectrum chemical wastes that
are expected cargoes for this ship will require especially resistant
Unk coatings. The selection of tank linings or the development of
new tank lining materials for hazardous waste carriage deserves much
more attention in the later stages of the chemical waste incinerator
ship program.
Tank arrangements differ between the two new ship designs, as is shown
in Figures 1 and 2. The PD-246A, which is designed to carry a full
load of the most hazardous Type I cargo, has eight tanks of 900 cubic
meters each. Type I liquid wastes must be located inside the
boundaries of 1/5 the beam of the hull and all cargo tanks must be
protected by adequate double bottoms and wing tanks. Designing the
ship with the capability to carry exclusively Type I cargoes results
in a large amount of ballast tankage, which can be sequentially filled
to help the ship maintain a constant draft and uniform ship motions as
the cargo wastes are incinerated.
The PD-246B, which is designed to carry combination of 45% Type I and
55% Type II cargo wastes by volume, has twelve cargo tanks, of which
only the four centerline tanks can carry Type I cargoes. Chemical
wastes of lesser hazards can also be carried in these tanks. The
eight port and starboard cargo tanks, which can carry Type II wastes,
extend outside the Type I boundaries, but are still protected by wide
wing ballast tanks greater than the minimum 760 mm(2'-6*) required for
Type II protection.
The ship is required to carry ten days worth of solid waste for the
rotary kiln, so 360 metric tons of solid waste will be carried. Safety
requirements dictate that solid waste be stored topside; therefore
solid waste will be stored on deck within the same boundaries as is
the liquid cargo. The solid waste is prepackaged and placed within
commercially available containers measuring 1.3m(4 feet) square by
2.6m(8 feet) high. The containers will be secured within a container
guide framework, equipped with machinery to transfer the container to
the rotary kiln. Each container holds two metric tons of solid waste.
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so 180 containers will be stowed on the main deck, single height.
Solid Waste Stowage Arrangement
Coast Guard regulations require that all sources of ignition or
combustion be at least eight feet above the cargo tanks and ten feet
fore and aft of the cargo tank areas, or be provided with equivalent
protection. As a result, the solid waste cargo stowage area and
handling equipment directly above the liquid waste cargo tanks are
separated from the liquid cargo tanks by a three foot high inert gas
filled cofferdam void space that extends the full width of the cargo
area. This system is expected to provide equivalent protection to the
two cargo areas as does the physical separation required in the
present regulations. However, this inert gas protection does leave
the entire stowage structure well within the boundaries of the
hazardous zone. Further design will have to include developing and
justifying a system that provides equivalent protection, in order to
receive formal approval from either the Coast Guard or IMCO.
The Incineration Plant Area
The incinerators and their auxiliaries are located aft. Also located
aft are the incinerator machinery room, the incinerator control room,
an equipment room used to store special plume monitoring devices, the
propulsion motors, and the cargo pumproom. There should be adequate
space both on deck and below decks for research and testing areas
desired by EPA. Personnel may travel from the deckhouse to the
incinerator area via enclosed passageways located port and starboard
immediately below the main deck.
The experimental rotary kiln is located aft of the cargo area, flanked
on both port and starboard by the two forward liquid injection
incinerators. This location is exposed to ship pitching motions, but
placing the kiln here is considered least disruptive to the kiln
operations. Adequate distance is provided between the kiln and the
liquid injection incinerator that serves as afterburner for the rotary
kiln flue gas exhaust. The kiln/liquid injection incinerator
combination is on the ship's centerline, with the two other liquid
injection incinerators located outboard of the kiln's forward end.
The clearances between and around all the incinerator units on both
the new construction designs should be sufficient for all anticipated
deck operations.
Structure
The material for both new vessel designs is mild steel. No unusual
structural problems are anticipated which would require extensive use
of high strength steel.
Stability
Intact: Trim and stability calculations were done for full load
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departure (in port) and ballast departure (on site) conditions. Both
conditions have satisfactory intact stability. Because there is a
large amount of available ballast capacity in the PD-246A and a lesser
amount in PD-246B, the trim and stability for other conditions will be
satisfactory with proper adjustment of ballast.
Damaqe: Damage stability calculations were done for a number of
operating conditions and locations of damage. In order to meet USCG
and IMCO requirements on the PD-246A, open crossflooding is necessary
between pairs of port and starboard win^ tanks. As a result of open
crossflooding, a loading restriction is required such that each pair
of wing tanks is either full pressed-up or empty at all times to avoid
large free surface effects. For the PD-246B, a forecastle was added
above the main deck forward of the deckhouse in order to meet USCG and
IMCO requirements. Open crossflooding between pairs of tanks is not
required because of the different tank arrangements.
Speed and Power
The PD-246A and PD-246B vessels are designed to maintain 12 knots
cruising speed with a service power of 3500 HP and 3320 HP,
respectively.
Seakeeping
The roll period for both new construction designs is estimated at 14.5
seconds, well above the most frequent wave periods for most seas. As
a result, resonant roll should be an infrequent problem. This is
crucial since the vessel will be drifting between 60 degrees and 90
degrees off the wind when the incinerators are burning. Preliminary
estimates of the maximum pitch angle are about 2 1/2 degrees (single
amplitude) for both designs. This is unlikely to disrupt the
operations of the kiln. A detailed seakeeping analysis should be
undertaken for more advanced levels of design. Future designs will
investigate the use of passive tank stabilizers as a means of
controlling the platform motions to some extent.
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3. Propulsion and Electrical Machinery
The new Chemical Waste Incinerator ship will have a service speed of
twelve knots,provided by a diesel electric propulsion plant. Two
attributes of the diesel electric machinery determined its selection.
First, the diesel generators that supply the power to the electric
propulsion motors can be located apart from the motors. In this ship
design, the propulsion motors must be located aft, below the
incineration systems. The diesel generators, however, are installed
forward, below the accomodations deckhouse, so that the attended
machinery space, where the ship's crew will spend most of the voyage,
is separated from the incineration system and the waste cargo spaces.
Second, the power produced by the diesel generators can be used for
the incineration plant when the propulsion plant is idle or operating
at reduced speeds. This "power pool" arrangement makes it possible
for the ship's total power needs to be supplied by a single
installation, rather than having separate ship's propulsion and ship's
service generator installations.
Five diesel driven AC generators will be installed. They will be
connected via a common bus to two propulsion motors, through a silicon
controlled rectifier (SCR) that converts the AC generated power to DC
propulsion power. The propulsion load is easily accomodated by four
diesel generators, always leaving the fifth as a backup. However,
linking multiple generators to a common bus allows the flexibility to
accomodate the ship's varying power and propulsion conditions without
severely overloading or underutilizing the individual units.
Likewise, the two tandem-mounted propulsion motors are preferred
because one can be shut down during the ship's reduced speed {6 knots)
operation while the ship is in the incineration zone. For the reduced
speed conditions, the tandem motors also provide greater redundancy
for emergency backup.
A 500 HP bow thruster will enable the ship to maintain a constant
heading into the wind as the ship drifts in the incineration zone.
The bow thruster can also assist the vessel's docking or undocking at
the waste loading terminal.
The incineration plant electric power can be supplied from the same
installed propulsion diesel generators, since simultaneous
incineration and full speed propulsion is not planned. During the ten
day incineration operation, propulsion will be limited to six knots
steaming or intermittent bearing adjustments that can be accomplished
with the bow thruster alone. Neither of these conditions requires
more than 500 HP, which leaves ample power for the incineration
plant's operations.
Likewise, the customary ship service load can be supplied by the
installed diesel propulsion generators.The ship service load is
estimated to be about 540 HP(400 kw).
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The basic information on the installed machinery follows.
Propulsion and Electrical Machinery
Item
Diesel Generators
PD-246A
5 @ 1 ,000KW
Propulsion Motors 2 @ 2,OOOHP
Required Propulsion 3500HP
Power,approx.max.
Req'd Incineration 1500HP
Power,approx.max.
PD-246B
5 @ 80 0KW
2 @ 1750HP
3320HP
1500HP
4. Incineration Systems
Both liquid waste and solid waste incineration systems are provided on
the PD-246 new construction concept designs. Each system is sized for
ten days continuous operation and consists of a waste stowage system,
a delivery or feed system to transfer waste to the appropriate
incinerator, the incinerators, and auxiliary equipment, such as
combustion air blowers and combustion monitors.
Any contamination of the ship by its hazardous waste cargoes must be
avoided. In addition, the extreme service conditions for the
incinerators and the cargo containment systems make it important for
the ship to be able to continue operations on a partial basis, even if
some equipment is shut down for maintenance or repairs. Modular
component design has therefore been emphasized for both the solid and
liquid incineration systems. For example, the rotary kiln is securely
mounted on a deck foundation, but could be easily removed from the
ship if necessary.
Liquid Incineration System
Three vertically mounted, liquid injection incinerators are to be
installed in the stern deck area. Each can burn ten metric tons/hour,
so that tie plant capacity is 30 metric tons/hour. The capacity of
the liquid injection units, combined with the ten day operations
assumption, set the size of the PD-246 new construction concept
designs.
Tiauid wastes will be loaded into the ship's epoxy lined cargo tanks
usina shoreside pumps and dockside loading gear at the ship's
terminal!! At the burn zone, the wastes will be fed into the preheated
incinerators via uncoated extra heavy mild steel pipes and cargo
DumDS The waste feed and transfer system will be arranged so that
any incinerator can take waste from any cargo tank and deliver it to
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any liquid injection incinerator.
Additionally, one of the three liquid incinerators will be the
afterburner for the experimental solid waste rotary kiln, to complete
the destruction of the solid phase chemicals that may be only
vaporized in the kiln. The other two liquid injection units will have
no attached kilns. However, any large scale expansion of the solid
waste incineration capacity would require that the other two liquid
injection units also be used as afterburners for any kilns added
later.
Solid Waste Incineration Plant
The solid wastes rotary kiln is the most experimental facility in the
PD-246 concept designs. The 1.5 metric ton/hour rotary kiln unit
selected is well proven in landbased operations, but is entirely
untested for use aboard a ship moving in a seaway. The problems of
safely loading, handling, and incinerating the solid wastes have
affected the overall ship design in several respects. Specifically,
the kiln's operations and solid waste cargo transfer to the kiln are
likely to be affected by the ship's motions and some compensations
have been provided in the concept designs.
The rotary kiln incinerator is a 3m(10') diameter by 5m(16') length
drum mounted at an angle along the longitudinal axis, with one end of
the drum higher than the other end. Gravity "tumbles" the wastes
along the length of the incinerator drum, so that wastes loaded into
the upper end of the drum are completely burned by the time they
tumble to the lower end of the drum. The combustion "residence" time
of the wastes in the kiln can be adjusted by either slowing or
speeding up the incinerator's rotation. Adequate residence time of
the solid wastes in the kiln is critical for achieving complete
thermal destruction. The drum will be mounted with its axis parallel
to the ship centerline to minimize the effect of roll on the waste
residence time. However, the kiln will still be vulnerable to the
ship's pitching motions and large pitching angles could conceivably
tumble the material out of the kiln before combustion is complete.
Preliminary estimates are that the maximum pitch angle will be about 2
1/2 degrees, which is unlikely to disrupt the rotary kiln's operation.
The ship's vibrations and roll motions impose additional loads on the
kiln's external rotary drive. However, two major vibration sources
aft, the propulsion motors and the propeller, will be idle much of the
time that the solid waste incinerator is operating. They will
otherwise be operating at a reduced load. Also, the diesel
generators, another major source of induced vibration, are located
forward, remote from the incinerators. Therefore, ship source
vibrations should not be disruptive to the. rotary kiln. Vibration
isolation mountings and a modified rotary drive will alleviate the
effect of vibration and roll. A more detailed analysis of this
equipment would be part of further design development.
The residue ash from the kiln will drop into a quench pit at the exit
end of the kiln. The ash is estimated to range from one percent to
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twenty-five percent of the waste, but ten percent is a reasonable
allowance. The ash will be retained on board until the ship returns
to its loading terminal, where it can be removed by shoreside
equipment. Although it is possible to discharge solid waste ash
overboard if the material is inert, the design has conservatively
provided a quench pit large enough to handle residues from the 360
tons of solid waste to be carried.
Solid Waste Stowage and Incinerator Waste Feed System
solid wastes will be stowed on deck in intermediate size bulk
ISitaine", each of which can hold about two metric tons of wastes
tie hundred eighty container stowage cells will be provided on deck
above the liquid cargo tanks. Dockside cranes will place each
container into a specified cell of the solid waste stowage structure,
SSSh as dockside cranes load standard transportation containers into
cell guides on cargo ship decks. The waste container, once locked in
place, will not be released until it is delivered to the waste
incinerator. Only one container per hour needs to be delivered to the
incinerator so that only one container at a time needs to be removed
f?™ She stooge area. A light duty crane, mounted on the overhead
structure of the waste container stowage area, will remove each
container from its cell and deliver it to the transporter on the
ship's centerline. The transporter will lock onto both the container
and the conveyor and will move the container to the incinerator.
At the incinerator, a lifting mechanism specifically for use with
these containers will elevate the container to the incinerator feed
chute. The container hatch will be automatically opened and the solid
wastes will be fed into the chute. After the container is emptied, the
door will be automatically closed and the container will be lowered to
the transporter The transporter will return the solid waste
container to the stowage area, where it will be returned to its cell.
Stowing the waste containers in specific cells will waste
incineration to be sequenced based on the known contents of the waste
containers, so that adequate residence time and adequate combustion
can be assured. A programmed burn sequence would also make
identification of the incinerator contents simpler, m case of
accident or incinerator shutdown.
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B. PD-246C: Converting a National Defense Reserve Fleet Ship to a
Chemical Waste Incinerator Ship
Since the Maritime Administration/ Maritime Subsidy Board has offered
to make a National Defense Reserve Fleet ship available for conversion
to a chemical waste incinerator ship, the NDRF was investigated as a
source of a lower cost single hull alternative. However, the
selected conversion scheme was neither attractive nor satisfactory.
The ships, for one reason or another, could not be made to meet
regulatory body requirements without an exceptional amount of
modification and extra cost. The basic design of many NDRF ships make
it impractical and expensive to place the attended machinery spaces
and accomodations forward of the cargo area and separated from the
incineration plant area. This arrangement is desirable to ensure
maximum distance between the personnel on board and the incinerators,
as well as to ensure that the incinerator exhaust plume does not
impinge on the living and working areas of the ship.
The selected NDRF vessel for a practical and satisfactory conversion
was an LSD-12 class (Landing Ship Dock) ship, a former Navy vessel.
The LSD vessel has accomodations and navigation spaces forward and a
large cargo well amidships and aft that opens to the sea by a stern
gate when the ship is partially submerged. It also has twin machinery
and twin screws, port and starboard amidships in the wingwalls of the
hull on either side of the cargo well. It appeared that the desired
separation between incinerators and the accomodations and attended
machinery could be attained with this vessel. A design study,
PD-246C, was made, with new independent liquid cargo waste tanks in
and over the center well, aft of the house. Liquid waste incinerators
and solid waste rotary kiln were located aft of the area, with solid
waste stowed over the cargo tanks, as in the new ship designs, PD-246A
and PD-246B, which are presented in this report.
The conversion would have been less than ideal, however, as the
vessel's draft was greatly increased, which created poor seakeeping
and propulsion characteristics. Also, even at a deeper draft, the LSD
could not carry the desired load capacity within the available cargo
conversion spaces. Finally, the PD-246C design would not meet U.S.
Coast Guard requirements that the machinery be clear of the cargo
tanks. The conversion design would need a complete new propulsion
plant located in a different part of the ship, which would be
prohibitively expensive to install. This coupled with other
conversion costs and the design disadvantages already noted, eliminate
the PD-246C conversion from further consideration at this time.
However, though the LSD is inappropriate for a chemical waste
incinerator ship equivalent to the new ship designs, the LSD may still
be a useful platform for alternative projects in the Chemical Waste
Incinerator Ship Program. Specifically, the LSD would probably be
satisfactory as a platform for a "solids only" incineration at sea
plant. The restrictions against the proximity of machinery and
packaged "dry cargo" are not as stringent as are those between
machinery tnd liquid cargo. There is ample room within the cargo well
for a research and development scale rotary kiln and cargo stowage
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system. Besides the cost of installing the solid waste stowage
handling and incineration equipment, however, there would be other
large costs: reactivating the old vessel; putting it "in class" with
the classification societies as a commercial vessel, rather than its
original Navy designation; renovating and modernizing the existing
obsolete steam power plant; renovating and modernizing the
accomodations; and extensive replacement or strengthening of old and
pitted steel hull plating.
Further evaluation of an LSD or any other NDRF ship conversion to a
chemical waste incinerator ship was not pursued.
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IV. CONSTRUCTION SCHEDULES
A. PD-246A: A New IMCO Type I Chemical Waste Incinerator Ship
About thirty months will be required for the PD-246A design's
construction, based on the anticipated 870,000 labor hours involved in
the project. An expected start fabrication date after six months
leaves twenty-four months to construct the vessel from start of
fabrication to delivery.
B. PD-246B: A New IMCO Type I/Type II Combination Chemical Waste
Incinerator Ship
About thirty months will also be required for the PD-246B design's
construction, as it is estimated to require 790,000 labor hours to
complete.
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V. CONSTRUCTION COSTS
JULY 1980 BASE PRICES PD-246A PD-246B
Contract Drawings $ 1 $ 1
Construction Contract (1) $53 $50
Spares, Plan Approval $ 1 $ 1
and Inspection
TOTAL= $55 $52
ESTIMATED FINAL COSTS (2)= $80 $75
NOTE (1) Each alternative includes $14 million for the subcontracted
incineration systems.
(2) Estimated final prices are based on a contract award date of
October 1982 and a delivery date of March 1985 for both
ships. 10% per annum inflation rate is assumed.
B. Incineration System Equipment
July 1980
INCINERATION SYSTEM EQUIPMENT
COST AND WEIGHT ESTIMATES
Incinerator Approximate Weight Installation Total Cost
Costs($1000) (mt) Costs($1000) ($1000)
Rotary kiln 900 50 219 1,119
(1.5 mt/hr solids)
Liquid Injection Unit 2,500 300 1,312 3,812
(10 mt/hr)
Two additional Liquid 5,000 600 2,624 7,624
Injection Units
Total Costs & Weights 8,400 950 4,155 12,555
Reference: TRW, Inc. Report, August 1980.
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VI. OPERATING COSTS
A. Chemical Waste Incinerator Ships
For both the Type I and Type I/II ship, an operating crew of thirty
three is estimated to be needed, in addition to the scientific and
incinerator operating crews. The estimated vessel operating expenses
per typical two week voyage are given below:
Ship Type
Type I
Type
Wages
$6340
$6340
Subsistence
290
290
Stores, Supplies, Eqpt.
300
290
Maintenance & Repair
832
790
Insurance *
2040
1890
Other
100
100
Daily Vessel Operating Expenses are $9900 for the Type I ship and
$9700 for the Type I/II ship. The vessel operating costs per voyage
are therefore approximately $138,600 and $135,800 for each ship,
respectively.
* Insurance estimates include coverage for Hull and Machinery,
Protection and Indemnity (P&I), and War Risk, but do not include
protection against liabilities arising from water and/or air
pollution.
Additionally, fuel costs for propulsion fuel alone are about $29,000
per voyage for each ship, based on a fuel consumption of 115 metric
tons and a fuel price of about $250.00 per metric ton.
Therefore, vessel operating costs, independent of laboratory and
incineration plant costs are approximately $167,600 per voyage.
Additional insurance for coverage of the ship's particular mission
will increase that cost.
B. Incineration Plant
The operating costs for the incineration plant are not included in the
standard operating costs for this vessel. Large cost elements in the
operating costs for the incineration plant are the personnel required
to operate the incinerators, the personnel required to perform
environmental and chemical analysis of the burn in progress, and the
auxiliary fuel used to "boost" the combustion of low thermal value
chemical wastes.
The incinerators are specified to operate continuously, so that round
the clock incinerator operator crews have been anticipated. Three
people are likely to be needed to fully monitor the liquid and solid
waste destruction, so nine incinerator operators are needed. These
people are likely to be paid similarly to engineering officers on the
ship operating crew.
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The number of environmental monitoring personnel will depend on
several factors: whether the waste to be burned has been monitored
already, whether full scale chemical analysis will be done on the ship
or at the shore terminal, and whether a periodic full spectrum
performance analysis on the incinerators and their effluents is to be
included in the monitoring on a long term basis. Though all these
varying circumstances mean that the number of environmental monitors
could change frequently, preliminary estimates for the crew have been
developed. Much more detail in this category should be developed for
further stages of the Chemical Waste Incinerator Ship Program.
Tha preliminary estimates are given below.
ENVIRONMENTAL MONITORING PERSONNEL
Senior Chemist 1
Senior Technician 3
Junior Technician 1
Auxiliary incinerator fuel will also be required for three purposes.
First, fuel will be needed to heat the combustion chamber before
self-combusting chemical waste is injected into the incinerator. Fuel
is also needed to ease the thermal shock to the combustion chamber as
it cools after waste combustion is stopped. Second, fuel will be
needed to blend with some waste cargoes in order to guarantee
sufficient heat value to completely destroy the waste. Third, fuel
will be needed to "thin" some viscous cargoes to a pumpable liquid
that can be incinerated efficiently.
Diesel fuel alone is burned for warming up the incinerators and for
gradual cooldown. Each liquid injection unit burns about five metric
tons of fuel per hour during warmup or cooldown. During a ten hour
warmup, the three incinerators will burn about 150 metric tons of fuel
and an additional five hour cooldown would consume about 75 metric
tons. At about $250 per metric ton, incinerator auxiliary fuel for
warmup and cooldown will cost about $56,250.
Fuel costs for the second usage, blending with waste cargoes, is much
more difficult to predict quantitatively. The ideal cargo will
self-combust and many cargoes can be burned with no auxiliary
"booster" fuel. The cost of incinerating low heat value waste cargoes
will include the cost of the additional fuel that is needed to
successfully incinerate the low heat value waste. If high heat value
wastes can be blended instead, the additional fuel cost can be
avoided.
Finally extremely viscous wastes can be thinned with either fuel or
other liquid wastes. As with the previous case blending different
wastes to reduce viscosity will eliminate additional fuel costs.
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PAGE NOT
AVAILABLE
DIGITALLY
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APPENDIX D
to
REPORT OF THE INTERAGENCY
AD HOC VdORK GRCUP FCR THE
CHEMICAL WASTE INCINERATOR
SHIP PROGRAM
-------
DESIGN REQUIREMENTS FOR A WATERFRONT FACILITY TO
SUPPORT CHEMICAL WASTE INCINERATOR SHIPS
FINAL REPORT
by
D. K. Mc Neil, G. Richard, A. M. Takata, arid P. J. Weller
TRW, Inc.
One Space Park
Redondo Beach, California 90278
and
M. L. Neighbors
Diversified Marine Services, Inc.
915 Fifteenth Street, N.W.
Washington, D. C. 20005
Contract No. 68-02-2560
Work Directive No. T5017
EPA Project Officer: D. A. Oberacker
Incineration Research Branch
Industrial Environmental Research Laboratory - Cincinnati
U. S. Environmental Protection Agency
Cincinnati, Ohio 4S268
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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CONTENTS
Foreword D-l
Summary D-2
D.l Design Criteria D-5
D.l.l System Requirements 0-5
D.1.2 Facility Location D-7
D.l.3 Structural Criteria D-8
D.l.4 Safety, Health and Environmental Criteria d-8
D.2 Process Design D-ll
D.3 Preliminary Facility Design D-13
D.3.1 General Features D-13
D.3.2 Subfacility Descriptions 0-17
D.4 Costs D-25
D.4.1 Capital Costs 0-25
D.4.2 Operational Costs D-29
D.5 Existing Terminal Facilities in the United States D-30
References D_35
D-lt
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FOREWORD
This appendix describes the preliminary design of a waterfront
facility as part of the U.S. flagship system for incineration of chemical
waste at sea. This facility will do the following:
• receive liquid and solid hazardous wastes either by
land or by waterborne barge transport
• analyze, blend, shred, and containerize or package
the materials as appropriate for incineration at sea
• load the waste aboard ship in a safe and efficient
manner
• remove and receive residues from the incinerator ship
for analysis and disposal either on land or at sea, in
the case of incineration of wastes producing a collectable
residue during disposal
This design deals only with the equipment and processes located within the
waterfront facility and does not consider transportation of the chemical
waste to and fromthe facility or the ultimate disposal of the waste, other
than to provide for the interface with the appropriate transportation modes.
This design is preliminary and site-independent. More detailed design
requires selection of a site and further analysis.
The discussion in this appendix begins with a definition of the
criteria for the design and proceeds with descriptions of both the process
flow and the actual facility. Capital and operating cost estimates are
presented, and a survey of existing terminals which could be used as
chemical waste waterfront facilities is summarized.
D-l
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SUMMARY
Several design criteria were used in the preliminary design and will
also apply for subsequent design stages. The facility must accommodate
wastes in almost any physical form and in several types of containers, some
of which may be older, corroded, and possibly leaking. Ideally the facility
would service three transportation modes of delivery of wastes: truck, rail
and barge. The facility must consecutively accommodate up to two incinerator
ships, each of which is on a two-week cycle. The required waste storage
capacity of the facility is as follows:
The facility must also provide for preparing and blending wastes for optimum
transfer and combustion, and for unloading ash residue from the incineration
process from each ship.
The ideal site for the facility would be located where potential
environmental impact is minimal, transportation time for the various modes
are minimal, and topography is convenient. Structural standards must be
carefully followed, and these are normally defined by the Uniform Building
Code and additional location-specific building regulations.
The design must also meet safety, health and environmental criteria,
which include provisions for facility monitoring, personnel safety, and contin-
gency planning in the event of both major and minor releases of chemical wastes
that have the potential to reach soil, water, or air. In general these cri-
teria are specified by federal regulations.
Liquid waste, solid waste, and ash residue from incineration will be
processed and stored separately. Liquid waste in drums and other containers
will be sent through a shredder in the dedrumming facility. Liquid from
both the containers and the decontamination of the containers will be blended
to optimize transfer and combustion processes and pumped to storage tanks.
Liquid Waste
Solid Waste
30,000 m3 (181,000 bbl)
1,800 m3 (64,000 ft3)
0-2
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Liquid waste arriving in tank trucks or tank cars, along with the tanker
decontamination rinse, will also be blended and pumped to the storage tanks.
Solid waste arriving at the site will be unloaded at the unloading rack,
prepared for incineration by shredding, and placed in bulk material containers
(BMC) to be loaded on the ship.
The ash residue from the at-sea burn will be returned to the waterfront
facility and kept in the residue storage area until removed for ultimate
disposal, probably in a landfill approved for hazardous waste disposal.
The waterfront facility is designed to prevent emission of hazardous
materials; to contain spills, leaks and other accidents; and to minimize harm
to personnel in the event of accidents. Planned measures include the following:
• collection and disposal systems for vapors from waste transfer
• detailed material balance audits
• dry break valves which prevent spillage during disconnecting
• above ground plumbing and convenient access to fittings
t use of corrosion resistant materials
• pipes sloped away from points of potential discharge
• complete fire prevention and control systems
• security provisions including guards and continuous fencing around
facility
¦ special training in hazardous wastes for personnel
• effluent and media monitoring in and around facility.
• dikes around liquid storage areas
The facility is expected to require approximately 75,000 square meters
(18 acres) of land and will require a staff of approximately 40 to operate
on a two-shift schedule.
Capital costs for the installed facility (excluding dock rental and
land costs) are estimated to be $19 million in 1980 dollars. Land costs
will vary greatly depending on the location and are expected to be in the
range $5 to $20. million. The operating costs, including labor, maintenance,
depreciation, power and ash disposal, are estimated to be $4 million annually.
D-3
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This excludes insurance costs and potential land and dock rental costs.
Insurance premiums are estimated to be $3 million to $6 million annually.
In case the land and dock will not be purchased, lease costs will be at least
$300,000 annually.
The survey of existing terminal facilities in the United States found
that 139 ports and 1,221 terminal docks, piers or wharves on the East, Gulf,
and West coasts of the continental U.S. have sufficient water depth and space
to receive the incinerator ship. These terminals are concentrated primarily
in the states of Texas, New Jersey, Louisiana, California and New York. Most
terminals are privately owned. These owners feel that compliance with regu-
lations not yet finalized is the major determinant of their ability to handle
hazardous wastes. The technical feasibility to handle these wastes is a
secondary question. Several military depots appear to have capability for
handling both liquid and solid hazardous wastes and this possibility should
be explored further.
None of the bulk liquid terminal operators thought it advisable to provide
solid waste service at a bulk liquid terminal, primarily because of differences
in the handling characteristics of the wastes. Although separate facilities
for liquid and solid wastes are not necessarily a recommendation of this
report, it is suggested that this apparent concern be investigated further.
0-4
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D.l DESIGN CRITERIA
The waterfront facility must meet several sets of external requirements
and constraints imposed by pertinent regulations and by considerations asso-
ciated with the functioning of the entire system for shipboard incineration
of chemical waste. These requirements and constraints translate to design
criteria and fall into four categories: system requirements, facility
location, structural criteria, and safety, health, and environmental
criteria.
D.l.l System Requirements
This section defines the requirements of the waterfront facility as a
part of the entire system design for chemical waste disposal using inciner-
ator ships. These requirements include waste types, transportation modes
that the facility must accommodate, the necessary waste throughput and
storage capacity, the preparation necessary before loading onto the inciner-
ator ship, and the capability to handle the ash residue from solid waste
combustion.
The waste type to be expected at the facility has been defined in
Appendix C of this report:
"...combustible, organic hazardous chemicals, including
organohalogens and other petrochemicals whose combustion
generates very corrosive flue gases."
It must be expected that waste delivered to the facility could take almost
any physical form, including bulk solids, liquids, pulp, granular solids,
slurries, and mixtures of any of these. Some waste will be delivered in
mobile tankers, other waste will be in containers. Common forms of con-
tainers expected for the delivered waste are 55 or 30 gallon steel drums,
fibrous drums, and bulk containers filled with bottles and cans of miscel-
laneous size. Most containers (especially older containers) holding
liquids will be corroded and leaking.
The ideal facility would service three transportation modes for
delivery of waste: truck, rail, and barge. Access to the facility from
transportation corridors, appropriate unloading equipment, and decontami-
nation areas must be provided for each of the actual modes.
D-5
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The facility must consecutively accommodate up to two incinerator
ships, each of which is on a two week cycle. Thi§ cycle is described in
Appendix C. The capacity of each of these ships is as follows, where the
cargo weights for liquid and solid wastes have been equated to volumes by
assuming that the specific gravity of the liquid waste is 1.0 and the bulk
3 3 *
density of shredded solid waste is approximately 0.8 g/cm (50 lb/ft ).
Cargo Weight Cargo Volume
Liquid Waste 7200 metric tons 7200 m3 (45,300 bbl)
Solid Waste 360 metric tons 450 m3 (16,000 ft3)
These values also represent the weekly throughput of waste from the facility
It is recommended that the storage capacity of the facility represent four
weeks of throughput. The required volumetric storage is as follows:
Liquid Waste 30,000 m3 (181,000 bbl)
Solid Waste 1,800 m3 (64,000 ft3)
The waste delivered to each ship must be prepared and blended for
combustion. Shredding will be required for some solids, and liquids will
be blended to optimize the heating value of the waste stock in storage at
the facility and to improve the properties of liquids (such as viscosity)
during transfer operations. In some cases, it will be necessary to add
fuel oil to the waste to provide the necessary combustion temperature. It
is recommended that this fuel oil be blended with the waste at the facility,
although it is possible for the ship to add fuel oil during combustion at
the burn site.
The facility must also provide for unloading the ash residue from the
incineration process from each ship, storing it, and loading it for trans-
port to ultimate disposal. If this ash represents 10 percent by volume of
*
This value is used here to calculate a conservative volumetric requirement
for storage. The actual average density is difficult to estimate. Actual
material and bulk densities range widely.
**
1.0 metric ton =0.98 long ton
D-6
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the original solid waste, the weekly throughput of residue will be
45 cubic meters (1,600 cubic feet). Four weeks of storage is equivalent
to 180 cubic meters (6,400 cubic feet).
D.1.2 Facility Location
This section defines the locational requirements for the facility in
conjunction with port shiploading facilities for incinerator vessels.
Major considerations in the selection of potential sites for locating such
a facility include public safety, protection of the equipment, and cost.
The ideal site would:
• not be located in a heavily populated area
• not be located in a fault area nor in a 100 year
flood plain (Resource Conservation and Recovery Act
(RCRA) requirement; 40 CFR 250.43-1)
• be located so as to minimize transporation time and
distance to the facility
• be located in close proximity to an existing or
potential hazardous waste landfill
• be located where port facilities are adequate for
safe harboring and loading of incinerator vessels.
The ideal facility would service three transportation modes for
delivery of wastes including truck, rail and barge. Locating the facility
near existing transportation corridors will minimize system costs and
reduce some safety risks inherent in transporting hazardous materials long
distances.
The standards applicable to transporters of hazardous waste are
addressed by RCRA. These standards are coordinated with applicable U.S.
Department of Transportation regulations for identification and transport
of hazardous materials, 49 CFR Parts 171-173 and 179.
¦ Also of concern in locating the terminal is the proximity to a landfill
approved for disposal of hazardous wastes. The terminal will receive
hazardous incineration residues which must be disposed of in an environ-
mentally acceptable fashion on land. RCRA 40 CFR Parts 264 and 275 are
standards applicable to owners and operators of hazardous waste treatment,
D-7
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storage and disposal facilities. These standards will apply to the
waterfront facility and will also delineate land disposal facility require-
ments for hazardous waste.
From the system design standpoint, it is optimal that the facility be
located at the waterfront, although it may be necessary, depending on the
specific site, to locate the unloading and storage subfacilities away from
the water. In order to preserve the general applicability of this appendix,
the terminal design has been based on the assumption of a waterfront
facility. The adequacy of the terminal facilities must be addressed with
local port authorities. The port must provide safe harboring and loading
facilities, and be capable of meeting the 7 meter (23 foot) draft,
25 meter (82 foot) beam, and 140 meter (450 foot) length requirements of
the incinerator vessel.
D.1.3 Structural Criteria
Structural criteria depend largely on local conditions and local build-
ing codes. Earthquakes on the West Coast and high winds due to hurricanes
on the Gulf of Mexico coast would be primary considerations for structural
design af facilities in those areas. Another factor varying locally is the
bearing capacity of the soil at the site. An example of an appropriate
building code is the South-East Region Uniform Building Code (UBC) used by
many municipalities in the Gulf Coast region. Under the UBC, the wind
velocity used for structural design in these areas is 110 mph. In addition,
structural design must be consistent with local zoning plans and all local,
state and federal regulations.
Particular attention must be paid to the strength of the storage tanks
and the vulnerability of pipelines carrying hazardous materials to heavy
winds and earthquakes. In addition, all structures should be designed to
withstand explosions, and storage tanks and other facilities coming into
direct contact with hazardous wastes must be designed of materials which
are resistant to corrosion.
0.1.4 Safety, Health and Environmental Criteria
This section addresses the safety, health, and environmental require-
ments for the waterfront facility. Design and equipment requirements for
D-8
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the facility will be influenced by regulations dealing with the handling,
storage and disposal of the most toxic and/or hazardous substances. Perti-
nent regulations concerning safety, health and environmental criteria
include standards for facility monitoring, personnel health and safety,
environmental protection and contingency planning.
Facility Monitoring. Standards in RCRA for owners and operators of
hazardous waste treatment facilities require that operators prevent air
emissions which would violate standards or regulations promulgated under
sections 110-112 of the Clean Air Act. Control and disposal of vapors and
other discharges of hazardous substances as a result of facility operations
are essential for the protection of personnel and the environment. To
insure that no federal, state or local air or water quality regulations
are violated, proper facility design and an adequate monitoring program
are necessary. The Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA) part 165 also recommends the establishment of monitoring systems
at pesticide waste disposal facilities. At a minimum, samples from the
surrounding air, water, wildlife and plant environment should be tested
in a regular program to assure minimal environmental impact. Analysis
should be performed in accordance with Association of Official Analytical
Chemists (AOAC) methods and standard methods described in federal environ-
mental regulations. It is important that testing protocols and schedules
be carefully defined during consequent stages of the facility design
process.
Personnel Safety. Regulations controlling the health and safety of
personnel in the working environment are addressed in the OSHA Safety and
Health Standards, 29 CFR 1910, Subpart H (Hazardous Materials) and Sub-
part Z (Toxic and Hazardous Substances).
Under section 19a of FIFRA, procedures -and regulations are established
for the disposal or storage of pesticides and pesticide containers. Under
Subpart C, section 165.10, safety precautions are delineated.
The maintenance of personnel safety requires the implementation of an
effective personnel hygiene program and appropriate safety procedures. A
comprehensive health and safety plan must be developed for the waterfront
D-9
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handling facility. This plan should be in compliance with pertinent
regulations and include basic requirements for effective personnel hygiene
and equipment.
Contingency Planning. Key elements of a contingency plan include
preparedness, prevention, notification, and emergency procedures. Although
site specific details cannot be addressed in this appendix, the basic
features of these elements can be discussed. Upon selection of a facility
location, a detailed contingency plan must be prepared in accordance with
RCRA regulations in 40 CFR 265.5 and Section 311 of the Clean Water Act.
Design of the facility should provide for emergency control. Emer-
gency equipment such as safety suits, shovels, brooms, pails, and sandbags
should be prominently located and available for use in containment activi-
ties. Site personnel must be trained in the use of emergency equipment
as well as the maintenance of facility storage and handling equipment.
Local hospitals, fire departments and emergency response teams must be
apprised of facility operations.
The facility emergency coordinator should be completely informed of
any release of chemical waste that either reaches or has the potential to
reach soil, water, or air. All incidents must be documented with respect
to time, location, severity, cause, type of pollutant, etc. The recom-
mended notification format is the U.S. Air Force Pollution Incident
Notification Format, AFR 19-1, Items 1 through 12. Standard forms have
been developed and are readily available for this purpose.
Incidents which are judged to be major by the facility emergency
coordinator also require immediate notification of the facility supervisor
and the following:
• EPA Regional Administrator or his designee
• Oil and Special Materials Control Division, Spill
Prevention and Control Branch, EPA, Washington, D.C.
• U.S. Coast Guard (USCG) National Response Center
(NRC), Washington, D.C.
• . Director, Center for Disease Control, U.S. Public
Health Service, Atlanta, Georgia.
D-10
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For incidents that occur during non-duty hours, the NRC will use a »list of
on-call personnel from the Oil and Special Materials Control Division, EPA,
Washington, D.C., to implement notification.
Incidents which have the potential to reach coastal waters are under
U.S. Coast Guard jurisdiction. In those cases, initial spill notification
will be made to the appropriate USC6 District Headquarters. Previously
listed notifications will be made immediately following Coast Guard
noti fication.
All agencies must be contacted in the above scheme. If notifying
personnel are unable to contact a listed agency, the next listed agency
should be contacted. This procedure continues until all agencies have
been contacted.
In the case of minor spills, leaks or discharges, the facility
emergency coordinator can determine the appropriate cleanup procedures.
Minor incidents must also be documented, although notification require-
ments are not as extensive as for major incidents. The recommended
notification format is the U.S. Air Force Pollution Incident Notification
Format, AFR 19-1, Items 1 through 12.
D.2 PROCESS DESIGN
Figure D-l is a generalized process flow chart. Although it may be
found preferable in subsequent design phases to have separate waterfront
facilities for liquid and solid wastes, this appendix considers only the
case of a combined facility. The advantages of separate facilities will
depend on existing locations and more detailed analysis of operational
considerations.
Each of three major waste streams is processed in a different manner
Liquid waste in drums and other containers will be sent through a shreddei
in the dedrumming facility. Liquid from both the containers and the decon-
tamination of the containers vnll be blended for incineration, if necessary:
and pumped to storage tanks. Liquid waste arriving in tank trucks or tank
cars will be transferred to the receiving and testing tanks. Then, along
with the tanker decontamination rinse, these wastes will be blended, as
necessary, for incineration and pumped to the storage tanks.
D-ll
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TRANSPORTATION
POOL
Figure D-l. Waterfront Facility Process Flow
D-12
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Solid waste arriving at the site will be unloaded at the unloading
rack, prepared for incineration by shredding, and placed in bulk material
containers (BMC) to be loaded on-the ship.
The ash residue from the at-sea burn will be returned to the water-
front facility and kept in the residue storage area until removed for
ultimate disposal, probably in a landfill approved for hazardous waste
disposal.
Detailed records must be kept at all stages of the flow of wastes
through the site. Mass balances will be calculated to help prevent loss
of hazardous material. Particularly important are records of incoming
waste quantities, amount of solvent used in decontamination, blending
ratios, amounts of material in storage, amounts loaded on ship, and
quantities of ash residue returning to and leaving the site. Care must be
taken to continuously inventory waste disposition. This will allow proper
blending practices and, in the event of a spill or leak, identification of
the source will be sufficient to identify the material and decide on
appropriate action.
D.3 PRELIMINARY FACILITY DESIGN
The waterfront facility area, occupying approximately 75,000 scuare
meters (18 acres), includes a support building; chemical waste receiving,
preparation, and storage facilities; and ship loading and unloading
facilities. Figure D-2 shows a conceptual layout of the facility. (The
layout for the actual site will be somewhat different due to specific
topographical and property considerations.) Open space for expansion of
these various facilities is also provided. The perimeter of the site is
enclosed with a fence having rolling gates at the road entrance and at
the rail siding entrance. The access road enters the complex and leads
to the receiving tanks, the tanker decontamination facility, the solid
waste storage area and the residue storage area. The rail siding provides
access,to both the receiving tanks and the tanker decontamination facility.
D.3.1 General Features
The waterfront facility is designed to prevent emissions of hazardous
materials; to contain spills, leaks and other accidents; and to minimize
harm to personnel in the event of accidents. Several measures will be
D-13
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140 N (410 'T)_
Figure D-2. Waterfront Facility Layout
D-14
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employed to avoid emissions of hazardous wastes during handling. Vapor
collecting systems will be installed throughout the facility to capture
vapors released during loading and unloading of wastes. The vapors will
be routed to a surge tank and processed through a vapor disposal system.
Articulated loading arms with vapor shields and closed-loop return lines
will be used for loading liquid wastes into the ship. Piping, manifolds,
pumps and valves interfacing with marine loading arms will drain back to
receiving tanks where the liquid can be returned to storage. Buildings
housing waste processing and transfer operations will be maintained at a
slightly negative pressure. All tanks, piping, pumps, manifolds and
valves will be located above ground for ease of installation, inspection,
maintenance and replacement. All connections will use dry break valve
fittings, which prevent loss of liquid when the pipes are disconnected.
Piping will slope away from initial connections so as to eliminate leakage
if a valve failure should occur. The tanks themselves must be constructed
from materials resistant to corrosion over long periods of contact with a
wide variety of hazardous wastes.
Safeguards against accidents will be included in the design. It is
essential that all personnel responsible for handling and loading the
hazardous wastes are properly trained to prevent accidents. The laboratory
will be equipped with the appropriate safety equipment, and the entire
facility including the interior of the support building will be monitored
to detect hazardous material emissions. Both fugitive emissions and
ambient air quality will be monitored extensively. In addition, the water
sediment,and soil in the area will be monitored. The detection system will
be connected with local emergency alert systems. Testing protocols con-
sistent with the protection of workers, the environment, and public health
must be developed specifically for this facility.
In the event of leakage, the site and its operations are designed to
prevent or minimize impacts. Curbs surround the tanker unloading area and
dikes surround all of the hazardous waste storage areas to retain spills.
The dikes will be high enough to contain a volume of liquid equal to the
capacity of the largest storage tank and the curb loading area will hold at
least the maximum capacity of any single tanker unloading at the site, plus
0.3 meter (one foot) of freeboard in each case. The storage areas
0-15
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themselves are lined with reinforced concrete to render the diked area
essentially leakproof, and a drainage system will contain and remove any
spilled liquid waste. The entire complex has an impermeable barrier to
prevent toxic wastes from entering aquifers, estuaries or other nearby
waterways. This barrier remains impermeable in the event of a fire or
explosion, so that wastes will still be contained.
Provisions are made to minimize injury to site personnel from
accidents. First aid stations and deluge shower facilities are located
in all areas, including the laboratory and the unloading areas, where
personnel might come in contact with the toxic materials. In addition to
first aid supplies, personnel with proper first aid training should be on
site at all times. Personnel protective equipment, such as respirators
and self-contained breathing apparatus, will also be available on site
for emergencies.
Fire prevention measures must also be designed into the facilities.
Overhead sprinklers, deluge showers, hose racks, portable extinguishers
and hydrants are located in appropriate areas throughout the complex.
The hydrants and portable extinguishers will be located according to local
ordinances. Corranunications with local fire emergency services will also
be provided.
Security measures for the site, designed to protect property as well
as to improve safety, include guard personnel at the gates, a night watch-
man, and a seven foot chain link security fence topped with three strands of
barbed wire.
A total of forty people are required to operate the facility two
shifts daily. Table D-l lists the required personnel, their duties, and
the shift requirement:. Actual staffing will vary from this general plan
according to the specific site plan and location. All operators, mainte-
nance, and security people will be trained in emergency procedures and
assigned specific responsibilities to be carried out during spills and
spill cleanup.
0-16
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Table D-l. Personnel
Position
Description of Duties
Number Per
Shift
Day
2nd
3rd
Facility Supervisor
Oversees and directs operations throughout the facflfty,
throughout the day
7
Second Shift Supervisor
Oversees and directs operations during the second shift
1
System Operator
Manages the flow of liquid wastes, fuel, and solvent
throughout the facility (unloading, blending, ship
loading)
Handles all waste containers, (unloading, moving to and
from storage and shredder, loading ship)
3
3
Forklift Operator
2
2
Container Processor
Operates shredders and directs flow of material to and
from shredding facility
2
2
Water Treatment Operator
Operates water treatment facility
1
1
Analytical Chemist
Designs analytical procedures and supervises analysis
of incoming wastes, blended wastes, ash residue and
monitoring samples
1
1
Laboratory Technician
Collects and prepares samples for analyzers; carries
out standard analytical procedures
3
3
Secretary
Does clerical work
2
Maintenance
Handles mechanical, electrical, plumbing and carpentry
work, performs both routine and emergency maintenance
on all equipment
3
3
1
Security
Keeps out unauthorized personnel ant checks on employees
working alone
7
7
Night Watchman
Patrols the facility during the third shift when opera-
tions are shut down*
1
Janitor
General cleanup
J.
J_
20
IB
2
a,The night watchman will also stay 1n contact with the night maintenance worker and any other employees
working the third shift under special circumstances.
D.3.2 Subfacility Descriptions
The important subfacilities in the design are discussed below. Since
this design is preliminary, both the exact location of each subfacility in
the site plan and the design details for each subfacility cannot be speci-
fied completely.
Tanker Unloading. An unloading facility is located between a branch
of the access road and the rail siding and is capable of removing solid or
liquid wastes from tank trucks and tank cars, in addition, equipment
designed to unload wastes from barges is located on the waterfront. Liquid
wastes transported 1n bulk are then pumped to the receiving tanks. Cranes
and conveyors are also on site to unload drums, other containers', and bulk
D-17
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solids. Portable bins will be used to store both small containers and
solid wastes which cannot be processed immediately. Provision will be
made to sample the waste, both before and after preparation for incinera-
tion, so it can be analyzed in the laboratory.
Container Processing. Drums and other containers of liquid and solid
wastes are moved to the container processing facility. The containers
are fed by a conveyor or forkl'ift into shredders located within enclosures
vented to a vapor collection and treatment system. Two shredders (or sets
of shredders), one for liquid wastes and the other for solid wastes,
process both drums and smaller containers.
The shredder for liquid waste containers will drain off the liquid,
rinse the container shreds with an appropriate solvent, and send the
liquid waste and rinse to the blending facility (see Figure D-3). The
container shreds will be disposed of by landfill or salvaged. Some
container shreds may require thermal decontamination prior to disposal
or salvage, depending on the waste type and suitability of solvents.
Containers of solid wastes will also be shredded, and both the con-
tainers and wastes will be put in bulk containers which eventually will be
loaded on the incinerator ship (see Figure D-4).
Low speed, high torque, 150 horsepower, shear-type shredders will be
used. This type of shredder is capable of handling almost all types of
materials, and containers, and is virtually jam proof. Shear-type shredders
produce a minimum of fines and do not agglomerate the material. Such
shredders are available in many combinations of speed and torque and can be
chosen to suit the type and amount of material to be handled at the site.
Although many safety features are designed into this type of shredder
to minimize noise, chances of explosion, and hazards of flying objects, it
is advisable to take additional precautions regarding explosion because
of the potentially severe consequences of accidents at this facility. One
option is to allow only an inert or evacuated atmosphere in the shredding
enclosure and to electrically ground the shredder blades to minimize
frictional sparking. Highly explosive materials, presenting great danger
in the shredder, will require special handling procedures.
D-18
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Figure D-3. Containerized Liquids Processing
Figure D»4. Containerized Solids Processing
D-19
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Decontamination. In close proximity to both the rail siding and the
access road is the tanker decontamination facility. This facility will be
designed to decontaminate the barges and ship containers as well as tank
cars and tank trucks. A multiple-rinse procedure will be used for decon-
tamination. Rinse solvents, depending on the waste remaining in the tank
or container, may be water, fuel oil, or other liquid.
Preparation and Storage. Once removed from tankers or containers to
the receiving and test tanks, the liquid wastes are, if necessary, blended
with either fuel oil or other waste liquids to produce a mixture with a
heat content sufficient to burn properly in the ship incinerators (approxi-
mately 13,000 kJ/kg (5500 Btu/lb). For example, a liquid hazardous waste
with a very low heat content may be mixed with another waste with a very
high heat content in order to produce a waste mixture which will burn well
at sea.
Solid wastes coming either directly from train, truck, or barge, or
from the shredding facility are placed in bulk containers which are loaded
on board the incinerator ship.
Storage facilities able to handle both liquid wastes and solid waste
are necessary. Two adjoining areas, one for liquids and one for solids,
each surrounded by a dike, will hold wastes until they are put aboard ship.
Liquid wastes will be stored in an 8,400 square meter (90,000 square foot)
area containing tanks totalling 30,000 cubic meters (181,000 barrels) in
volume. Tanks containing solvent will also be in this area. The adjacent
area of 5,600 square meters (60,000 square feet) is designed to store both
solid wastes and liquid wastes in containers. Ramps over the dikes provide
access into and between the storage areas. The storage areas are located
away from the dock to help prevent accidental spillage or leakage into the
harbor.
Vessel Loading. Along the dock is a series of articulated loading
arms designed to load the liquid hazardous wastes on board the incinerator
ships. The loading arms are equipped with vapor shields and closed-loop
return lines designed to prevent accidental emission of hazardous wastes.
Vapor collection systems route emissions to a central vapor disposal sys-
tem (i.e., an incinerator or absorption unit).
D-20
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Also along the dock are cranes able to load the containers of solid
wastes onto the deck of the ship. In addition, tanks for storage of ship
fuel are located near the dock.
Vapor Control. A variety of collection and disposal systems may be
employed to prevent emissions produced during the loading, unloading and
storage of hazardous liquid wastes. Safety is a principal concern in the
management of the vapor collection/disposal system. To prevent the
collected vapor emissions from reaching an explosive mixture, precautions
are required. Saturation and dilution are common alternate methods used
to prevent explosions. Dilution is typically employed for vapors con-
taining low concentrations of hydrocarbons, which are characteristics of
the heavy hydrocarbons comprising the hazardous waste liquid mixtures.
High volume blowers provide dilution air and the motive force collecting
the vapors.
The best means of vapor disposal is combustion by incineration. The
diluted gas mixtures are combined with fuel and additional combustion air
(if necessary) at the burner to obtain very high destruction efficiency.
A scrubber will also be used to remove inorganics in the combustion gases.
The incinerator combustion efficiency will be monitored according to
requirements of the appropriate permitting authority, and operating param-
eters such as temperature and excess oxygen may also be regulated based on
initial performance tests.
Such incinerators are commercially available and allow a wide flexi-
bility for varying capacity and concentration. Often, however, the
collected vapor is routed to a vapor holding tank to permit more consistent,
efficient and economical operation of the incinerator. When vapor holding
tanks are employed, adsorption units (e.g., activated carbon) may be used
as an alternative to incineration for efficient removal of organics. Since
many variables affect the selection of the collection and design system, a
complete economic analysis would be necessary to determine the optimal
design.
D-21
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Residue Receiving and Storage. In addition to loading the ships with
hazardous wastes, shore facilities must also be designed to unload the ash
residue from returning ships. A 3,700 square meter (40,000 square foot)
storage area to hold the residue in containers prior to removal from the
site is located adjacent to the unloading equipment. This waste can be
directly removed by truck via the access road or transported up to the
rail siding and removed by rail.
Support Building. The Support Building provides 460 square meters
(5,000 square feet) of space for offices, a laboratory and toilets. The
laboratory is made up of three rooms, a receiving and storage room of
40 square meters (400 square feet), a preparation area of 60 square meters
(600 square feet) used to prepare samples of waste for laboratory analysis,
and an area for analytical work, also occupying 60 square meters. The
laboratory will be capable of performing both physical and chemical
analyses of the wastes to be loaded on the ships and of the residue returned
to land after incineration. A typical inventory of equipment is shown in
Table D-2. Other standard laboratory equipment,such as microscopes, heat
sources, reagents, and glassware have not been included in this table for
the sake of brevity. The primary value of the gas ctvroraotograpb (GC)
and high pressure liquid cliroma to graph {HPLC] is to help assess performance
of the shipboard incinerator during the implementation phase. Requirements
for organics identification during the routine operation of the incinera-
tion system could be satisfied by contractor laboratories, depending on
required turnaround. Purchases of a GC and a HPLC have been included
in the capital cost estimate to be conservative. The laboratory gives
the operator of the site the ability to analyze the incoming wastes
accurately and quickly so that proper preparation procedures and incinera-
tion procedures may be decided. Analyses of returned incineration residue
will allow sound storage and disposal decisions to be made.
In addition to local laboratory and toilet ventilation, the Support
Building will have an Environmental Control System (ECS) incorporating air
conditioning for warm weather and heating for cold weather.
0-22
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Table D-2. Equipment List for Laboratory Analysis of Waste
Instrument
Purpose
Physical Analysis
Laboratory-size shredder (2)
Solid sample preparation
Calorimeter (5)
Heating value and combustibility
Specific gravity balance (3)
Specific gravity of liquids
Brookfield viscosimeter (3)
Viscosity measurement of liquids
and sludges
Imhoff cones and centrifuge
with graduated tubes (2)
Percent solids by volume
Cleveland open cup flash point
detector (3)
Flash and fire point
determinations
Muffle furnace, oven, and
balances (4)
Percent ash, solids, and moisture
by weight
Differential thermal
analyzer (2)
Explosion characteristics and
fusion temperature
Juno meter or equivalent (1)
Radioactivity
Chemical Analysis
Gas chromatographa (1)
Organics identification
High pressure liquid
chromatographa (1)
Organics identification in low-
volatility wastes
Atomic absorption
spectrograph (2)
Metals concentration
pH meter and automatic
titrator (4)
Acidity and alkalinity
C, H, N, CI, and S analyzer (1)
Elemental composition
a'May be required only during implementation phase of incineration
system.
Utilities. Fuel gas service from the local public utility will be
used at the complex for the hot water heater in the support building and
for burner outlets in the laboratory. A maximum of approximately 1.7 cubic
meters (60 cubic feet) per hour will be required. A delivery pipe will run
from the property line to the support building.
D-23
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The facility will utilize commercial electric power also from the
local public utility. Power is needed for lighting, convenience receptacles,
and environmental control systems in the support building, as well as elec-
trical equipment, such as pumps, used throughout the facility.
Municipal water and sewage systems will also be used. Only the drains
from the toilets and the laboratory will be connected to the sewage system,
and laboratory waste will be sampled regularly to avoid emissions of
hazardous waste by this path. Waste sample residues from the laboratory
and all other waste generated on site will be separately contained for
disposal by other means (ship incineration or landfill) to avoid putting
toxic wastes in the local sewage system.
Storm Runoff and Mater Treatment. An onsite water treatment facility
will treat water contaminated by hazardous wastes. The entire unloading
and storage area is designed so that any liquid on the ground will flow
downhill into drainage channels leading to a catch basin. Normal storm
runoff will proceed to the water treatment facility and, if no treatment
is required, or if it is cleaned sufficiently, on into the port waters.
However, in the event of a spill beyond the capacity of the water treat-
ment facility, the outlet of the drainage system will be closed and the
liquid will be retained until it can be pumped to the storage tanks. The
outlet of the treatment facility will be monitored to help avoid any dis-
charge of hazardous materials. Storm runoff bypassing the treatment
facility will also be monitored.
Fire and Safety. Also located on the site is a building housing fire
and safety equipment. Included are extra fire extinguishers, hoses, and
a large quantity of adsorbent to temporarily contain small spills. The
fire and safety building is shown on the Figure D-2 layout, but its loca-
tion is somewhat arbitrary.
Expansion. Chemical waste generation is projected to increase during
the coming years and land disposal is becoming less satisfactory. There-
fore it is important that the site is designed to accommodate expansion.
The facilities most likely to be expanded are the storage areas and,
therefore, open space is located near each of the three storage areas.
D-24
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Miscellaneous. A maintenance building and dock controls are also
included among onshore facilities. While these facilities are shown in
Figure D-2, their locations are somewhat arbitrary.
D.4 COSTS
Capital costs are based on information supplied by vendors and on
unit costs developed for the onshore support facility in the Offshore
Platform Feasibility Study (2 ). The major costs involve engineered
systems which are not available as off-the-shelf items. These systems
require extensive design before accurate cost estimates can be developed.
Costs for these systems have been estimated here based on vendors' know-
ledge of costs for similar systems previously supplied for analogous
applications in other industries. For those standard off-the-shelf
items which can be identified at the preliminary design stage, costs
were provided by vendors based on list costs of the equipment.
Operational costs include labor, supplies, utilities, maintenance,
and depreciation of equipment and buildings. A yearly maintenance cost
factor of eight percent of the installed equipment cost was assumed, and
depreciation costs were based on a 15-year period for equipment and
buildings. The cost of labor has been estimated for each of the Tabor
categories based on wage information presented in the Platform Study
(2 ). Significant utilities costs are based conservatively on a peak
load requirement of 400 kw extended throughout the two-shift work period.
D.4.1 Capital Costs
Table D-3 summarizes capital costs for major components of the
facility preliminary design. Dock construction and land costs are
excluded from this table. The major cost items involve engineered sys-
tems such as the marine loading terminal, the bulk unloading rack, and
the facility plumbing system. Although some standard off-the-shelf
items may be purchased for direct installation, most equipment will have
to be engineered into an appropriate system before it may be utilized.
The terminal equipment is described in terms of subfacilities, since a
detailed examination of the individual system components for the numer-
ous design alternatives is not consistent with the intent of this pre-
liminary study. Subsequently, many of the subfacility cost estimates
presented here should be considered rough estimates (+_50% accuracy).
D-E5
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Table D-3. Capital Costs of Waterfront Facility Installation
Description of Equipment
Total
Installed Cost
(1980 Dollars)
Activated carbon water treatment system for rinse and washdown wastewaters
(1,400 m3/day)
$ 900,000
Bulk material containers (3.3 m3). 1,900 bins for storage of incoming miscellaneous
containers of solid and liquid waste, containers for shredded solids, and 70 con-
tainers for ash residue from incineration.
2,200,000
Dock loading crane (10 metric ton capacity at 30 m)
500,000
Marine terminal loading dock apparatus (including meters, valves, loading arm
assemblies, control systems and support structures
4,000,000
Tanker bulk liquid unloading rack (including tanker decontamination system)
2,000,000
Monitoring instrumentation (including gas analyzers, recorders, sampling equipment)
125,000
Security-accountability system (software to inventory wastes, sources, disposition,
cost information, potential hazards)
120,000
Liquid waste storage tanks (carbon steel, fixed cone roof) and tank site preparation
8 each 3000 m~ capacity
10 each 1200 m3 capacity
10 each 300 m capacity
1,270,000
910,000
400,000
p
Epoxy coating for 14,750 m of tarvk interior
430,000
Fuel tanks (2) of 2,370 m3 capacity
250,000
Installation, plumbing, and system controls for waste storage tanks, blending, and
fuel tanks
3,000,000
Vapor collection and disposal system (incinerator and scrubber) for bulk unloading
racks, marine terminal loading, storage tanks, container decontamination, and
container shredding
1,500,000
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Table D-3. Capital Costs of Waterfront Facility Installation (Continued)
Description of Equipment
Total
Installed Cost
(1980 Dollars)
Enclosed system to process containerized solids for incineration
Bin unloading mechanism
Shredder (2.3 metric tons/hr)
Conveyor
Plumbing and drain tank
Emission collection system (baghouse and blower)
Enclosure (6m x 21m)
$ 5,900
67,000
4,200
5,000
30,000
60,000
Enclosed system to process containerized liquids for incineration
Bin unloading mechanism
Shredder (2.3 metric tons/hr)
Conveyor
Plumbing and drain tank
Vapor collection system
Enclosure (6m x 21m)
5,900
67,000
4,200
10,000
10,000
60,000
Safety and fire equipment
40,000
Site preparation
37,000
2
Paving-concrete (22,500 m diked areas)
350,000
Paving-asphalt
87,000
Railroad siding (240m)
53,000
Fencing (750m)
34,000
Administrative buildings and laboratory (460 m )
235,000
Heating, ventilating, air conditioning
22,000
Electrical
215,000
Laboratory Equipment
360,000
Total Capital Cost of Installed Facility (excluding dock construction and land costs)
$19,000,000
-------
All facility costs include contractor overhead and profit (25%), contingency
(10%) and engineering (10%).
No land acquisition or dock construction costs have been included in
the cost estimates. These costs will vary greatly depending on the loca-
tion. Based on data presented in the National Port Assessment (16) the
average construction cost of a single berth at a seaport terminal facility
for transport of liquid bulk petroleum is $5 to $20 million. The cost of
seaport terminals handling hazardous liquid waste would be substantially
greater than the typical petroleum handling terminal. However, these costs
may be minimized if federal dock facilities and nearby property are
available.
The number of bulk material containers (BMCs) required at the ter-
minal was estimated based on the storage capacity of the standard BMC
and the total solid or containerized liquid wastes which will be stor-
ed at the terminal. It was assumed that the quantity of liquid wastes
received in small containers is equal to 20 percent of the total liquid
waste received, and that one-half of these containerized liquids have
been processed and routed to bulk storage while the other half are stored
in BMCs awaiting processing. The amount of solid waste which' is stored
is 1,440 metric tons and the amount of incinerator ash residue stored is
144 metric tons. The density of the waste material was assumed uniform
and the capacity of each BMC was estimated conservatively as two metric
tons. Vendors place the cost of the BMC at $937 each.
The capital cost of the water treatment system was based on cost
estimates published for the treatment system evaluated in the Platform
Study (2 ). The cost was adjusted according to the system capacity
requirement, which was estimated based on the quantity of wastewater
runoff which would be expected from the diked areas during a 24-hour
rainstorm producing five centimeters (two inches) of rain, plus waste-
water produced by normal daily washdown and decontamination rinse
operations.
D-28
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The cost of laboratory equipment has been estimated based on
consultation with analytical chemists who participated in pertinent related
studies (2, 3, 4, 5, 8, 11). The costs of required accessories and support
equipment were conservatively estimated at 50 percent of the cost of the
major equipment items listed in Table D-3. Contractor costs for engineer-
ing, overhead, fee, and contingency were also included in the overall
estimate.
The total capital cost of the terminal is estimated to be $19 million.
This value is consistent with the $20 to $50 million range of cost esti-
mates provided by Henry (9 ) and with costs estimated for the smaller
facility of the Platform Study (2 ). The annualized capital cost, amor-
tized over a 15-year economic lifetime at an interest rate of 10 percent,
is $2.5 million.
D.4.2 Operational Costs
Table D-4 summarizes costs of operation for the waterfront facility.
Insurance costs are not included in the estimate. This cost will vary
greatly depending on several factors (e.g., toxicity of waste, trip
lengths) and may exceed all other operational costs combined. It is
estimated that insurance coverage to allow $50 million per incident for
the entire at-sea incineration enterprise would be available at annual
premiums of $3 to $6 million (9 ).
Also omitted in the cost summary are potential land and dock rental
costs (in case land and dock will not be acquired). Lease costs vary
greatly by location. Costs investigated for the Mobile, Alabama area in
the Platform Study (2 ) were assessed at $3.90 per square meter ($0.36
per square foot) of industrial land with intermittent access to dock
facilities. Applying this rental rate to the present facility design,
annual lease costs would be approximately $300,000. However, this lease
rate should be considered a low estimate since the magnitude of the pro-
posed terminal operations would require total dedication of the docking
faci1ities.
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Table D-4. Annual Operating Costs
Item Description
Annual Cost
Total Labor (including overhead)
$1,100,000
- Facility supervisor, 2 at $79,000/yr $158,000
- System operator, 6 at $40,000/yr 240,000
- Forklift operator, 4 at $26,000/yr 104,000
- Container processor, 4 at $26,000/yr 104,000
- Water treatment operator, 2 at $29,000/yr 58,000
- Analytical chemist, 2 at $60,QQ0/yr 120,000
- Laboratory Technician, 6 at $29,000/yr 174,000
- Secretary, 2 at $24,000/yr 48,000
- Security guard, 2 at $36,000/yr 72,000
- Janitor, 2 at $20,000/yr 40,000
Maintenance (8% of installed equipment costs)
1,520,000
Depreciation (based on 15 year economic life)
1,270,000
Electrical power (based on 400 kw during working hrs)
57,000
Disposal of 1900 metric tons of incinerator ash
residue (haul distance 80 km)
26,000
Total annual operating cost j
$4,000,000
Note: Insurance and lease costs for land and dock (if necessary) have
been omitted from this table. (See text.)
Maintenance of equipment is expected to be the principal operations
expense, but the cost of labor and depreciation of the facilities are com-
parable. The total annual operating cost for the facility is estimated
to be $4 million. The total annualized cost of the hazardous waste ter-
minal facility, including the annualized capital cost, is $6.5 million.
Based on the expected annual throughput of 400,000 metric tons of
hazardous waste, the cost of receiving, processing, and dispensing
hazardous waste at the terminal facility will be approximately $16 per
metric ton of hazardous waste.
D.5. EXISTING TERMINAL FACILITIES IN THE UNITED STATES
Since there are no single existing marine terminal facilities in
the United States which have the capability of providing terminal ser-
vices for large volumes of both dry solid hazardous waste and liquid
hazardous waste, the approach used for this survey consisted of four
steps. Existing facilities that regularly accommodate vessels similar
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in length and draft to the vessel described in Appendix C were identified,
without regard to the type of commodity or material being handled. Only
those terminals having a minimum water depth at loading berths of
7.6 meters (25 feet) were included. This list of terminals was then
reduced to those that are handling either liquid and/or dry cargoes that
are hazardous or commodities that possess physical and chemical character-
istics that are similar to those anticipated for hazardous wastes (igni-
tability, corrosivity, reactivity, toxicity). The latter group of
terminals was evaluated from the standpoint of their potential for con-
version or development into a liquid and/or hazardous waste marine ter-
minal. Marine terminal and materials handling experts were consulted
regarding reasonable and practical alternatives in the development of a
hazardous waste marine terminal. Finally, on the basis of information
developed, preliminary findings, conclusions, and recommendations were
documented.
The sources of information used for this survey are references
numbered 13 through 16 in the reference list for this appendix, current
U.S. military publications (unclassified) covering military installations
that provide terminal services for fuel and for ammunition and explosives,
and personal and telephone interviews with officials in the following
U.S. Government agencies and companies:
Maritime Administration
Environmental Protection Agency
U.S. Coast Guard
General Services Administration
Navy Supply Systems Command, Field Operations Division
Military Traffic Management and Terminal Command
Selected hazardous waste management companies
Dow Chemical Company
American Association of Port Authorities
Selected port authorities
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Selected port officials
Selected commercial bulk liquid terminal operators
This survey found that 139 ports and 1,221 terminal docks, piers
or wharves on the East, Gulf, and West coasts of the continental U.S.
have sufficient water depth and space to receive the conceptually designed
chemical waste at-sea incineration vessel. Of the 1,221 terminal docks,
piers and wharves, 381 handle refined petroleum products or liquefied
chemicals (and allied products). These terminals are concentrated pri-
marily in the states of Texas, New Jersey, Louisiana, California and
New York. Ownership of terminals other than military terminals is pre-
dominantly private as opposed to governmental.
Of those terminal companies having membership in the Independent
Liquid Terminals Association, several specifically offer terminal ser-
vices for liquid chlorinated hydrocarbons as well as other commodities
and solvents having compatible handling characteristics. Almost all
major terminals handling cargo in containers (of various sizes and
descriptions, both standard/intermodal shipping containers and specialized
commodity containers) handle some hazardous cargo. The volume, however,
is relatively low, thus minimizing the need for special storage and handl-
ing equipment. A number of the major oil and chemical companies can pro-
vide terminal facilities that are capable of handling liquid bulk waste.
It was from such a facility that waste was loaded for initial at-sea
incineration of U.S. wastes. The availability of these facilities for
waste generated from non-company sources would, however, not seem
likely.
At U.S. military terminals, liquid hazardous commodities such as
fuel and dry hazardous commodities such as ammunition and explosives are
generally handled in separate facilities. Furthermore, none of the bulk
liquid terminal operators contacted thought it advisable to provide solid
waste terminal service at a bulk liquid terminal. The extreme differences
in the handling characteristics for the two types of commodities seemed
to be a major factor. Personnel handling bulk liquids did not usually
have what was considered to be the expertise that would be needed to
handle solid hazardous waste. Military bulk fuel depots and terminals
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do not handle large volumes of ammunition and explosives at the same
terminal, nor do the ammunition and explosive depots handle large volumes
of fuel. For the handling of large volumes of dry bulk commodities
(usually free flowing solids), specialized terminals are used. Smaller
shipments of such commodities may be handled in standard bulk commodity
intermodal containers, in packages or bags in intermodal containers, or
on pallets.
The larger the volume of the commodity handled, the greater are
the chances for finding development of a specialized handling system
developed for that particular commodity from point of commodity origin
to point of final destination.
Most of the major and many of the smaller bulk liquid terminal
companies that offer terminal services to the public are members of the
Independent Liquid Terminal Association (established in 1974). Through
that association they are relatively well informed of environmental
rules and regulations that are being developed in compliance with con-
gressional legislation. Accordingly, they are not only familiar with
long existing local, state, and federal regulations for handling liquid
waste (which are more concerned with fire, explosion and safety matters),
but are also familiar with recent Environmental Protection Agency regu-
lations for implementing the Resource Conservation and Recovery Act.
Several of these companies plan to file "Notification of Hazardous Waste
Activity," EPA form 8700-12, with EPA regions in order to qualify ter-
minals for "interim" status. Their knowledge and expertise could contri-
bute to development of a waterfront facility.
Terminal services to incinerator ships for wastes of European origin
have developed within existing bulk liquid terminals handling commodities
with similar physical and chemical characteristics. A major European
terminal handling liquid waste for loading on incinerator ships is at a
port 67 kilometers (36 nautical miles) from the North Sea,
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Discussions with bulk liquid terminal operators as to their offering
hazardous waste bulk liquid terminal services indicate it is not so much
a question of their availability and ability to handle such wastes as it
is of the additional costs that may be incurred in order to comply with
regulations yet to be finalized. Investment capital, although available,
still seeks investments where the risk factor is less in doubt-
Several of the U.S. military ammunition and explosive stations
and/or depots appear to have potential for handling dry hazardous waste.
Also, the Naval Construction Battalion Centers at Port Hueneme, California,
Gulfport, Mississippi, and Davisville, Rhode Island, should be explored for
handling of such waste. The availability of these activities would
probably depend on the effect of such work on their primary mission.
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REFERENCES
1. Ackerman, D.G., R.J. Johnson, T.L. Sarro, L.L. Scinto, R. Scofield
Draft Environmental Impact Statement for the At-Sea Incineration
of Liquid Si 1 vex, February 1 980.
2. Corey, R.J., G.G. Engelman, F.E. Flynn, R.J. Johnson, E.L. Moon,
T.L. Sarro, R.L. Tan, S.L. Unger, P.J. Weller, C.A. Zee. Offshore
Platform Hazardous Waste Incineration Feasibility Study. Phase I:
Conceptual Design, March 1980.
3. Ackerman, D.G., R.J. Johnson, R.A. Orsini, B.L, Riley, L.L. Scinto.
Operations Plan and Guidelines for the At-Sea Incineration of Liquid
Silvex. TRW for EPA under contract 68-02-3174, March, 1980.
4. Johnson, R.J., C.Z. McKean, M.K. O'Rell, C.A. Zee. Silvex Disposal:
EIS Information Development. TRW for EPA under contract 68-02-2613,
February, 1980.
5. U.S. Environmental Protection Agency. Final Environmental Impact
Statement, Designation of a Site in the Gulf of Mexico for Incinera-
tion of Chemical Wastes, July, 1976.
6. Battelle Memorial Institute for the Federal Water Quality Admini-
stration Department of Interior. Control of Spillage of Hazardous
Polluting Substances, November 1, 1970.
7. Booz-Allen & Hamilton, Incorporated. An Appraisal of the Problem
of the Handling, Transportation, and Disposal of Toxic and Other
Hazardous Materials. Prepared for the Department of Transportation,
Council on Environmental Quality, January 30, 1970.
8. Johnson, P..J., D.A. Ackerman, J.L. Anastasi, C.L. Crawford, B. Jackson,
ana C.A. Zee, Design Recommendations for a Shipboard At-Sea Hazardous
Waste Incineration System. Prepared by TRW Environmental Engineering
Division for Environmental Protection Agency, June, 1980.
9. Henry, D.L. and Cos Cob, Incineration at Sea. Presented at CMA
Seminar on Hazardous Waste Management, 1980.
10. Means Company, Inc., Building Construction Cost Data, 1979.
11. Johnson, R.J., F.E. Flynn, and P.J. Weller. A Preliminary Feasibility
Study for an Offshore Hazardous Waste Incineration Facility: Summary
Report. Prepared by TRW for the Environmental Protection Agency, June, 1980.
12. Neighbors, M.L. Preliminary Survey of Existing Maritime Terminal
Facilities on Continental United States Atlantic, Gulf and West Costs
Which Have*Capabilities of Serving an At-Sea Incineration Ship.
Diversified Maritime Services, Inc. Washington, D.C. 20005, August, 1980.
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13. U.S. Department of Commerce, Maritime Administration, Office of Ports
and Intermodal Development. National Port Assessment No. 1. (July
1980 status).
14. U.S. Coast Guard Draft Environmental Impact Statement. Waterfront
Facilities Regulations - Dated 19 December, 1979, and same as first
task.
15. Independent Liquid Terminals Association. 1980 Directory - Bulk
Terminals and Storage Facilities.
16. U.S. Department of Commerce, Maritime Administration, Office of Port
and Intermodal Development. National Port Assessment 1980/1990, (An
Analysis of Future U.S. Port Requirements).
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