Public Hearing, Held Pursuant To Notice, Upon Application Of The United States Air Force For A Permit Under The Marine Protection Research And Sanctuaries Act Of 1972, For The Ocean Incineration Of Herbicide Orange, Held In The Legislative Auditorium, Hawaii State Capitol, Honolulu, Hawaii, On Friday, April 25, 1975, Beginning At 9:30 A.M


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OfSO
ENVIRONMENTAL PROTECTION AGENCY
Public Hearing, held pursuant to notice, upon
application of the United States Air Force for a permit under
the Marine Protection Research and Sanctuaries Act of 1972
for the ocean incineration of Herbicide Orange, held in the
Legislative Auditorium, Hawaii State Capitol, Honolulu, Hawaii
on Friday, April 25, 1975, beginning at 9s30 A.M.
BEFORE: MR. J. BRIAN MOLLOY HEARING OFFICER
Acting Deputy Assistant Administrator for
Water Enforcement, EPA
MR. KENNETH BIGLANE
Director, Division of Oil and Special Materials
Control, EPA
DR. JAMES MAC KENZIE
Chief Pesticides Program Branch, EPA Region 9
DR. HENRY ENOS
Director, Equipment & Techniques Division
Office of Monitoring Systems, Research & Development
EPA Headquarters -
1'
,	EPA HEARING PANEL
ALSO PRESENT: . JAMES A. 'ROGERS, ESQ.
Office of the General Counsel, EPA
T. A. WASTLER "•
Chief, Marine Protection Branch
Ho TSASK
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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INDEX
PAGE
Opening Remarks	4
DR. BILLY F. WELCH, USAP	14-126
LT. COI» CARLTON R. WILLIAMS, USAF	37-66
MR. RICHARD MARLAND, Director,	55
Office of Environmental Quality Control,
State of Hawaii
MR. TONY HODGES, Representative,	58
Life of the Land
DEMEI OTOBED, Trust Territory Environmental	69
Protection Board
DR. KARL BASTRESS, ARTHUR D. LITTLE CORP.	73
LT. COL. GALE TAYLOR, USAP	80
DR. RICHARD BARKLEY	96
MAJ. JOHN J. GOKELMAN, USAF	102
CAPT*. STEPHEN G. TERMAATH, USAP	107
DR. J. MAC KENZIE	134
MR. MANFRED BRAUN, D.D.G. HANSA	147
JAMES L. BOYLAND, MARQUARDT CORP.	168
ELAINE W. SCHARTZ	190
MARGARET SCHMITT-HABEIN	191
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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MR. MOLLOYs Good morning.
My name is Brian Molloy. I am the Acting Deputy
Assistant Administrator for Water Enforcement for the
Environmental Protection Agency, Washington, D.C.
The hearing today is convened to receive
information and consider the application of the Air Force
for a permit under the Marine Protection, Research and
Sanctuaries Act of 1972 for the ocean incineration of
Herbicide Orange.
On my right, Mr. Kenneth Biglane, Director of
the Division of Oil and Special Materials Control, EPA,
Washington, D.C.
On my inroediate left is Dr. James MacKenzie,
Chief of the Pesticides Program Branch of EPA, Region 9
Office, San Francisco, California.
And on the far left, Dr. Henry Enos, Director
of the Equipment Techniques Division, Office of Monitoring
Systems of the Office of Research and Development, EPA
Headquarters in Washington, D.C.
Before I go on, I would like to ask Mr. Biglane
to make a few opening remarks.
Mr. Biglane.
MR. BXGliANE: Thank you, Mr. Chairman.
As the Chairman identified, my division is the
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Division of oil and Special Materials Control, and I would
like to relate to you just a few of the activities that we
do. It is within this division that the oil spill response
program for EPA is housed, also in charge of the Environmental
Impact Statement for Water Programs, and then we have the
ocean dumping program.
With us today is Mr. T. A. Wastler, taking to
our left, who is Chief of the Marine Protection Branch of
that program.
The reason I asked the Chairman to let me have
a few minutes is, I want to report to you that the Congress
J
is quite interested, as you know, in this program. Mr.
Wastler and I spent about an hour and a half, over one hour
and a half yesterday, and before two subcommittees of the
House of Merchant Marine and Fisheries Commission responding
to questions from this group about the ocean dumping program
of the United States.
Their questions ranged, of course, from concern
over resources available to the Environmental Protection
Agency and other federal agencies involved with conducting
this program. They were also quite interested in the new
technologies that are coming before us now, and ocean
incineration certainly is one of the newer technologies.
This is the second public display in which
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ocean incineration will be discussed, and the third one, as
you know, is scheduled for San Francisco on Monday. And I
can accurately report that the Congress is concerned that
alternatives be found to the disposal of wastes in the
oceans, and have penetrating questions on what is this
country doing to look for alternatives, as opposed to dis-
posing of these wastes in our marine waters.
I think today you are going to hear some of
these alternatives.
As we know in our ocean dumping program, if
there are viable alternatives, feasible alternatives to the
disposal of this material, either by incineration or any
other way into the marine environment, then those procedures
should prevail.
And again, I think as the testimony unfolds,
we have tried to show you, we have tried to bring the
problems associated with these kinds of materials directly
to the public.
This country manufactures more and more
chemicals each year. We are ending up with very highly
toxic substances. We found long ago that just merely
leaving the disposal of these materials to the land environ-
ments or to the air environments or to the marine environ-
ments, damages will occur. We must be very careful in the
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controlled release or depositing of any of these materials
into any of the environments.
Mr. Chairman, now with this concern statement
behind me, I recommend that we proceed forward.
MR. MOLLOY: Thank you, Mr. Biglane.
I have just a few introductory remarks, and I
will leave most of the technical information to be discussed
by other people later on.
As I said before, we are here today to receive
information on the application of the Air Force to dispose
of approximately million gallons of a chemical known as
Herbicide Orange by incineration at sea.
The Air Force has applied to the Environmental
Protection Agency for a permit pursuant to the Marine
Protection, Research and Sanctuaries Act of 1972 to burn
this material about 120 miles to the west of Johnston Island.
EPA has reviewed the information that has been
made available by the Air Force and other interested parties,
and it has made a tentative determination to issue a research
permit to the Air Force that would allow approximately 4200
metric tons of this material to be incinerated in the ocean
under certain controlled conditions. They are not too long.
I will read those conditions that we would impose, or we
have tentatively agreed to impose on any permit issued to
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the Air Force.
"1. The incineration will take place within
the disposal site.
"2. The emission rates after the burn will not
be in excess of one-tenth of one percent.
"3. The Herbicide Orange will be removed from
the storage drums and loaded on the incineration vessel in
such a manner that no TCDD escapes to the environment in
measurable quantities. In the process of removal of
Herbicide Orange it shall employ the best available technology
"4. The drums from which the Herbicide Orange
is taken will be triple rinsed with solvent prior to disposal
or otherwise cleaned with equal degree by jet rinsing, and
the rinses will be added to the waste to be incinerated.
"5. The carrier will maintain a combustion
temperature in each incinerator of at least 1400 degrees
centigrade.
"6. Feed rate of the Herbicide Orange into the
combustion chambers will be as low as possible and not in
excess of 12 metric tons per hour for each incinerator.
"7. The applicant and the carrier shall
maintain a sealed automatic monitoring device for constant
review of the operating temperatures of the incinerators.
"8. The applicant will employ such other
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monitoring procedures as are requested by the Environmental
Protection Agency.n
That is a tentative determination. A final
determination will be made by the Environmental Protection
Agency following this hearing and any subsequent sessions
of this hearing, and the receipt of any public comments
concerning this proposal.
As Mr. Biglane mentioned before, a major con-
sideration that EPA muBt take into account before a permit is
issued is the question of whether there are any feasible
alternatives to the incineration. We expect several state-
ments to be made today on these alternatives.
The rules for today's hearing are as follows:
First of all, this is an informal hearing and
there will be no cross-examination of witnesses. Written
questions, though, may be presented from the floor. If you
will write out any questions you have and hand them to one
of the ladies in the back of the room, we will try to have
all germane questions answered, given the problems of time
if we run into those problems.
Everyone speaking should use the lectern to
my left, and should identify themselves by name, and
affiliation if that's appropriate.
The order of speakers, as far as practicable,
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will be, (1) any Introductory remarks by the Environmental
Protection Agency; (2) the Air Force presentation as they
see the problems; (3) we have a statement on EPA policy on
pesticide herbicide disposal. Then (4), we would like to
have any elected representatives of federal, state or local
governments to speak, followed then by any federal, state
or local governmental agencies. After the governmental
agencies are through, we would like any representatives of
groups, and then following that any specific individuals.
Now, there may be a problem with time, and so
if anyone has a time problem, if they would make that
problem known to one of the ladies in the back of the room
we can probably try to juggle that as best we can.
We would appreciate it if any statements you
made were in writing, and then you can just summarize these
statements when speaking.
We will have a fifteen-minute break at about
eleven o'clock.
Finally, we are making a transcript of today's
proceedings, so that if you have a written statement and you
have it available, please give a copy of the statement to
the Reporter who is sitting next to the lectern to make it
a little easier for him.
So with that, I think we will now begin formal
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statements.
I would now like to call on Mr. James Rogers,
an attorney, Office of General Counsel of SPA Headquarters,
Who will discuss the law under which we are operating here.
MR. ROGERS: Thank you, Mr. Chairman.
My name is Jim Rogers. I am a lawyer with EPA,
and I would like to take a few moments to help provide some
more background for this hearing, and to give a brief outline
of the iaw as viewed by the Staff under which EPA operates.
As the Chairman indicated, the statute which
governs the proceedings is the Marine Protection, Research
and Sanctuaries Act of 1972. This Act was passed in October
of 1972, and was amended in March of 1974 to make it con-
sistent with the convention on the prevention of marine
pollution by dumping of wastes and other matter.
This is the second application for use of an
incinerator ship that has been processed by EPA. The first
was the application of the Shell Chemical Company to
incinerate in the Gulf of Mexico troublesome organic chloride
wastes generated by its Deer Park, Texas facility.
EPA held three separate hearings on that
application, and the hearings resulted in the granting of
two research permits and one interim permit to incinerate
those wastes. The same ship that conducted those incinera-
tions will be used by the Air Force if the permit is granted
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under this proceeding.
There are two reports that have been produced
as a result of the Shell experience. One Is by the Shell
Chemical Company. The other is by EPA, and I would suggest
and offer at some point in this hearing that we include
these in the record.
It may be useful to quickly mention the nine
statutory criteria that must be considered before an ocean
dumping permit can be granted. These are in Section 102-A
of the Act, and I am going to paraphrase them.
The first criterion is the need for the proposed
dumping.
Second is the effect of such dumping oh human
health and welfare.
Third is the effect of such dumping on fisheries
resources, shellfish, wildlife, shorelines, et cetera.
The fourth is the effect of such dumping on
marine ecosystems.
The next is the persistence and permanence of
the effects of dumping.
The sixth is the effect of dumping particular
volumes of concentrations of materials.
And they go on.
It should be noted that When the Act refers to
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dumping, this has been construed by EPA as meaning disposal
by whatever form in the ocean, purposeful disposal.
The first statutory criterion, the need for the
proposed dumping, leads to a major consideration that would
be discussed today, and that is whether there are possible
alternatives to the ocean incineration of these wastes.
As Dr. Welch and other witnesses will testify
to today, there has been under intensive consideration by
several agencies, agencies of the government, possible
reprocessing of Herbicide Orange into useful pesticides
which are currently registered by EPA's Office of Pesticide
Programs and are in quite some demand.
Later on there will also be mention made of
the EPA pesticide regulations, which encourage the reuse of
material so as to avoid destroying of valuable resources.
And finally, there is one potential issue in
this case that has not been finally resolved, and that is
whether or not the combustion products that may result from
the incineration of Herbicide Orange would result in the
disposal of a chemical or biological warfare agent, as that
term is used in Section 102-A of the Act. The tentative
determination of the EPA Staff is that at the present time,
and considering the minute quantities, if any, of unburned
material that may be discharged into the environment, it is
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unlikely that there would be a violation of the Act) although
as the Chairman said, this is strictly a tentative determin-
ation and is subject to evidence that is put forth at this
hearing.
Thank you, Mr. Chairman.
MR. MOLLOYt Thank you, Mr. Rogers.
Before we go on, I have two documents that I
would like to enter into the record.
The first is the Environmental Protection Agency
Notice of Receipt of Application and Tentative Determination*
This is the full text of the tentative determination that I
read from before.
Secondly is a draft for the report entitled,
Disposal of Shell Chemical Company Organic Chlorine Waste
By Incineration at Sea, prepared by the Environmental
Protection Agency Office of Water Program Operations, Divi-
sion of Oil and Special Materials Control, April, 1975.
I would like to emphasize that this is a first
draft of a report, and we anticipate that there will be at
least some modifications to that report as it gets further
finalized. When those changes are made, and if a more
complete draft is prepared along with the final draft, that
will also be entered into the record of this hearing.
With that out of the way, I would like to call
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on the Air Force representatives. The first speaker today
will be Dr. Billy E. Welch, who is the Special Assistant
for Environmental Quality, Office of the Secretary of the
Air Force in Washington, D.C.
Dr. Welch.
MR. GRANT REYNOLDS (Assistant General Counsel,
USAF): Mr. Molloy, while Dr. Welch is talcing the lectern,
may I make a couple of remarks?
MR. MOLLOY: Yes, sir.
MR. REYNOLDS: I am Grant Reynolds, Assistant
General Counsel of the United States Air Force.
We would also like to note that the record
consists of the permit application by the Air Force with a
500-page Environmental Impact Statement attached thereto.
MR. MOLLOY: That is fine with me. That is
the document in front of me here, and it is so noted and it
is entered into the record.
MR. REYNOLDS: Thank you.
As you know, we have in addition to the permit
application, eight witnesses with which we propose to cover
each of the points discussed by Mr. Rogers, plus those in
the tentative permit application.
The first witness is Dr. Welch, who is a
Special Assistant for Environmental Quality, Department of
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the Air Force.
MR. MOLLOY: Thank you.
Dr. Welch.
DR. WELCH: Mr. Chairman, thank you very much.
Good morning, ladies and gentlemen.
I would like to briefly recount some of the
history regarding Orange Herbicide and summarize Air Force
actions relating to disposal of this material in order to
put this problem into the proper perspective.
First, we should recognize that Herbicide
Orange is an equal mixture (50:50 by volume) of two com-
mercially available agricultural products - namely
2,4,Dichlorophenoxyacetic acid and 2,4,5-Trichlorophenoxy-
acetic acid - or as we commonly refer to them - 2,4-D and
2,4,5-T. Herbicide Orange consists of what iB chemically
called the normal butyl esters of those two compounds.
There are products registered by the EPA for use in this
country, which contain mixtures of the butyl esters of
2,4-D and 2,4,5-T. In general, these products are not as
concentrated as Herbicide Orange, but one is nearly identical,
In April 1970, the U.S. Department of Agricul-
ture, Health, Education and Welfare and the Department of
the Interior suspended certain uses of 2,4,5-T. Concurrently,
the Department of Defense suspended the use of Orange
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Herbicide. As a consequence of the suspension of some uses
of 2,4,5-T, the U.S. Air Force, acting as the executive
agent for the Department of Defense, was left with 1.5
million gallons of Herbicide Orange in Vietnam and approx-
imately 0.8 million gallons of Herbicide Orange at Gulfport,
Mississippi.
Following that suspension in April 1970, in
September 1971, the Department of Defense directed the Air
Force to return this material from Vietnam and to dispose
of it in a safe, efficient manner. Following that particu-
lar direction, the Air Force published a draft environmental
statement in January 1972, stating that incineration
appeared to be the best way of resolving the problem, and
that we had numerous studies under way. Due to the fact
that these studies were under way and had not yet been
completed, it was felt that the impact statement should be
held in abeyance until the studies were completed.
As a result of that, the material that was
stored in Vietnam was moved in April 1972 to Johnston Island
for storage, pending a final disposal decision.
Since that time, the Air Force has conducted
or caused to have conducted or assisted in conducting many
studies to look at the various means for disposing of this
particular material. The results of these efforts have
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been documented In the environmental Impact statement which
is a part of our permit application. I will quickly outline
these studies for the benefit of those who have not reviewed
the statement. We conducted incineration tests ranging
from static tests in the laboratory, to small scale labora-
tory tests, to drum size tests conducted for the Air Force
at a commercial facility on the West Coast.
The results of these studies indicated that
the butyl esters of 2,4-0 and 2,4#5-T acids are destroyed
between 550-700 degrees Centigrade, and the tetrachlorodi-
benzo-para-dioxin or the TCDD is destroyed between 980 and
1000 degrees Centigrade.
In addition to the incineration studies, we
looked at the potential for use. This particular material
is not a registered herbicide; and, for it to be utilized,
it would have to be registered or reprocessed into some
other material that would be useful.
At this point, somewhere in mid-1973 to early
1974, when we were looking at this particular problem,
2,4,5-T was considered to be a material that had perhaps a
limited lifetime in.terms of acceptability for use, and
indeed the EPA had planned to hold public hearings in June
1974 to evaluate the overall use of 2,4,5-T in this country.
These public hearings were subsequently cancelled with no
o
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decision being reached due to the lack of sufficient
information on Which to base decisions.
We looked at deep-well disposal. We looked
at the prospect of putting the material in nuclear test
cavities, at the prospect of burying it, and at microbial
reduction with subsequent destruction of the dioxin. We
also looked at the concept of chlorinolysis, which is com-
plete chlorinization of the molecule producing phosgene,
carbon tetrachloride and hydrochloric acid.
We examined rather extensively the concept
of soil biodegradation. This particular concept relates to
putting the material into the soil and allowing the soil
micro-organisms to handle the biodegradation of the material,
thus breaking it down.
We also looked at the question of returning
the herbicide to the manufacturers. In March 1972, we
contacted the original manufacturers of the herbicide and
inquired if they had any interest in the material. We
inquired whether they could reprocess it to remove the TCDD
and subsequently reuse the herbicide. This created what
might be known as a wide wave of disinterest at that
particular point in time. Subsequently, in August 1974,
following EPA's decision in June 1974, we contacted the
manufacturers again with the same type of results. They
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reported they did not have the capability nor the interest
to reprocess this material.
In Hay of 1974, we published a draft
environmental impact statement in which we stated that
incineration appeared to be the best way of destroying the
material. Further, it was stated that incineration.) at a
remote site was preferable to incineration in the Continental
United States.
Accordingly, we said that incineration on or
west of Johnston Island would be preferable. We looked at
incineration at sea west of Johnston Island as having the
least prospect of causing environmental damage. Incineration
on Johnston Island is feasible and could be handled by
building a facility that would be environmentally acceptable;
but this option has the opportunity for potentially greater
impact than incineration on the high seas.
When we filed the draft environmental Jumpact
statement, the EPA position was that incineration on the
high seas was not covered by the Ocean Dumping Act, or the
Marine Protection, Research and Sanctuaries Act referred to
earlier. Over 400 copies of the draft environmental impact
Statement were distributed. An LO-2 rating was given by
the EPA. The LO indicates they lacked objection to the
proposal. We did receive comments from others, and I will
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apeak of those after finishing the chronology.
Subsequently, in December 1974, we published
the final environmental impact statement. Again, we said
that our primary option was incineration on the high seas
west of Johnston Island or approximately 970 statute miles
west of Hawaii. From the proposed site of incineration
downwind, it is approximately 1200 statute miles to the
next land mass, which is the Marshall Island Group. The
UBual ocean currents and the wind move from Hawaii to
Johnston Island and, thence, away from Johnston Island and
from Hawaii.
In the interim, between the filing of the
draft and final statements, the EPA reversed their prior
position and ruled that incineration on the high seas was
within the purview of the Marine Protection, Research and
Sanctuaries Act. On January 9, 1975, the Air Force requested
that the EPA issue a special permit for the incineration of
three loads of Herbicide Orange west of Johnston Island.
The EPA on February 19, 1975, conducted a
public meeting in Washington, D.C. to consider several legal
and factual issues that the EPA felt might arise in connec-
tion with processing the Air Force application. The issues,
which the public was asked to comment upon, were:
1. Whether feasible alternative methods of
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, disposal exist.
2. Whether Herbicide Orange is a "chemical"
or "biological warfare agent" within the meaning of
the Act, and Whether it retains this character follow-
ing incineration.
3* Whether incineration of Herbicide Orange
at high combustion efficiency is compatible with the
Act, assuming the compound is a warfare agent.
4.	Whether adequate techniques exist with
which to monitor the incineration of Herbicide Orange.
5.	Whether incineration is a feasible and
environmentally safe means of disposal of Herbicide
Orange, and
6.	Whether the disposal site requested by
the Air Force is an appropriate location for incinera-
tion of this waste.
Approximately 60 persons were present at the
public meeting, including representatives of the National
Wildlife Federation, the Environmental Defense Fund, and
the Center for Law and Social Policy, which represents the
Friends of the Earth and the National Audubon Society.
In regard to the first point concerning
feasible alternatives, I have previously enumerated a list
of alternatives which we have already studied. A
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modification of our direct use alternative is presently
being evaluated. In November 1974, even before we filed
the final environmental impact statement for incineration,
we proposed to the EPA a concept of disposal that involves
destruction only of the contaminant, dioxin or TCDD as we
referred to it earlier. It was proposed that qualified
chemical companies would be requested to submit information
outlining how they would chemically modify the Herbicide
Orange to produce another form of 2,4-D and 2,4,5-T. In
the process of modification, the dioxin would be destroyed
or removed. The EPA responded affirmatively in January 1975
and provided a list of companies they felt would be capable
of modifying the herbicide and removing the dioxin. The
Air Force supplemented the list by once again requesting
the original manufacturers to express their interest. A
total of 24 solicitations were mailed. Indications of
interest have been expressed by some chemical companies.
Those that appear to have proposed feasible reprocessing
techniques have been requested to demonstrate their techniques
on a pilot plant scale. We are actively pursuing this
potential disposal option.
The second point concerns whether Herbicide
Orange is a "chemical" or "biological warfare agent" within
the meaning of the Act and whether it retains this character
C. RAY BEEBE fie ASSOCIATES
HONOLULU, HAWAII

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following incineration. Within the meaning of the Marine
Protection, Research and Sanctuaries Act, Herbicide Orange
is a chemical warfare agent. I emphasize within the meaning
of that Act. There is specific legislative history
indicating that herbicide compounds intended for use in
warfare activities are regarded as chemical warfare materials,
dumping of which is prohibited.
This leads to the third pointi Given that
Herbicide Orange cannot be "dumped," is ocean incineration
compatible with the Act? We do not consider that the
Administrator is barred from issuing a permit for the
-V
incineration of Herbicide Orange upon the ocean. Based on
our analysis presented in the Final Environmental Impact
Statement and upon the success of the VULCANUS when it
incinerated chlorinated hydrocarbons in the Gulf of Mexico
and upon independent analysis of our conclusions, it cannot
be reasonably anticipated that any constituent of Herbicide
Orange will be detected in the mixing zone of the ocean
environment. In testimony of the public meeting in February
1975, a representative of the Center for Law & Social
Policy stated that the combustion products do not retain
chemical or biological warfare characteristics. At the same
meeting, the National Wildlife Federation indicated the
conditions they considered necessary to insure a safe burn
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and then stated that incineration, under the indicated
circumstances, would be consistent with the law. The point
is - they were aware of the legislative history, as well as
the Air Force proposal, and concluded the Air Force proposal
was consistent with the law.
Monitoring of the incineration of Herbicide
Orange was raised at the public meeting. Monitoring was
again raised in the announcement of this public hearing.
Our environmental impact statement explained the details of
our sampling train and presented data to demonstrate a high
recovery efficiency for 2,4-D and 2,4,5-T. We felt confi-
dent that dioxin would be trapped in our benzene impingers
if it was present, but we did not present quantitative data
to support our contention. We have recently completed
experiments to verify the efficiency of recovering dioxin.
The sampling train consists of a quartz probe which will be
placed through the sampling port on the stacks of the
VULCANUS and into the stack exhaust. A 50-foot heated
teflon line will carry the sample to our impingers. Based
on our experiments, we can say that our train is capable
of detecting the presence of 2,4-D, 2,4,5-T and dioxin in
the stack exhaust; that the teflon line, when properly
heated, will transport the constituents from the stack to
the benzene impingers; and that the train will essentially
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pick up 100% of the constituents entering the probe.
The second point on monitoring regards the
marine environment. The notice of the public hearing stated:
"The applicant shall also present evidence at the public
hearing as to its capability to monitor for TCDD, 2,4,5-T
and 2,4-D in the immediate marine environment during
incineration.M I emphasize "during incineration." There
are no instruments that we know of Which will allow monitor-
ing the ocean water for these constituents in real time
.during the incineration. We do have the capability to
analytically determine the presence of 2,4-0, 2,4,5-T and
TCDD in a properly collected sample of sea water. We would
use a technique comparable to that of the DOW Chemical
Company during our analysis. This type of monitoring should
not be necessary, as we have demonstrated the efficiency of
stack monitoring and will be able to detect these consti-
tuents and determine that the permit conditions are being
complied with.
The fifth point as to whether incineration
is a feasible and environmentally safe means of disposal
has been answered by the studies conducted and reported on
in the environmental impact statement process, by the
tentative determination of BPA to issue a permit for
incineration of a shipload of Herbicide Orange, and by the
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support of the environmental groups at the February public
meeting. However, the point of this hearing is to insure
that undisclosed facts do not exist. The Air Force has,
of course, already concluded that incineration on board the
VULCANUS is an environmentally acceptable means of disposal.
Based on the comments received on our draft environmental
impact statement, most reviewers have come to the same
conclusion.
The final point raised for discussion at the
public meeting concerned the appropriateness of the selected
disposal site. The EPA, in their discussion of the pro-
posed designation of the site, stated that the proposed
site is typical of tropical open ocean areas which are un-
productive parts of the oceans. They also drew a comparison
with the Gulf of Mexico site previously used by the VULCANUS,
for which it was concluded that incineration was found to
have no impact on the marine environment.
We have once again reviewed a number of
references, including information obtained from the National
Oceanic and Atmospheric Administration's Environmental Data
Service and from NOAA's National Marine Fisheries Service.
This review indicated that the information presented in the
environmental impact statement is correct and that the
productivity of the general area is low. We know of no
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reason why such an area would not be suitable for ocean
incineration.
It would seeiln appropriate at this time to
discuss>the comments provided to us by the State of Hawaii,
Office of Environmental Quality Control. The Environmental
Center of the University of Hawaii was primarily concerned
because the Environmental Statement did not contain all of
the biological background information we had accumulated
, for Johnston Island. It was unfortunate that the reviewer
felt we were not being responsive to the ecological aspects
of Johnston Island. We specifically commissioned the
Smithsonian Institution to study the Johnston Island ecology.
The complete report was and is available, but its volume
simply precluded its publication under the same cover. We
therefore published only the summary of the report — said
summary also being prepared by the Smithsonian Institution.
The Environmental Center also expressed doubt, which is
not necessarily shared by the Air Force, about incineration
on Johnston Island and favored use of the VULCANUS.
Our proposal is to incinerate the herbicide
using the vessel. Incineration on Johnston Island is
feasible, but we consider this option to be less environ-
mentally acceptable than ocean incineration. The commenter
concluded regarding ocean incineration, "I foresee the
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deleterious consequences of this alternative as being
minimal."
The Chemistry Department of the University
of Hawaii also provided comments. They felt the herbicide
,. t k
should be processed by the original manufacturers to obtain
useful chemicals. As I have previously pointed out, we
have tried at least three times to interest the manufac-
turers to no avail. We have, however, recently obtained
indications of interest from companies regarding our repro-
cessing proposal, which X have also discussed. If there
is a feasible, environmentally safe way to reprocess the
material, we will certainly pursue that aspect.
Concern for adequate monitoring of the
vessel was expressed. Here, too, I feel my previous com-
ments regarding the type and efficiency of monitoring
served adequately to indicate our concern that the vessel
be adequately monitored to demonstrate the efficiency of
incineration. The requirement for properly handling the
emptied drums was pointed out. We will spray wash all
the drums we empty in order to remove the remaining
herbicide. The dedrumming operation will be conducted in
a specially designed facility so that any spill will be
contained. We believe this operation can be conducted
without damage to the environment.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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The Hawaii Department of Agriculture
recommended that controlled incineration be used for dis-
posal. They preferred incineration at sea and said, "No
significant detrimental environmental effects can be
v
expected from this method of disposal." It was further
indicated, should incineration on Johnston Island be
selected, that a biological monitoring protocol should be
developed. It is certainly our intent to conduct detailed
monitoring before, during and after incineration should
Johnston Island be selected as the disposal site. We will
have a monitoring program under way during the dedrum
operation to document the environmental safety of this
operation.
These comments of the State of Hawaii, along
with others, were included and addressed in our final
environmental impact statement filed in December 1974.
We distributed over 200 copies of the final
environmental impact statement. We have had one set of
written comments from the Environmental Protection Agency.
We have had one verbal comment from the Center for Law and
Social Policy on the final environmental statement.
My point in mentioning this is to indicate
to you that this particular public hearing we are having
today is not to discuss a problem that just surfaced, not
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HONOLULU, HAWAII

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to discuss something that the public has not had an
opportunity to be interested in or had an opportunity to
comment on. It is our contention that we have documented
the environmental problems relating to this particular
situation and that these environmental problems are the
same whether a permit is required or whether one is not.
In the announcement of this public hearing.,
there were a number of points addressed which are expected
to be permit requirements. Each of these will be mentioned
and commented upon very briefly.
Incineration will take place in the
designated disposal area. When a permit to incinerate
Herbicide Orange at sea is issued, we will stipulate, in
any contract we negotiate for ocean incineration, that
incineration will occur within the designated boundaries.
The emission rates of TCDD. 2.4-D or 2.4.5-T
will not be in excess of 0.1% of the total amount of the
respective constituents in the Herbicide Orange waste.
This also is a situation which bears discus-
sion. While we are confident the research burn will
demonstrate that the above limits can be achieved - what
if it does not? Of what significance should it be? Let
me run through a few figures. Our herbicide has an average
concentration of 2 ppm of dioxin. For our some 24,000,000
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HONOLULU, HAWAII

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pounds of herbicide, we calculate that about 48 pounds of
dioxin is to be incinerated. In complying with the condi-
tions I mentioned previously, no more than 0.1% emission
is allowed. Thus, a total of 0.048 pounds of dioxin will
be emitted during our total time of burn over an area of
about 66 by 138 statute miles or 9117 square miles or
5,834,861 acres. If this dioxin were spread over the
entire burn area, an application rate of about 8.2 x 10
pounds of dioxin per acre would result, or expressed
another way, about four micrograms per acre. Now assume
in standard weed control work that about two pounds of
herbicide are applied per acre and that the dioxin con-
centration is 0.1 ppm, which is the current EPA criteria.
Calculation will result in a figure of about 90 micrograms
per acre. Our dioxin will be deposited in the middle of
the Pacific, in an area known to be unproductive. We can
place only four micrograms of dioxin per acre due to
incineration; but, in standard agricultural practice, an
amount more than 20 times as much (90 micrograms) would be
allowed on the land areas of the United States. The
Council for Agricultural Science and Technology, in a
report on phenoxy herbicides, said that - and I quote -
"The amount of TCDD distributed in the United States in
2,4,5-T is probably no more than eight ounces annually.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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This material is distributed over approximately five million
acres at a rate of about 50 micrograms per acre. • . .H
Again, we see that the permit restrictions will limit the
amount deposited on an unproductive area to only four
micrograms. Here again, my point is that while we will
still comply with the 0.1% requirement, we should be aware
that more dioxin is allowed to put on the ground in the
U. S. than we will be putting into the Pacific Ocean. And,
of course, if the burn area were larger, the amount per
acre would be even less.
I believe the next point that was raised
regarding removing the Orange from the drums and loading
of the vessel in a safe manner has been covered, as has
the requirement to rinse the drums. We will have spill
prevention control measures, absorbent material in the
event of a spill, curbs to prevent run-off and specially
designed facilities for dedrumming and rinsing. These
permit requirements will be no problem and have already
been incorporated into our planning documents.
'	The carrier will maintain a combustion
temperature in each incinerator of at least 1400 degrees
Centigrade. The controls available on the ship were listed
in the impact statement. We stated in our permit applica-
tion that electric waste pumps will not operate to feed
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HONOLULU, HAWAII

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herbicide to the incinerator burners of that combustion
chamber in which the temperature falls below 1400°
Centigrade. If such a condition or situation occurs, the
incinerator malfunction is corrected, and the combustion
chamber temperature is returned to above 1400° Centigrade
with conventional fuel before any herbicide is reintroduced.
Also the burners for a particular incinerator are auto-
matically shut down if any of the following conditions fall
below preset levelsi the air feed pressure to a burner,
the herbicide feed rate to a burner, and the3 flame intensity
of the burner. Also, operational controls and monitoring
panels are manned at all times by an engineer whose sole
ship responsibility is operating and maintaining the
incinerator system at the desired combustion parameters.
Thus, we do not foresee this as a problem, and we will
comply.
The feed rate will not exceed 12 metric tons
per hour for each incinerator. We will comply with this
requirement and do not anticipate any difficulty in so doing.
The feed rate can be set and monitored.
A sealed automatic monitoring device for
constant review of the operating temperatures of the
incinerator - this presents no problem. The VULCANUS has
this type of equipment installed, and its use will be
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HONOLULU, HAWAII

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required.
The applicant will employ such other
monitoring procedures as are requested by the Environmental
Protection Agency. While this is generally acceptable, the
words are far ranging. We assume the EPA does not intend
to require monitoring, which past experience or analysis
of available data would indicate is unnecessary. Likewise,
we do not believe EPA would intend to require types of
monitoring whose only purpose is cosmetic to make the
operation look good but in reality adds nothing.
A final point that I wish to address is the
loss of herbicide during transportation. The vessel is
designed so that liquid cargo wastes can only be on-loaded
via pumps on shore. Once loaded, shipboard pumps are only
capable of discharging the liquid wastes directly into the
combustion chambers. However, international regulations
require that in the event the safety of the vessel and
arew may be threatened, there must be some means of dis-
charging the cargo directly into the sea. This could be
effected through gravity release valves which remain
officially sealed in normal circumstances. It is our
understanding that release of the material has not been
necessary, even operating in the North Sea, which is renown
for its rough seas. Storms should not be a problem near
C. RAY BEEBE &
HONOLULU,
ASSOCIATES
HAWAII

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Johnston Island. Since 1955 there have been only two local
storms and one hurricane which affected Johnston Island.
Hurricane Celeste did cause in excess of three million
dollars in August 1972. However, there have been only two
hurricanes since 1955 which passed within 100 miles and
only eight which passed within 1000 miles. Contact with
the U.S. Coast Guard will be adequate to warn of any storms
in the area.
The ship has been constructed according to
Inter-Governmental Maritime Consultative Organization (IMCO)
regulations and meets current U.S. Coast Guard requirements
for carriage of cargo such as Herbicide Orange. Her double
hull and double bottom provide added containment protection
from collision or other marine hazard. The vessel is
divided into 15 cargo tanks - none of which is in contact
with the vessel's hull or bottom. Clearance between the
tanks and hull is about 3% feet - more than required by
regulations. The question of "what if" regarding sinking
due to a collision can logically be asked. It should be
remembered that this vessel is a chemical tanker which
happens, regarding this issue, to be carrying a waste. The
question of sinking can be asked regarding any chemical
o
tanker carrying a variety of cargoes, many of which are
extremely hazardous. The loading and conveyance via barge
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HONOLULU, HAWAII

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or ship of toxic or ecologically harmful cargo is a normal
occurrence. The regulatory agencies have recently required
vessels of this type to have double hulls for the very
purpose of minimizing release of cargo due to an accident.
In two years of operation, no problem has occurred with
the VULCANUS. Quantification of the impact of cargo
jettison or ship sinkage is not prudent because of the
many assumptions required. We can make, however, some
general statements. The acute toxicity of the normal
butyl esters of Orange Herbicide ranges from 1-10 ppm,
depending on the species of fish, pH and other factors.
Generally, the normal butyl ester of 2,4,5-T has been found
to be less toxic than the normal butyl ester of 2,4-D.
The acid and salt forms are roughly 100 times leBs toxic
than the normal butyl esters; thus, the rate of hydrolysis
of the esters in Orange Herbicide is important in reducing
the toxic effects* Toxicity also depends on how much
Orange Herbicide is available for aquatic organisms via
vigorous and continuous mixing. Laboratory studies
indicate that, if Orange Herbicide were spilled in a body
of water, it would sink to the bottom, depending on currents.
If not greatly agitated, it would produce local effects
in an area determined by the rate it would go into solution
versus the rate of hydrolysis. Hydrolysis is expected to
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HONOLULU, HAWAII

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be rapid in normally alkaline sea water.
Laboratory experiments with artificial sea
water and Herbicide Orange in solution indicate that 99
percent of the normal butyl esters are hydrolyzed in 14 to
21 days in the absence of marine organisms. Using 2,4-D
butyl esters in actual sea water with shrimp, plankton,
and other normally occurring organisms, 99.9 percent
hydrolysis will be complete in 50 hours. Data indicate
that aomparable results whould occur with Orange Herbicide.
Mr. Chairman, this concludes the opening
statement that I wish to make at this time. We would like
to present to you certain technical presentations dealing
with the overall issue, and following these technical
statements we will have a closing comment which will
conclude our presentation.
MR. MOLLOY: Thank you, Dr. Welch.
The next Air Force speaker is Lieutenant
Colonel Carlton R. Williams from the U.S.A.F. Environmental
Health Laboratory, Kelly Air Force Base in Texas.
Colonel Williams.
LIEUTENANT COLONEL WILLIAMS: Mr. Chairman,
ladies and gentlemen. My name is Lieutenant Colonel Carlton
R. Williams. I am with the Environmental Health Laboratory
at Kelly Air Force Base in San Antonio, Texas.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII
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CARLTON R. WILLIAMS	38
I have a Master of Science degree in
engineering, and I am a candidate for the degree of Doctor
of Philosophy at the University of Michigan.
My academic program includes mathematical
modeling of national ecosystems, and also a study of
incineration of solid wastes and of sewage sludges.
I have worked exclusively in the field of
sanitory or environmental engineering since 1955, and I
have been involved in the Orange disposal project for about
° two years.
I was the Air Force Team Chief on a test
burn conducted at The Marquardt Company of Orange Herbicide
the
in November of 1973. This is/largest, most extensive test
incineration of Orange Herbicide which has occurred as yet.
I am a member of the Texas and the National
Water Pollution Control Federation, the American Chemical
Society, American Conference of Governmental Industrial
Hygienists.
I am a registered professional engineer in
the State of Texas.
I have a paper entitled The Incinerator Ship
VULCANUS Incineration of Orange Herbicide. It includes an
introduction, statement of the incineration situation,
discussion of the information, and VULCANUS incineration of
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CARLTON R. WILLIAMS	39
Orange Herbicide, and other considerations.
You have the paper.
I. INTRODUCTION
The currently proposed action to incinerate
the Orange Herbicide was initially described in the Revised
Draft Environmental Statement (RDES) filed in May 1974.
This statement received widespread public circulation
which resulted in written comments directed to the Air Force
on various facets of the disposal project. The EPA and the
Marquardt Company were among the comroentors, and were
particularly concerned about the appropriateness of the
incineration aspect of the project. All comments received
on the RDES and the Air Force reply are contained in the
Final Environmental Statement (FES) which was filed in
December 1975. On 9 January 1975, the Air Force submitted
an application for a special ocean dumping permit to the
EPA, the FES was included as a part of the application.
The EPA, in the 4 February 1975 edition of the Federal
Register announced a "Notice of Receipt of Application and
Meeting" pertaining to the above mentioned ocean dumping
application and scheduled the meeting for 19 February in
Washington, D.C. In the 24 March 1975 edition of the
Federal Register the EPA announced a "Receipt of Application
and Tentative Determination" regarding the ocean dumping
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	40
application. This notice included a "Summary of Application"
and the "Tentative Determination" as regards the disposal
project. The Summary of Application included:
1)	a statement that written comments were
forwarded to the EPA by the Marquardt Company, the National
Wildlife Federation, and the United States Department of
the Interior, and
2)	a paragraph stating that the Marquardt
Company has requested a public hearing on the application.
The action by the Marquardt Company represents a total of
three letters, one to the Air Force on the RDES, one to the
EPA concerning the Final Environmental Statement and need
for a public hearing and one to the Council of Environ-
mental Quality requesting that a public hearing be held
concerning the application. The latter two letters also
requested that congnizant EPA engineers who monitored the
test burn on board the VULCANUS (Shell Chemical Company
project) present their findings. This action would also
be most welcome by the Air Force. The National Wildlife
Federation made a statement at the 19 February meeting and,
as mentioned above, submitted written testimony. The
National Wildlife'Federation's stand on incineration of
Orange Herbicide by the VULCANUS is considered favorable
with certain qualifications and Marquardt*s stand is
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	41
considered unfavorable. The 24 March Federal Register
announcement reviewed the Orange disposal project status
in a thorough manner. In addition to the letter of comment
by the EPA to the Revised Draft Environmental Statement,
the EPA also wrote the Air Force a letter concerning the
Final Environmental Statement which, among other things,
required that stack monitoring would be necessary to
incinerate Orange aboard the VULCANUS.
Several commentors to the Revised Draft
Environmental Statement expressed agreement with the
proposed action of incineration at sea (Appendix 0, Final
Environmental Statement); however, in view of the situation
surrounding incineration as described above, this paper
has been prepared to describe the VULCANUS and substantiate
the judgment that 99.9 percent Orange Destruction Efficiency
can be attained. The Air Force position is comprehensively
stated in the Final Environmental Statement, and the
Revised Draft Environmental Statement and Final Environ-
mental Statement have received wide distribution, therefore
the Final Environmental Statement will be referenced
extensively throughout this paper. Shell Chemical Company
data and results from their test burn of chlorinated
hydrocarbons aboard the VULCANUS in the Gulf of Mexico
will also be utilized; this information was not available
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	42
in time to be incorporated into the Final Environmental
Statement.
In addition, the Air Force has contracted
with the firm of Arthur D. Little, Cambridge Massachusetts
to perform an independent evaluation of the Air Force
position on the incineration of Orange Herbicide by the
VULCANUS.
II. STATEMENT OF INCINERATION SITUATION
The VULCANUS has not incinerated Orange
Herbicide nor is there any data on the destruction of
Orange Herbicide in a "conventional" incinerator. The
Air Force has made a judgment that the VULCANUS can destroy
Orange Herbicide at 99.9 percent efficiency. This judgment
is based on a synthesis of the following information:
1)	The results of thermal degradation and
combustion of Orange Herbicide in various types/sizes of
incinerative systems.
2)	The results of combustion efficiency
studies and ocean ecological studies from incineration of
chlorinated hydrocarbon aboard incinerator ships, including
the VULCANUS, and efficiency of a land-based incinerator at
Rocky Mountain Arsenal Company utilized to incinerate
mustard agent.
3)	A comparison of the overall operational
C. RAY BEEBE 8c ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	43
capabilities of the VULCANUS incinerators with incineration
system combustion parameters, which are known to effect
essentially 100 percent destruction of Orange Herbicide.
It is the resultant judgment (99.9 percent
efficiency) that is a prime factor in the concern expressed
by the EPA, The Marquardt Company, and the National
Wildlife Federation, and which has resulted in the EPA
opting for a tentative position for a research permit
instead of a special permit and scheduling of public
hearings. It is significant to note that there has been
relatively little concern for the environmental impact of
the proposed action (99.9 percent destruction) in the
comments to the Revised Draft Environmental Statement or
at the 19 February 1975 meeting; in fact, the Air Force
position is that the environmental impact would be minimal
and deemed acceptable even if the Orange Destruction
Efficiency were lowered to 99.0 percent (Part III.B.2. and
III.C.5., Final Environmental Statement).
III. DISCUSSION OF INFORMATION
Thermal Degradation/Combustion of Orange
Herbicide. Five studies on the thermal degradation/combus-
tion of Orange Herbicide have been conducted and the
objectives and conclusions of these studies are included
as Appendix D to the Final Environmental Statement. Two
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	44
of these studies are of particular interest.. The
Mississippi State/U.S. Department of Agriculture report
states that the normal butyl (n.b.) esters of 2,4-D and
2,4,5-T are combusted between 550 and 700° Centigrade and
that 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) is com-
pletely combusted between 980 and 1000° Centigrade. The
other is The Marquardt Company and Air Force study which
was conducted in November of 1973; this study is included
in its entirety as Appendix B to the Final Environmental
Statement. This study reported the results of eight test
burns with injection fuel temperature ranging from 66/63°
Fahrenheit to 179/175° Fahrenheit. The relative pyrolysis
efficiencies for the eight runs ranged from 99.98 percent
in Run #2 which had a fuel input temperature of 98/96°
Fahrenheit to 99.999 percent in several of the other burns
(P.E(1-13), Final Environmental Statement). However, the
Orange Destruction Efficiency, although not reported, was
effectively 100 percent/ i.e. no n.b. ester of 2,4-D,
2,4,5-T, or TCDD was detected in the combustion gas from
any of the test runs. All of the studies in Appendix D
show that undiluted Orange will sustain high temperature
incineration.
Ship Combustion/Ecological Data. Appendix
N of the Final Environmental Statement contains the
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	45
following studies relating to incinerator ships:
1)	An extract from Professor (Dr.) Klaus
Grasshoff, Kiel University, Germany, Report on Possible
Effects of Burning of Chlorinated Hydrocarbons at Sea.
2)	Data from the incinerator ships MATTHIAS
conducted by the Bayer Corporation, Germany on "Burning of
Chlorine Containing LiquidInvestigations of the
Combustion Gases: 26 August 1971*"
3)	An ecological study conducted by the
Center of Biological Studies and Research and of Oceano-
graphic Medicine, France, on the "Effect on the Marine
Environment of the Combustion at Sea of Some Industrial
Wastes."
4)	A French government document on
"Incineration on the High Seas of Chlorinated Industrial
Wastes."
5)	Testimony presented by a representative
of the National Research Council of the Netherlands on
incineration of chlorinated hydrocarbons by the VULCANUS;
this testimony was presented in the public hearing 4 October
1974 on the Shell Chemical Company's Application for Ocean
Incineration. All of these documents are favorable for
ocean incineration as regards combustion efficiency and
ecological effects.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	46
Documents 1, 2 and 3 listed above apply to
the incinerator ships MATTHIAS, document 4 applies to the
MATTHIAS I and II and the VULCANUS, and document 5 applies
to the VULCANUS. The documents in paragraph 2 and 5 state
measured combustion efficiencies greater than 99.9 percent.
The document in paragraph 1 quotes Dr. Grasshoff as stating
that "if burning of chlorinated hydrocarbons is carried
out at temperatures higher than 1000° Centigrade, more
than 99.9 percent of the materials are completely burnt."
The document in paragraph 3 gives a favorable report on
ecological impact upon the ocean environment. The document
listed in paragraph 4 is favorable toward the VULCANUS,
stating that it achieves essentially complete pyrolysis,
but is unfavorable, in part, to the combustion in the
MATTHIAS II and relates its unfavorable remarks to the
MATTHIAS' inability to maintain a uniform temperature of
1000° to 1100° Centigrade. As stated above, the documents
are contained in total in Appendix N and are also referred
to frequently throughout the narrative of the Final
Environmental Statement.
Land-Based Incinerator Data. Part V.B. of
the Final Environmental Statement describes the conventional
incinerator system at Rocky Mountain Arsenal which destroys
mustard agent at a calculated destruction efficiency of
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	47
99.9887 percent. This is presented to further establish
that conventional high temperature incinerators are capable
of essentially complete destruction of waste combustibles.
Shell Chemical Company - VULCANUS. Since
the filing of the Final Environmental Statement, the Shell
Chemical Company has incinerated four shiploads of
chlorinated hydrocarbon waste by the VULCANUS at a desig-
nated burn area in the Gulf of Mexico approximately 160
miles from Galveston, Texas. The first two shiploads were
accomplished under a research permit which required, among
other things, that Shell demonstrate by stack sampling the
VULCANUS, a combustion efficiency of at least 99.9 percent.
The data from the first burn was presented at a public
hearing on 14 November 1974 in Houston, Texas, at which
the EPA and Shell gave testimony that the combustion
efficiency was greater.than 99.9 percent. These figures
were disputed somewhat at the hearing but were upheld by
the EPA and Shell. The objections, however, were valid
enough for the EPA to require stack monitoring on the second
Shell bum. This Laboratory, EHL(K), has not received the
data from the second Shell burn but has been assured that
the combustion efficiency was greater than 99.9 percent;
Shell was not required to perform stack sampling on the
incineration of the remaining two (shipload) burns of the
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	48
Shell waste.
I understand that this report is finalized
and that the data is in now.
Data presented at the 14 November hearing
also indicated that temperatures of 1400° Centigrade were
achieved in the incinerator fire box and that the hydrogen
chloride gas exhaust did not significantly affect the pH
jof the water in the burn area nor could any adverse biolog-
ical factors be attributed to the first burn.
The BTU rating of the Shell waste ranged
from 6200-6400 BTU/pound. Herbicide Orange has a BTU
rating of 10,000 BTU/pound; therefore, it is expected that
high temperatures can be achieved by incinerating Orange
in the VULCANUS' incinerators. In addition, since the
Shell burns were generally at the maximum fuel flow rate,
and the chlorine content of the Shell waste was about 65
percent compared to 30 percent for the Orange, it appears
that the environmental aspects of generation of hydrogen
chloride can be discounted for ocean incineration.
The favorable outcome of the Shell project
is very encouraging toward predicting the capability of
the VULCANUS to adequately incinerate Orange Herbicide.
The VULCANUS Vessel. The VULCANUS is
described in the Final Environmental Statement and in the
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	49
transcript of the public hearing of the Shell Chemical
Company's Application for Ocean Combustion. For those not
familiar with the vessel, it has a length of 334' 6",
breadth 45' 11" and a maximum draft of 24' 5". It has 15
waste tanks ranging in size from 115 to 574 cubic meters and
carries a maximum load of 4,200 metric tons. The waste is
pumped from the tanks to either of two high quality
incinerators mounted on the aft of the vessel. The maximum
waste fuel incineration capacity is 12.5 metric tons per
hour per incinerator and the maximum air flow is 90,000
cubic meters per hour per incinerator. The waste must be
liquid and pumpable; it may contain solid substances in
pieces up to 5 cm in size which are subsequently minced
into about 2 mm pieces prior to injection into the
incinerator firebox. Each incinerator has a maximum inside
diameter (firebrick to firebrick) of 4.80 meters, a total
height including stack of 10.45 meters, and the volume of
each is calculated to be 87.9 cubic meters. Each inciner-
ator chamber has three rotating cup injectors manufactured
by the Saacke Company, Bremen, Germany, to provide
atomization and turbulence. Rotating cup injectors are
excellent systems which are widely used in the incineration
industry. Ross describes the rotary cup injector and states
that liquids should have a viscosity of less than 750 SSU
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	50
(130 centistokes) for satisfactory atomization (Part V.B.,
Final Environmental Statement). The specification on the
SKV Saacke burner states that the temperature of the fuel
flow should be as low as possible to prevent fouling of the
rotary atomizer cup; however, it should be high enough so
that the fuel arrives at the burner at a viscosity of not
more than about 5-8 degrees engler ( 38-60 centistokes).
Regarding operation of the incinerators, auxiliary fuel is
used to bring the incinerators up to the temperature re-
quired for the waste and then the waste is admitted to the
incinerator.
The Shell Chemical Company's Application for
Ocean Incineration contains a letter from the Department of
Transportation, U.S. Coast Guard to the Ocean Combustion
Services BV Rotterdam, The Netherland, 16 September 1974,
stating that authorized cargos to be handled in U.S. ports
are Herbicide Orange and chlorinated hydrocarbons. The
Shell Chemical Company had nothing to do with the inclusion
of Orange Herbicide in this letter; this was an independent
action taken by Ocean Combustion Service.
IV. VULCANUS INCINERATION OF ORANGE HERBICIDE
In January 1974, a description of the Orange
Herbicide, including its viscosity, was furnished the agent
of Ocean Combustion Engineering and the Air Force was
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	51
subsequently advised by the agent that the VULCANUS was
capable of incinerating the Orange; this position was veri-
fied via telecon with the agent on 14 April 1975. The
VULCANUS does not have provisions for heating of the waste
fuel tanks; therefore, the viscosity of the waste fuel will
be dependent upon its temperature aboard the VULCANUS. The
winter and summer temperature of the ocean water is 80° -3°
Fahrenheit and the temperature of the incinerator control
room is often in excess of 100° Fahrenheit. The temperature
of the Orange in the VULCANUS tanks when in the burn area
cannot be predicted at this time; however, personal commun-
ication has revealed that the temperature in the storage
area would be at least 80° Fahrenheit and quite possibly
higher. Since the viscosity of Orange Herbicide is 26-30
centistokes at 80° Fahrenheit and decreases fairly rapidly
as the temperature increases, it is expected that the
rotary cup injector mentioned above can satisfactorily
atomize and inject the Orange into the firebox.
In February 1974, two representatives of the
Air Force visited the Ocean Combustion Services BV Rotterdam
and inspected the VULCANUS. Discussion with Ocean Combustion
Services personnel and the Air Force representative con-
cluded with the judgment that the VULCANUS was capable of
high temperature incineration of Orange.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	52
With a feed rate of 12 metric tons per hour
and an air flow rate of 90,000 cubic meters per hour, the
. dwell time, fuel to air ratior and excess air are, as
calculated by the EHLs, approximately 0.6 seconds, 0.11,
and 30 percent, respectively. With a BTU content of
10,000 units per pound, it is expected that the 1400°
Centigrade temperature can be maintained. These parameters
are equal to or in excess of those which the Air Force
considers acceptable parameters (Part II.C., Final
Environmental Statement), and as quoted from the Final
Environmental Statement H. . . acceptable parameters:
measured combustion temperatures 2400-2800°F; dwell time
equal to or greater than 0.14 seconds; a fuel to air mass
ratio of approximately 0.1; and excess air greater than
30%." It is noted that the above sentence says acceptable
parameters, not the Marquardt Company parameters, although
it is readily admitted that the acceptable parameters are
based primarily on the Marquardt-Air Force test burn con-
ducted in November 1973. However, as stated in Part II.C.
of the Final Environmental Statement, one of the main
purposes of the above-mentioned test study was to obtain
data on Orange incineration so that the requirements of
any incinerator system designated for Orange incineration
could be specified.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	53
In view of the information presented in this
paper: studies indicating that Orange Herbicide sustains
high temperature combustion, studies showing that the
incinerator ship can incinerate liquid waste at a very high
efficiency with minimal environmental impact, and a data
analysis that the VULCANUS can incinerate Orange at condi-
tions which are deemed acceptable for destruction of
Orange—it is the Air Force position that the VULCANUS can
destruct the Orange Herbicide with a 99.9 percent destruc-
tion efficiency.
V. OTHER CONSIDERATIONS
Although not germane to the 99.9 percent
destruction prediction, some perspectives seem appropriate:
1)	Three shiploads (2.3 million gallons)
is a relatively small volume of waste; it is recognized
that the TCDD content should warrant consideration; however,
the project is not like gearing-up to handle waste from
a chemical manufacturing process which will generate wastes
for discharge into the environment for many years.
2)	The Orange is now stored on Johnston
Island and Gulfport, Mississippi, two locations where
weather conditions can become adverse to the extent that
a catastrophic event could occur causing serious environ-
mental problems. In addition, maintenance of the storage
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	54
areas to preclude any release of Orange into the environment
is a continuing cost to the taxpayer.
3) The proposed action represents a "high
efficiency" waste disposal action with the resultant dis-
charge stream being emitted into a relatively unproductive/
unpopulated ecosystem. While the appropriateness of such
action can be discussed, it certainly should be agreed that
waste streams from treatment processes should be discharged
where they would do the least harm to the environment.
Once such environment is the designated bum area, another
good environment for discharge would be one that is already
so polluted that the waste stream couldn't possibly have
any further deleterious effect. However, as noted in
Part V.B.3, incineration within the United States is not
considered a viable alternative.
Finally, as mentioned in the introduction,
the consulting firm of Arthur D. Little, Cambridge,
Massachusetts has been contracted to evaluate the Air
Force position as regards the proposed action; specifically,
their contract was to evaluate the capability of the
VULCANUS to incinerate Orange Herbicide with particular
emphasis upon the probability of attaining a 99.9 percent
destruction of the Orange. Their report will be submitted
at'this public hearing and discussed by the next speaker.
•c. RAY BEEBE 6c ASSOCIATES
HONOLULU, HAWAII

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CARLTON R. WILLIAMS	55
That concludes my report, Mr. Chairman.
MR. MOLLOY: Colonel Williams, before we
open it up to questions from the Panel, if there are any,
I would like to divert from the schedule a little bit.
There are two people that indicate that they have severe
time problems, so if I can just ask you to step aside for
a minute or two, I would like to call both of these forward.
The first speaker who has indicated that
he has a time problem is Richard Marland, who is the
Director of the Office of Environmental Quality Control,
State of Hawaii. Dr. Marland represents the Governor here
today.
Dr. Marland, I apologize. I didn't realize
that you had a time delay, a time problem.
DR. MARLAHD: Thank you very much, Mr.
Chairman.
I am not surprised you were not aware that
we had a time problem because we didn't tell you that we
had a time problem until after the presentation of the
Air Force had started. We underestimated the length of
time that their presentation would take.
I am Richard Marland, Director of the Office
of Environmental Quality Control for the State of Hawaii.
Governor Ariyoshi has asked me to express
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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RICHARD MARLAND	56
to you his aloha, but most particularly, to express to you
his gratitude for the consideration you have shown in
holding this hearing here in Honolulu today. Hawaii is
indeed extremely interested in the proposal by the United
States Air Force, and we are grateful to you for holding
this where the people from Hawaii can present you with
their views.
My own testimony relates to the Environmental
Impact Statement for the disposition of Orange Herbicide
by incineration prepared by the Department of the Air Force.
The statement is a comprehensive, informative document
c
that presented well-researched alternative procedures for
incineration of Orange Herbicide.
Our major concerns within that Environmental
Impact Statement were previously presented in our July 9,
1974 letter to the Department of the Air Force. The
inclusions in this letter have been referred to by one of
the Air Force officials.
Of the two options presented in the EIS, we
favor incineration at sea through the use of a scrubber
system with constant monitoring of air emissions for the
entire process of incineration.
However, the alternative of recycling and
reuse of this material does present favorable advantages.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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RICHARD MARLAND	57
We recommend more effort be directed toward recycling of
the Orange Herbicide. In the low-key understatement process
of bureaucratic writing, that could be construed as saying
we are dissatisfied with the presentation of this potential
in the Environmental Impact Statement, and think that it
justifies far greater attention and possibly considerations
as to the procedure for disposition.
This project is of great interest to the
people of Hawaii. However, we deplore the fact that the
Air Force provided only a limited number of copies of the
Environmental Impact Statement for our review. Namely,
eight copies were provided, even though 'we requested more.
This has hindered widespread review within the State of
Hawaii, probably resulting in a less comprehensive review
than is warranted or desirable.
I thank you for your attention and this
opportunity to supply you with our wishes.
Again, I welcome you to Hawaii, and aloha.
MR. MOLLOY: Thank you.
. . I would just like to indicate our pleasure
at the people of Hawaii for allowing us to use this
marvelous room here today.
Thank you.
The next speaker with a time problem is Tony
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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58
Hodges, who represents Life of the Land.
MR. TONY HODGES: I will try to make my
remarks short and to the point, and I appreciate being fit
in with the schedule. > I don't like interrupting the Air
Force, but it seemed like it was going to take forever.
I think it's good that you are holding a
hearing in Honolulu, but I think that where you should be
holding the hearing is in Micronesia, because those are
the people who are downwind of this proposal, or they are
the ones that will be downwind of any ekhaust gases, and
the whole issue seems to separate into those who live upwind
and those who live downwind.
For instance, I am surprised, or I would
wonder if the Air Force would propose the same disposal
system if it were in fact 1200 miles upwind of the
continental United States? For instance, burning it in
the Atlantic with a wind moving to the west toward the
eastern seaboard. I believe that the Air Force would
probably not propose this disposal method of burning.
We have been told, and I have been going
through the Impact Statement, and I am sure that no one
sitting at the Air Force desk today is about to contradict
the official Air Force position of preferring ocean burning,
but we are told by the Air Force, in absolutely enormous
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TONY HODGES	59
and I think repetitive and perhaps superfluous detail, how
safe this is going to be. Well, if it's going to be so
damned safe, why are you putting it out in the middle of
the ocean? And if it's going to be so safe, the effluent
or the gases from this incinerator ship, then why isn't it
done close to a major population center? Why isn't it done
close to a major agricultural center in the continental
United States?
I believe that the Trust Territories, or I
should say the people of the Trust Territories, would be
strongly opposed to the burning of Agent Orange in any
location that would be upwind of them.
The statement by the Air Force that there
are 1200 miles between Johnston Island and the next island
mass would be of great concern if that next land mass would
be New York City. In fact, aerosols are known to be
carried four — I should say three and four thousand miles,
and there was a study done on this, the carrying of pesti-
cide aerosols, done at the University of California, Davis,
and in that experiment they found that airborne pesticides,
residue of it was found as far away as four thousand miles
downwind.
I think that this country — I mean the
United States — has for far too long a time played God to
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TONY HODGES	60
the South Pacific. I think that we have far too long a time
used the people of the South Pacific as guinea pigs and
placed them downwind of our experiments. This is an
experiment.
We obviously used it in a much stronger
fashion in Vietnam itself as a defoliant, but it seems to
me very, very wrong. And speaking I think morally and .
politically as much as environmentally, that we should —
that we would have the audacity to propose burning this
upwind of the Marshall Islands and the Gilberts. There
are people who live there, and there is no proof that the
Air Force can offer that they will not be affected.
The hearing today, and I wasn't at the other
one, seems like a bureaucratic exercise, again, with the
Air Force presenting, you know, the weight of the evidence,
five hundred pages of an Environmental Impact Statement,
which is obviously to justify what they intend to do,
anyway, and what they are trying to get EPA to do.
The State of Hawaii I think made a very good
suggestion, and that is, instead of burning perhaps you
should look seriously at the proposals by private industry
to break the Agent Orange back down into some of the
constituent parts, remove the dioxin and the other problems.
The Air Force dismisses, and simply dismisses,
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TONY HODGES	61
the possibility of the ship sinking. That is, the inciner-
ator ship. They say it has a double hull. Well, double
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hull ships go down, and this could very possibly happen out
there. There is no provision for dealing with the Agent
Orange if the incinerator ship should begin going down.
I have seen nothing in the Impact Statement — I haven't
read it in detail — about what the Air Force would propose
to do if the incinerator ship began to go down. How would
they transfer the material?
I would propose, and I say this, and it may
sound facetious, but it's really quite serious. I think
it brings home a point. If the Air Force feels that your
proposal is so safe for everybody concerned, then I would
suggest the location for the incineration would be in the
courtyard of the inner ring of the Pentagon. You would
then be able to monitor the possible adverse effects by
the effect it had on Air Force personnel as you go from
the inner ring outward. If you are so sure it's safe, then
you would be willing to do it there.
If you are not willing to do it in the inner
courtyard of the Pentagon — I am assuming now that the
Navy is not in the inner ring — but if you aren't willing
to do it there, then you shouldn't do it in the Pacific in
an area that's upwind of people in the Trust Territories
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TONY HODGES	62
who were not part of the Vietnam war and who are not accorded
real U.S. citizenship and rights of U.S. citizens, and who
had nothing to do with this at all. I don't think they
should have to take one iota of risk, and I think that the
Environmental Protection Agency has a very strong duty to
see that the Air Force does not present one iota of risk to
the people of Micronesia. And until the Air Force can
»
convince you one hundred percent, not 99.9 percent, but 100
percent that there is no possible danger to any person or
any living thing in Micronesia as a result of this project,
then the Environmental Protection Agency has a duty to the
people of Micronesia who are trying to become part of this
country — some of them are, certainly, under a U.S. trustee-
ship. You have a duty to refuse this and to make them go
back and recycle it.
I admit that what I have to say does not deal
with technical details, but 1 think it deals with what is
the real issue, and that is, who is downwind of this
project?
That's all I have to say.
MR. MOLLOY: Thank you, Mr. Hodges.
Given the fact that we have this material,
we are stuck with it, and possibly suggesting that burning
it in the inner ring of the Pentagon might be considered
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facetious., but do you have any other alternatives? There
will be comments later on.
MR. HODGES: Sure. There are other — I
think it should be burned in Washington, D.C., if not in
the Pentagon, and I am quite serious. I think that brings
the point home. If there are any risks, the people that
should have to suffer the risks are the people who
manufactured this material and people who used it on people
in Vietnam. They should have to take the risk, not people
who live in Micronesia.
For instance, there would be more people at
the hearing here, I can assure you, if this Agent Orange
were proposed for burning 1200 miles upwind of Hawaii.
People would be here in droves, I would assure you. And I
think that if you have hearings about this in Micronesia
on each of the islands, or made travel arrangements for
people from each of the islands in the Trust Territories
to come here, that you would have a lot of testimony saying,
no, we don't want to be upwind of your experiments.
And that's the real central fact, is, who
is upwind and who is downwind? And they would want to be
downwind, I should say, right, where they could be protected.
Where would I propose doing it? I say if
you are going to burn it, and it seems to me from looking
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TONY HODGES	64
through this, there seems to be a lack of discussion of the
possibility of, you know, recycling it, breaking it back
down to its constituent parts. I understand the Air Force
has several proposals to do that. I think EPA has an
obligation just to tell them, you know, sit tight and let's
see how it is you are going to get rid of it, but not burn
it. If you are going to burn it, I think the only people
that should have to run the risk are people who manufactured
it, and certainly Americans. And I would then come in and
say, we don't want to suffer that risk, and I can't see
how we can give to the Micronesians — and there is a
representative of them here today — how we can hand this
risk to them. They had nothing to do with it.
So the one thing that is absolutely
unacceptable to the United States, as far as I'm concerned
as a citizen of the united States, is allowing there to be
any risk whatsoever to anybody, you know, who is not an
American, period.
MR. MOLLOY: Are there any questions or
comments from the Panel?
DR. MacKENZIE: I would just like to say
very quickly, Mr. Hodges, that I will be presenting a
statement later on during the course of this hearing which
will deal very specifically with our considerations of the
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65
reprocessing, if you will, recycling options. That will
become part of the record of this hearing and considered
by the Environmental Protection Agency.
MR. HODGES: Surely, okay. And I think, too,
it would seem to me, I am not sure what legal recourse the
people of Micronesia have since they have not been allowed
rights in the United States Federal Courts to challenge
actions of federal agencies in Micronesia in the Trust
Territories, it would seem to me then that the only option
open to the Micronesians would be to go to the united
Nations and to have the United States, as the Trustee of
that area, forbidden to act in this way toward the Trust
Territories. I consider it a hostile act toward Micronesia.
o
99.9 percent, I'm Bure the Colonel here
would not like to sit downwind of that stack.
When they talk about the — what is it, .4
grams or micrograms per acre, and they say this is less
than we put on U.S. soil, well; this is not U.S. soil.
These are international waters.
He is also assuming, obviously, perfect
mixing. We all know there is no such thing as perfect
mixing, and those are phony figures when you add them up
like that. You could have a catastrophe.
If you lose one life in Micronesia, you know,
f- '
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CARLTON R. WILLIAMS	66
this project is murderous. If you make one person sick in
Micronesia* it's wrong. In fact, if you even make them
live with the psychological risk, knowing that this is
going to be done and they are worried, you have hurt them,
and I think that we have no right to do it. It's really
that simple. It's a moral question.
MR. MOLLOY: Thank you, Mr. Hodges.
MR. HODGES: Surely.
MR. MOLLOY: Are there any questions from
the Panel to Colonel Williams?
MR. BIGLANE: Yes, I have one for the Colonel
I was reading the statement in the last
paragraph. I refer to the conclusion that is drawn by you.
"It is the resultant judgment (99.9 percent
efficiency) that is a prime factor in the concern expressed
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by the EPA, The Marquardt Company, and the National
Wildlife Federation, and which has resulted in the EPA
opting for a tentative position for a research permit
instead of a special permit and scheduling of public
hearings."
Let me say that in speaking for EPA, that I
suspect we will recommend research permits be given on
several future incinerations of wastes. This is a new
technology. As I stated at the outset, we want to learn
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CARLTON R. WILLIAMS	67
from these burns. We want to learn just how acceptable to
the ocean incineration will be.
In learning, I do not mean to infer at the
expense of humans or of marine life and other participants
in our environment, and along with these remarks, let me
assure you that whatever EPA will recommend, and in the
monitoring following such burns, will not be cosmetic.
Such conditions that EPA might place on a
permit for incineration will be real, and there will be a
great deal of thought. There already has been a great
deal of thought given to the types of monitoring require-
ments that EPA might incorporate into a permit just for
the protection of people downwind, upwind, anywhere.
Because if this is going to become a technology available
to this country for disposal of highly toxic wastes, then
be assured whatever we do in requiring monitoring programs
will be addressed to just that concern.
I really didn't have a question. I just
wanted to get that on the record for clarification of
this conclusion. That's all.
COLONEL WILLIAMS; Right.
I understand that in the broad sense of the
new technology and emerging technology of getting data, is
that — I understand you are telling me that.
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CARLTON R. WILLIAMS	68
This comment was specific in the fact that
we submitted a request for a special permit which does not
require monitoring, and we had wondered or looked for
reasons why it is a research permit, and we felt that your
concern, as I said, expressed by EPA, and which you I think
have just voiced as to our position and the other people's
position, was that perhaps we wouldn't.get it 99.9 percent.
I don't see any discontinuity between what
you have said and what I have in my statement.
} '	MR-. BIGLANE: I just want to clarify that
\'	t
we would schedule a public hearing in any event, whether
it had been a special permit or research permit. And I
want to assure that we will probably issue research permits
for the next several types of incineration of wastes, not
just Herbicide Orange, but any other wastes that might be
proposed to be incinerated at sea that is different from
Herbicide Orange if we do go through that exercise and it
is successful, and that waste is different from the Shell
organic chlorine waste which was incinerated in the Gulf
of Mexico last October.
In any type of waste we will most probably
recommend the issuance of a research permit and schedule
a public hearing in that matter.
MR. MOLLOYt Are there any other questions
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69
or comments?
(There was no response.)
MR. MOLLOY» Thank you, Colonel.
LIEUTENANT COLONEL WILLIAMSs Thank you, Mr.
Chairman.
MR. MOLLOYs Before we bring on the next
speaker,: I said we would take a break at eleven o'clock.
It's ten minutes after, so we will reconvene at twenty-five
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minutes after eleven.
(A fifteen-minute recess was taken at this
time.)
MR. MOLLOY: We can begin again, please.
We will modify the schedule a little bit,
and I would like to call on Mr. Demei Otobed.
MR. DEMEI OTOBEDs My name is Demei Otobed.
I am representing the Trust Territory Environmental
Protection Board, and at the same time the Trust Territory
Government. I am the Chief Etymologist for the Trust
Territory.
The Trust Territory Environmental Protection
Board held its meeting in Honolulu this month and came up
with a short resolution. We cannot give you a 500-page
study report, so we give you only a half-page that contains
our concern regarding the burning of this Herbicide Orange
C. RAY BEEBE & ASSOCIATES
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DEMEI OTOBED	70
in the Pacific area, and I will read it. It's very short.
The Trust Territory Environmental Protection
Board, in a meeting in Honolulu, Hawaii, on April 21, 1975
unanimously resolved that:
1)	The Air Force has proposed that the Herbi-
cide Orange be brought to the Pacific Area for disposal
by burning;
2)	Burning of Herbicide Orange in the
- Pacific Area may expose the islands and the people of
the Trust Territory to dangerous health hazard and
environmental contamination the extent of which cannot
be determined;
3)	The Trust Territory Environmental
Protection Board unanimously resolved that alternative
methods should be sought and used which methods will
not be an environmental hazard to the environment of
the Trust Territory;
4)	That Mr. Demei Otobed be and he is
authorized by the Trust Territory Environmental
Protection Board to attend the public hearing as the
representative of the Board indicated and to present
there the thinking of the Board as by this resolution.
Thank you very much.
MR. MOLLOYt Are there questions from the
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71
Panel?
(There was no response.)
MR. MOLLOY: Mr. Otobed, I would like to
thank you for coming all the way from the islands to Hawaii
to present the views of your government on this Air Force
proposal. Thank you.
DR. WELCH: Mr. Molloy, before we proceed
could I make one clarifying comment?
MR. MOLLOY: Sure.
DR. WELCH: We have considered that the
proposed incineration site be west of Johnston Island
primarily from the point of view that approximately 1.5
million pounds of product is stored on that island at this
point in time, and that had this storage site not existed,
other burn sites might well have been selected. We are not
lightly considering this particular site.
MR. MOLLOY: Are you saying that you are now
considering other sites?
DR. WELCH: I am not saying that at all.
There was some concern that was expressed by a few previous
speakers that we were bringing the material to the Pacific
for the aspect of the burning, and all I am pointing out is
that the material currently is stored on Johnston Island,
and the burn site really is adjacent to its current storage
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72
site.
MR. MOLLOY: And have you considered other
burn sites other than Johnston Island, even considering the
fact that the material is now stored at Johnston Island?
DR. WELCH: We have not.
MR. TONY HODGES: Mr. Chairman, to add one
thing to it, I believe that they are proposing to bring, .8
million — you know, whatever — from Mississippi to the
bum site. Isn't that right? They are proposing transport-
ing it thousands of miles through the Panama Canal across
the Pacific, this Agent Orange to the Johnston Island burn
area.
MR. MOLLOY: I believe that is correct.
MR. HODGES: So he is talking about what is
on Johnston Island, but again there is almost an equal
amount not on Johnston Island, some five or six thousand
miles away.
DR. WELCH: That almost equal amount is
about 700,000 gallons.
MR. MOLLOY: Well, we can move on to the
next speaker, who is Dr. Karl Bastress from the Arthur D.
Little Corporation, Cambridge, Massachusetts.
DR. BASTRESS: Mr. Chairman, ladies and
gentlemen.
C. RAY BEEBE & ASSOCIATES
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E. KARL BASTRESS	73
My name is E. Karl Bastress. I am a member
of the professional staff of Arthur D. Little, incorporated,
a research and consulting firm, with headquarters in
Cambridge, Massachusetts.
My education includes a Ph.D. degree in
aeronautical engineering from Princeton University, and I
have had approximately twenty years of experience in the
design and performance analysis of combustion systems. For
the past seven years my work has been devoted primarily to
the analysis of combustion behavior and pollutant formation
in liquid fuel combustion equipment.
My colleagues at Arthur D. Little and I
have reviewed the action proposed by the Air Force to use
the incinerator ship VULCANUS to dispose of the Herbicide
Orange.
The purpose of our review was to provide an
independent assessment of the capability of the VULCANUS
to incinerate the herbicide and to achieve a 99.9 percent
target destruction efficiency.
Our assessment of the proposed action
included three tasks:
One, a review of relevant data.
Two, an assessment of the suitability of the
VULCANUS for incineration of the Herbicide Orange, and,
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E. KARL BASTRESS	74
Three, a quantitative prediction of the
destruction efficiency of the herbicide and its TCDD
contaminant.
Data which are relevant to the proposed action
are of three types:
1.	Data on destruction efficiencies of
chlorinated hydrocarbons by the VULCANUS.
2.	Data on incineration of the Herbicide
Orange by other incinerators, and
3.	Data on hydrocarbon destruction by
other combustion systems similar to the VULCANUS incinerators,
and burning fuels similar to Herbicide Orange.
In reviewing these data our first observation
is that destruction efficiencies exceeding 99.9 percent are
»
achieved routinely in many types of combustion equipment
burning liquid fuel, thus achieving a target level of 99.9
percent does not require an advance in the state of
combustion system technology.
Our second observation is that a number of
different definitions of destruction efficiency are in use.
Of these definitions we have chosen the most conservative
as a basis for assessing VULCANUS* performance with Herbicide
Orange. This basis includes two destruction efficiency
criteria; one, the destruction of all hydrocarbons.
C. RAY BEEBE 8c ASSOCIATES
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E. KARL BASTRESS	75
including the major constituents of the herbicide, and two,
the destruction of the minor constituent, TCDO.
With regard to the suitability of the
VULCANUS for incineration of Herbicide Orange, we reviewed
the potential problem areas of corrosion, suspended
solvents and viscosity, and found no factors which would
hinder the storage and handling of the herbicide by the
VULCANUS.
We also reviewed the conditions required to
destroy Herbicide Orange^ and the operating conditions of
the VULCANUS incinerators, and concluded that the VULCANUS
is capable of destroying the herbicide.
To provide a measure of confidence in the
Air Force prediction of 99.9 percent destruction effi-
ciencies, we conducted a theoretical analysis of the
combustion of Herbicide,Orange by the VULCANUS. Our
analysis involved a mathematical model of droplet formation
and evaporation, and combustion gas mixing, which are the
principal mechanisms which limit the efficiency of
destruction or combustion of liquid fuels.
Using this model, we have predicted that the
VULCANUS will achieve a total hydrocarbon destruction
efficiency of 99.92 percent. This level of hydrocarbon
destruction efficiency will assure equivalent destruction
C. RAY BEEBE 8c ASSOCIATES
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E. KARL BASTRESS	76
efficiencies for the major herbicide constituents 2,4-D and
2,4,5-T.
Consideration of the uncertainties in the
analysis which led to this prediction allow us to express
the result in terms of probability of achieving specified
levels of efficiency. Stated in these terms, we concluded
that the probability of the, VULCANUS achieving the target
level of 99.9 percent hydrocarbon destruction efficiency
with Herbicide Orange is 70' percent. The probability of
achieving 99.7 percent efficiency is 90 percent, and the
probability of achieving a 99.5 percent efficiency is 97
percent.
The complication of these results is that
¦ ¦	f
we are not 100 percent certain of achieving the target
efficiency level, but we are quite confident of either
exceeding this level or coming very close to it.
With regard to the TCDD destruction,
nominally we expect to achieve a destruction efficiency
equal to that achieved for other hydrocarbons. There are
certain physical and chemical properties of TCDD which may
tend to reduce its destruction efficiency, however, we do
not have accurate data on these properties, and therefore
cannot predict their effects with any degree of confidence.
We have developed a worst case or lower bound
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E. KARL BASTRESS	77
estimate of 96 percent destruction efficiency for TCDD, but
we expect that the level actually achieved will be near the
target level of 99.9 percent.
Finally, v;e have identified three possible
methods of increasing destruction efficiencies if the
target level is not achieved during the first burn. These
methods are:
e
1.	Heating the herbicide prior to burning.
2.	Diluting the herbicide with a low
viscosity fuel oil, and
3'. Reducing the herbicide and air feed
rates to the incinerators.
Of these methods the third appears to be
the most feasible.
We conclude that the proposed action is
sound in that the VULCANUS is a suitable facility for
incineration for Herbicide Orange. Destruction efficiencies
achieved by the VULCANUS will be high, and probably will
meet or exceed the 99.9 percent target level.
If this level is not achieved, any of a
number of simple remedial actions can be taken to raise
the destruction efficiencies to the target level.
Mr. Chairman, I have copies here of our
report to the Air Force on this study which I can leave
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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E. KARL BASTRESS	78
with you if you like. I must admit to there being a number
of typographical?errors in tiie appendices to the report,
so that if any of you wish to pursue the mathematical
analysis which we conducted, I would suggest that you
contact me for correction of these errors before you do so.
Thank you.
MR. MOLLOY: Thank you. We will put a copy
of that report in thfe record.
- I have a question.
You indicated that there were three
alternative ways to increase the probability of having
the 99.9 percent efficiency reached, and you said that
the last one was the better of the three alternatives.
Is there any reason why you couldn't technically combine
the alternatives?
DR. BASTRESS: Mr. Chairman, I indicated
three possible approaches, all of which would require some
modification of the VULCANUS; I indicated the third as
being the most feasible, not the best, because it perhaps
could be done with the least extensive modification of
the VULCANUS.
The VULCANUS is not, except for the
alternative of mixing a low-?viscosity fuel with the
herbicide, the VULCANUS is not prepared at the present time
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E. KARL BASTRESS	79
to utilize any of these approaches. It would require some
modification to the ship, but we don't regard those
modifications as infeasible. But nevertheless, the ship
is not prepared to carry them out at the present time.
MR. MOLLOY: Do you have any.idea of the
cost of those modifications?
DR. BASTRESS: No, I do not.
MR. MOLLOY: I have no further questions.
Are there any other questions from the
Panel?
DR. ENOS: I have a question.
MR. MOLLOY: Dr. Enos.
DR. ENOS: Did you make any calculation of
the residence time in the incinerator?
DR. BASTRESSt Yes. We agree with the Air
Force ^calculation of total residence time in the inciner-
ator of 0.6 seconds. That is divided between a residence
time in the main incinerator or chamber, Where most of
the mixing and incineration takes place, which has a
residence time of approximately 0.4 seconds, and the
remainder, 0.2 seconds is spent in the stack, which might
be regarded as an after burner. And, as I say, the
residence time there is 0.2 seconds.
DR. ENOS t Thank you.
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80
MR. MOLLOYt Thank you. There are no
further questions.
The next Air Force speaker is Lieutenant
Colonel Gale Taylor from the united States Air Force
Environmental Health Laboratory, Kelly Air Force Base,
Texas.
Colonel Taylor.
LIEUTENANT COLONEL TAYLOR: Thank you,
Mr. Chairman.
Ladies and gentlemen, I am Lieutenant Colonel
Gale D. Taylor. I am the Chief of the Veterinary Ecology/
Toxicology Division at the Environmental Health Laboratory
at Kelly Air Force Base, San Antonio, Texas.
I have a Doctor of Veterinary Medicine from
the University of Illinois. I have a Master of Science
in Research Animal Medicine from Texas A&M University.
I have a Master of Public Health from the University of
Minnesota, and a Ph.D in Environmental Health from the
University of Minnesota.
My main area of research has been devoted
to toxicology, primarily environmental toxicology and
environmental contaminants. I have been involved in this "
area since 1963, and have worked with both atmospheric and
water contamination.
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GALE D. TAYLOR	81
The title of my paper is. Description of
the Proposed Ocean Dumping Site for Herbicide Orange, and
there are a few typos.
Using presently available knowledge of
ocean characteristics and ecosystems, it is possible to
develop criteria for acceptable ocean disposal sites and
examine specific locations to determine their suitability
for this use. This presentation lists site criteria and
describes the area designated for incineration of
Herbicide Orange.
Pequegnat, in his testimony to EPA concern-
ing the ocean dumping of incineration waste in the Gulf
of Mexico, stated that the general advantages of offshelf
disposal of industrial wastes are: (1) the presence of
great volumes of water, (2) relatively simple water and
air currents, (3) little stratification of the water
column, and (4) relatively little productivity in the
area. The area chosen for disposal should possess all
these characteristics. This position statement will show
that the area designated for the disposal of incinerated
Herbicide Orange is acceptable in all aspects.
THE OCEAN ENVIRONMENT
A. General
The op6n ocean, particularly at the middle
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GALE D. TAYLOR	82
latitudes, provides the best medium for the disposal of
incinerated organic waste. It is one of the least
productive areas of the world. It has the capacity to
absorb, without deleterious effects, large amounts of
degradable and inorganic wastes. What small effect occurs
at the time of incineration is transient due to internal
recovery of the ecosystem of the particular area and by
immigration from adjacent areas.
Not all marine environments are unproductive.
Estuarine and inshore waters, unlike the open ocean, are
quite productive. These ecosystems may double the total
production (in biomass) of terrestrial agriculture under
irrigation and produce up to 30 times more per unit than
the open ocean such as the proposed disposal site.
Estuaries and inshore waters have the attributes of lower
salinity and higher nutrients due to the inflow of fresh
water and also have the advantage of shallower depths.
Disposal of materials far from land produces
the least environmental impact simply because it is being
put immediately into an unproductive ecosystem where it
can be diluted and degraded. When materials are disposed
of on land, eventually they may move through the hydrologic
system to rivers, estuaries, and inshore waters where
severe environmental impact may be exerted before
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GALE D. TAYLOR	83
degradation can take place. Also bioaccumulation of toxic
or hazardous materials could occur with still further
adverse implications.
With the exception of a total recycling
system, incineration in the unproductive open ocean is the
most environmentally safe alternative of waste disposal
known.
B. Ocean Food Chains
The primary producers are photosynthetic
plankton. These organisms assimilate inorganic materials
into organic matter. They consist mostly of microscopic
diatoms and dinoflagellates although in some areas green
and brown algae may predominate. These organisms are
found in the euphotic zone, which in some instances may
extend down to 200 or 300 meters, but the bulk of the
production is in the upper 100 meters.
Crustaceans and protozoa graze upon the
phytoplankton, and they in tuirn are fed upon by carnivores
such as fish. The food chain fpr carnivores is a long,
complex and intermingled web.
Below the euphotic zone nearly all the
r	_
pelagic animals are predators. The benthic organisms are
scavengers or decomposers feeding on detritus falling from
the zones above them.
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GALE D. TAYLOR	84
DESCRIPTION OF PROPOSED DISPOSAL SITE
Its Locationc
The disposal site is located between 15° 45*
to 17° 45' N latitude and 171° 30' to 172° 30' W longitude.
It comprises approximately 9117 square miles, which, by
the way, is about the size of the State of Vermont. The
reported mean depth is between 4937 and 5486 meters with
a minimum depth of 3575 meters and a maximum of 5568
meters. It is thus somewhat over two miles deep. It is
located approximately 120 miles southwest of Johnston
Island and 1200 statute miles southwest of the Hawaiian
Islands. The area is generally regarded as being one of
the least productive areas in the Pacific Ocean. Very
little specific data is available for this particular
area but several areas in the Pacific Ocean have been
studied and data can be taken from these studies.
Physical Features
1- PH
High pH in the receiving medium is necessary
for adequate chemical dissolution of the pyrolysis products
of incineration. Among these products is HC1 which would
tend to lower the pH of the receiving water. Ocean water
has a strong carbonate buffer system along with borate
and silicon systems. The diffusion of carbon dioxide into
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GALE D. TAYLOR	85
the upper ocean levels and biological activity at that
level give the ocean an alkaline pH strongly resistant to
change. In the Pacific Ocean, the pH profile shows a
distinct inflection. A pH maximum of 8,2 - 8.3 in the
first 100 m can be attributed to carbon dioxide diffusion
and biological activity. The pH minimum of 7.5 - 7.7
occurs at 200 - 1200 tn and is associated with the minimum
oxygen profile and is attributed to biochemical processes.
Specific values for surface pH in the area 10° to 20° north
and 170° to 180° west range from 7.9 - 8.3 with the read-
ing nearest the disposal area being 8.2.
2. Dissolved Oxygen
Dissolved oxygen is an important factor in
oxidizing pyrolysis products. The presence of oxygen in
sea water is due to contact of the water with the
atmosphere at the sea-air interface and to the metabolism
of photosynthetic organisms. The oxygen concentration
present at any given time is the result of a series of
biological and physical factors. The diffusion of oxygen
into sea water is dependent on the partial pressure of
the gas in the atmosphere, the concentration gradient in
the surface layer, the atmospheric pressure, temperature
and salinity. In most instances there is a maximum
oxygen concentration in the euphotic 2one due to diffusion
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GALE D. TAYLOR	86
and photosynthesis, but there is a steady decline until
an oxygen minimum is reached.
The vertical distribution of oxygen in
the sea can be summarized as followst (1) A well-mixed
layer in equilibrium with the atmosphere and relatively
uniform in oxygen content extending to the thermocline,
(2) at lower depths, reactions with organic matter causes
a variable decrease in oxygen concomitant with increasing
depths, the minimum concentration being found between 700
and 1000 meters, and (3) lower depths may have the
same or higher oxygen content due to sinking colder water
originating from waters that originated from much higher
latitudes.
3.	Salinity
The mean surface salinity for the proposed
disposal site is 34,75 parts per thousand with negligible
variation over the course of a year. This value is not
significantly different from average open ocean salinity
taken from other parts of the world.
4.	Light
Light penetration in the ocean has a great
effect on the vertical position of plankton. The depth
of the euphotic zone, in which the majority of phyto-
plankton is found, depends primarily on the total amount
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GALE D. TAYLOR	87
of light received and the transparency of the water. In
tropical regions with high average surface illumination,
the vertical distribution of phytoplankton may extend to
-depths of about 100 meters.
Diel rhythmic vertical migration of
plankton is also associated with fluctuations in light.
It is believed that this phenomenon is caused by animals
moving to a zone of optimum light intensity. This causes
an aggregation within certain strata. The phases of
migration are described as movement toward the surface
in the evening, departure from the surface at or about
midnight, return to the surface near dawn, and a sharp
return to normal daytime depth as the sunlight begins to
penetrate the water. It is estimated the three-fourths
of the zooplankton exhibit diel migration rhythms.
In general, pelagic fish follow a diel
rhythm in respect to vertical distribution. During day-
light hours they tend to be deeper and at night approach
the surface to feed. However, due to the low standing
biomass and the generally recognized low productivity,
these diel rhythms are inconsequential as related to
significant rhythmic increases of biomass in the mixing
zone.
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GALE D. TAYLOR	88
5. Temperature
The average surface temperature of the
tropical Pacific Ocean between 10° and 20° north latitude
is 26.4° Centigrade (79.5° Fahrenheit) with an annual
range of about 3° Centigrade. Those are the extremes in
temperature recorded in February and August. The mean
yearly temperature of the surface water in the disposal
area is 26.9° Centigrade (80.4° Fahrenheit) with a minimum
r
mean of 24.8° Centigrade (76.6° Fahrenheit) and a maximum
mean of 29.0° Centigrade (84.2° Fahrenheit). The vertical
temperature distribution in the upper layers consists of
an isothermal layer (identical temperatures at different
depths), the thermocline (a layer with maximum decrease
per unit depth), and a thick lower layer with slowly
decreasing temperatures. The thermocline is formed by
thermal energy received by the surface layer which
decreases the water density thus producing a vertical
stratification of progressively increasing stability.
The resulting thermocline restricts vertical heat and water
exchange. A strong thermocline also inhibits physico-
chemical and biological vertical exchanges thus greatly
affecting both the hydrographical and ecological dynamics
within the area concerned. The tropical sea has a steep
thermocline Which has considerable influence on both
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GALE D. TAYLOR	89
vertical exchange and animal distribution. The thermocline
in the proposed disposal area is located at a depth of
about 250-350 feet.
Vertical distribution of marine invertebrates
may be affected by temperature in three ways: (1) Exclusion
from water depths with unsuitable temperature, (2) migration
/
to suitable thermal levels within the vertical gradient,
or (3) passive transport. Accumulation or dissipation
due to hydrographical conditions is vitally important in
the vertical distribution of passively floating planktonic
forms. Many of these individuals would be lost from the
euphotic zone, thus removed from the reproducing population
except that they are returned to the lighted zone by
upward moving water. At the thermocline these downward
movements are sufficiently retarded to allow accumulation.
Vertical temperature gradients are more pronounced in
the lower latitudes than at the higher latitudes,
consequently, vertical distribution is influenced more
by temperature in the tropical and temperate regions than
in polar regions.
6. Wind and Water Currents
Wind and water currents are favorable in
view of mixing and keeping materials away from land masses.
The proposed disposal area lies in the westward moving
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GALE D. TAYLOR	90
equatorial currents and the prevailing winds are from the
east. The nearest land mass, the Marshall Islands, is
more than 1200 miles downwind.
There are no reported upwellings in the
area to bring nutrients to the surface nor does the wake
of Johnston Island influence nutrient levels.
C. Biological Features
1.	Biomass and Primary Productivity
Standing biomass in the proposed
disposal area is extremely low. Secchi disk readings for
this area are among the highest recorded in the Pacific
Ocean. The high Secchi disk readings indicate extremely
clear water with a sparse population of plankton.
'Ko measurement of primary productivity is
available from the proposed disposal area but it is
generally regarded as low. The reasons are the low
nutrient levels in the area, low standing biomass, and
relatively low fishing activity.
2.	Benthos Abundance
No data is available for this particular
portion of the ocean; however, studies in the Gulf of
Mexico estimated the total benthic macrofauna biomass,
exclusive of fish, to be 0.2 gm/square meter of florafauna.
Some of the organisms reported present on
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GALE D. TAYLOR	91
the Pacific Ocean floor were starfishes, sea cucumbers,
sea urchins, echinoderms and brittle stars. In deeper
areas sponges, barnacles, sea lillies and sea squirts
were found along with crabs, prawns, isopods and sea
spiders.
3. Commercial Fishing
The proposed disposal site will have
very little impact on commercial fishing. Commercial
fishermen from the Republic of Korea, Taiwan, Japan and
Samoa are the ones who frequent this area most with
Japanese fishing vessels comprising the majority of vessels
in the area. Table 1 shows, the catch of commercial species
\	o	o
of fish in the area 10 00* to 20 00' north latitude and
170° 00' to 180° 00* west longitude as compared to the
catch for the entire Pacific Ocean in 1971 and 1972.
The northern half of this area (15°00' - 20° 00' north
latitude), which includes the disposal area, is reported
to be less productive than the southern half.
I won't read the chart, but it shows only
a tiny, tiny percentage of the fish that are caught in
the Pacific Ocean are caught in this very large area
which includes the disposal site.
In view of the facts about the proposed
disposal site contained in this report — sparse
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GALE D. TAYLOR	92
productivity, low standing biomass, acceptable physical
and chemical characteristics of the receiving waters,
remoteness of the location, favorable wind and water
currents, and relatively little commercial fishing activity,
the proposed site possesses all the characteristics
described in the introduction as criteria for an acceptable
"i
ocean disposal site. It is recognized that the addition
of any foreign material into a small portion of a tropical
ocean ecosystem may have some effect; however, this effect
will be transient, minimal and inconsequential as it
relates to that ecosystem as a whole.
Thank you.
MR. MOLLOY: Are there any questions from
the Panel?
DR. ENOSt I have a question, Mr. Chairman.
MR. MOLLOY: Dr. Enos.
DR. ENOS: What precautions will be taken,
or what method of warning is possible to fishing vessels
of the activities that the incineration vessel will be
taking?
LIEUTENANT COLONEL TAYLOR: The next speaker
I think can give you some better account of that than I
can, although I understand that we can notify the Coast
Guard, who will in turn notify their counterpart in the
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GALE D. TAYLOR	93
other countries. This information will be broadcast to
the fishing fleet, so there shouldn't be any great problem
as far as announcement to these folks will be concerned
that we are in the area, operating in the area.
DR. ENOSs Will that mean that fishing
vessels would be excluded from the entire bum area?
LIEUTENANT COLONEL. TAYLOR: I don't think
I can answer that.
MR. MOLLOY: I have a question.
Is th^ biomass important in the degradation
of the material that gets into the ocean environment?
LIEUTENANT COLONEL TAYLORt Is it important?
I think that the other processes that are involved, the
hydrolysis, the fact that dioxin breaks down very quickly
under UV light, are much more important factors than the
biodegradation of the material. There are certain
hydrocarbons that are very responsive to biodegradation.
The ones that we are talking about, I think probably
that the physical degradation is much more important than
the biodegradation aspect.
MR. MOLLOY: What I am trying to get at is,
is it possible that the fact that this area has a low
biomass would result in some of the material not being
degraded and being carried farther than we would anticipate?
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GALE D. TAYLOR	94
LIEUTENANT COLONEL TAYLOR: Again/ as
Colonel Williams indicated a while ago, I think probably
the total area and its half life would be much less in a
highly polluted area where you have many, many organisms,
but I think that we are still talking about quantity of
material that's so low that really the difference in
time because of the quantity of aquatic organisms would
be inconsequential.
MR. MOLLOY: And finally, have you made
any studies on the possible effects on the environment
in this area to the — which could be, since the ecosystem
is so — since the biomass is so small, could there be
a severe impact on it from a spill of some sort?
LIEUTENANT COLONEL TAYLORa I have
personally not considered that as far as a spill is
concerned in that ecosystem. I don't know what the
results would be.
MR. MOLLOY: Thank you.
MR. BIGLANE: I have just one question for
clarification.
In your introduction you quoted Pequegnat.
LIEUTENANT COLONEL TAYLOR: Yes, sir.
MR. BIGLANE: And the three conditions or
four conditions, rather, that he establishes, and suggests
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GALE D. TAYLOR	95
as being advantageous for the incineration of these types
of wastes.
I would just ask the question, do you agree
with his four conditions here?
LIEUTENANT COLONEL TAYLOR: I think that
they are probably the best criteria that we have.
MR. BIGLANE: Thank you.
MR. MOLLOY3 Are there any other questions?
(There was no response.)
MR. MOLLOY: Thank you.
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96
MRo MOLLOY; The next speaker is Dr. Richard
Barkley, from the National Marine Fisheries Service in
Honolulu.
While Dr. Barkley is walking up, I would like
to say that I think we will try to break for lunch at quarter
\
to one or something like that if that's an appropriate time
when we get there, and probably take about an hour, an hour
and fifteen minutes.
Dr. Barkley.
DR. BARKLEY: Mr. Chairman, ladies and
gentlemen, ray name is Richard Barkley. I am the Chief of
the Fish environment investigations at the National Marine
Fisheries Service laboratosy in Honolulu. I have been with the
laboratory for fifteen years.
My specialty is primarily physical oceanography
I'm interested in classic phenomenon we call
island wakes, which includes the influence which islands have
on ocean currents, and in turn, the effects of the disturbance
that islands have on such things as productivity.
I have a PhD. from the University of Washington,
also a Master of Science Degree in Oceanography from the
University of Washington.' .
I have published a number of papers which are
pertinent. .I think perhaps the most significant in this
(
, -i
context is the °iceanographic Atlas of the Pacific Ocean which
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. ,	97
L	J
RICHARD A. BARKLEY
I published in 1968. it summarized all the oceanographic
data available from the Pacific up to that time.
Closer to home/ there is a paper I published
/
in 1972 entitled, Johnston Atoll's Wake, in which we looked at
the details of the current system around the Johnston Atoll
sea mouth.
My primary function in appearing here is
simply to provide you with a little more information about the
productivity in the vicinity of Johnston Island.
Literature research which I have carried out
has located a few observations of productivity from the area
in the vicinity of the burn site. They include seven
observations in the two adjacent five degree areas, and each
of these averages 0.2 milligrams of carbon produced per square
meter per hour.
To put this in context, this is among.the lowest
values that are typically measured in the ocean anywhere.
Technically, they would fall in the lowest
decile, the lowest ten percent of the range of productivity.
These low values are indirectly confirmed by Secchi disc
readings, which in mid-ocean provide an index of water clarity
and therefore of standing crops of plankton. Secchi disc
readings for the area near Johnston Atoll, some of which I
took myself, are typically about 50 meters, which can be
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98
R. A. Barkley .
compared with the theoretical maximum reading of 62 meters
for very clear or distilled water.
The basic reason for this productivity and
high water clarity is the. lack of. plant nutrients, not only in
the surface waters, but also'in the subsurface waters down to
approximately 300 meters. This subsurface water is an old
surface water which sank at the subtropical convergence,
about 20 to 25 degrees North, then spread toward lower
latitudes beneath the surface layer. It is for this reason
that upwelling and wind mixing do not cause enrichment of the
surface euphotic layer, because the water brought up from
below is as nutrient-poor as the normal surface waters. This
condition is typical for mid-latitude ocean areas all over
the world. The Sargasso Sea in the western North Atlantic
Ocean is the best source for this information.
Thank you.
MR. MOLLOY: I have a question.. It's in the
same area that I asked the previous speaker.
Do you have any idea, perhaps, do you know if
there have been any studies of the potential effect on this
type of ecosystem of a spill of this material, this type of
material?
DR. BARKLEYs The biota in the vicinity are not
in any sense that I am aware of unique. It is simply the
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R. A. Barkley
biota which one finds in the mid-latitude open ocean in the
less productive areas.-
They are probably supplied primarily by
production v.hich occurs in lower latitudes, which in turn is
fed by divergence of the Equator. So if, for example, there
were catastrophic destruction of vital plankton in the few
acres of the immediate vicinity of.the ship, this would be
replaced within a matter of days, I think, by local
productivity and by mixing and invection from laterally, and
presumably primarily from the southeast.
MR. IIOLLOY: Thank you.
Are there any other questions or comments?
Mr. Biglane.
MR. BIGLANE: I would like to ask one.
Appropos of a question asked last week in which
Dr. Pequegnat cites four criteria for consideration of the
generation of these types of waste, and refreshing your
memory, the first one says, the presence of great volumes of
water; second, relatively simple water and air current;
thirdly, low stratification of the water column, and four,
relatively little productivity in the area.
I would ask you, sir, would you agree with thesa
criteria, and if you do, would you have any more to add to
them?
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R. A. BARKLEY
DR. BARKLEY: First of all, I agree totally
with all but the third. I don't think that the lack of — or
the stratification is necessarily either a positive or a
negative factor. The lack of any significant stratification
would cause rapid vertical mixing, which would be favorable
in the sense that it would dilute the effects of any material
put into the water raither rapidly. In this sense it is
favorable. In another sense, it might be considered favorable
to retain the material above the deeper layers of the ocean
because of the upper layers of .the air, which are more exposed
to such process as oxidation, biological degradation and
so on.
• »
So I think that there is reasonable grounds for
argument about.whether a stratified or an unstratified system
would be better, but I don't think this is a highly significant
criterion, and I think the other three are more important and
probably the most fundemental.
MR. BIGLANE: Thank you.
MR. MOLLOY: The next speaker is Major John
J. Gokelman from the United States Air Force Environmental
Health Laboratory, McClellan Air Force Base, California.
MAJOR GOKELMAN: Mr. Chairman, ladies and
gentlemen,
My name is Major John J. Gokelman. I am
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Major Gokelman
currently the Chief of the Environmental Protection Engineerinc
Division at the Environmental Health Lab, McClellan Air Force
Base, California. We are the sister lab to the one at
Kelly Air Force Base.
I have a Master of Science Industrial from the
University of Michigan, specialty in Air Pollution from the
University of Michigan. I am also a candidate for"a Doctor
of Philosophy degree in air pollution from the University of
Michigan.
I am a Registered Professional Engineer in the
State of California, and certified by the American Board of
Industrial Hygiene in Comprehensive Practice.
I have worked in environmental and industrial
health since 1960, and I have worked in air pollution source
sampling since 1972.
I was the Chief of the Air Pollution Sampling
team that did the Air Force's monitoring work on the Marquardt
study in November of 1973.
My paper is, Procedures to Evaluate Stack
Emissions from Shipboard Incineration of Herbicide Orange.
This paper details the sampling and analytical
procedures which the Air Force will use to monitor stack gases
generated during the incineration of Herbicide Orange aboard
the VULCANUS. The procedures are divided into two systems,
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Major Gokelman	102
one to monitor Herbicide Orange components and TCDO and the -
other to monitor incinerator performance and obtain stack
volume flow rate.
The first portion I will discuss is the
herbicide components and TCDD monitoring system.
The sampling system to monitor emissions of
herbicide components and TCDO is a modified version of the one
described in Appendix E of the Final Environmental Impact
Statement, "Disposition of Orange Herbicide by Incineration,"
November 1974. The modification is the insertion of a 50-foot
heated Teflon line between the probe and the impingers. The
shipboard system consists of a quartz glass probe in a water
cooled stainless jacket, a 50-foot heated Teflon line with
temperature monitor, six Greenburg-Smith impingers, a pump
and a dry gas meter. The system¦, except for two one-inch
stainless steel connectors at the ends of the heated line, is
glass and Teflon.
The first three impingers have their impaction
plates replaced with coarse frits. They contain 350 millilete::
benzene each and trap afty; 2,4-D, 2,4,5-T and TCDD present in
tiie air sample. The last three impingers have their impaction
plates and tips removed. Two contain approximately 500 grams
each of 60/80 mesh activated carbon and one contains
approximately 500 grams of silica gel. They remove benzene
and water from the sample gas before it enters the pump and
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Major Gokelman	103
dry gas meter.
Collection efficiency tests for the original
sampling system were conducted with a four benzene impinger
train and a three foot glass probe heated to 180-190 degree
centigrade. They indicate that the fourth impinger was not
needed and that the system's efficiency is 90 per cent for
both 2,4-D and 2t4,5-T. This sampling system was used to
monitor the emissions from the Marquardt test burn. It
performed satisfactorily under field conditions. The previous!
referenced environmental impact statement contains a complete
report on the 2,4-D and 2,4,5-T tests and on the system's
performance during actual field use.
The modified sampling system was also tested
for TCDD collection efficiencies. They were conducted after
publication of the final environmental impact statement. The
percent recoveries were based on a 28 microgram sample to
TCDD. The average.line temperature was 190 degree centigrade.
Samples were analyzed by dual column gas chromatograph with
an election capture detector. The detection level was
0.2 microgram total sample. These data will be confirmed
by gas chromatograph/mass spectrometry at a later date. The
collection efficiency for TCDD ranged between 94 and 110
percent recovery.
The system cannot be operated continuously or
at a flow rate greater than 2 liters per minute due to benzene
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Major Gokelman	104
evaporation. Three one-hour samples will be collected during
each day of incineration. Sampling will begin after the
incinerator has reached equilibrium while incinerating
Herbicide Orange. Based on an absolute detection limit of
1 nanogram and an average TCDD concentration of 2 ppm, the
sampling will detect any TCDD present in the effluent gas up *
to a destruction efficiency of 99.997 percent.
In preparation for sampling, the line, connectoz
and impingers will be rinsed with benzene, the impingers will
be wrapped with foil to protect the contents from UV light,
all components connected, and the system leak tested. The
line will be heated to 190 degree centigrade, the flow rate
established at 2 liters per minute and sampling started.
Upon completion of the one-hour sampling period,
contents of the impingers will be transferred to amber glass
containers. The line and connectors will be rinsed with
benzene and transferred to amber glass containers. Ml sample
containers will be stored aboard ship until the test burn is
completed. At Johnston Island samples will be concentrated
and immediately transported by air to the Evironmental "Health.^
Lab, Kelly Air Force Base, for analyses by gas chromatography/
i
mass spectrometry.
. The second portion of the paper will discuss
the incinerator efficiency and stack volume flow rate
monitoring using the appropriate formulae.
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Major Gokelman	105
Dug to the high temperature and corrosive
nature of the exhaust gas and the steep angle of the sampling
port, it is not possible to measure the stack volume flow rate
using a pitot tube. It will be determined by measuring the
oxygen content of the stack gas. Using this value and the
theoretical stoichiometric stack flow rate for "Orange"
incineration, the actual stack flow rate will be determined
using the following formulae.
The sampling system for this portion of the
stack monitoring consists of a quartz liner inside a stainless
steel water-cooled probe, a 50-foot heated Teflon line, with
temperature monitor, a scrubber system to remove chlorine and
water from the gas and two continuous monitoring instruments,
a Beckman Model 865 Carbon monoxide analyzer, a Beckman 715
oxygen analyzer, and a recorder.
The carbon monoxide instrument will be used to
determine the efficiency of incineration. The continuous
monitoring equipment will be on line whenever the herbicide
monitoring system is not in use.
Appended to the paper are several attachments
showing the analytical procedures and also the test results
and some of our calculations.
That's all I have, sir.
MR. MOLLOY: 'Thank you.
Are there any questions by the Panel?
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Major Gokelman
Dr. Enos.
DR. ENOS: Yes.
Major, in the previous experience on board the
Vulcanus we had some difficulty with equipment not operating
at inopportune moments. Do you have any contingency plans
for backup equipment in case this should happen while you are
on the burn sites?
MR. GOKELMAN: Yes. We plan on bringing on two
heated lines. We have water-cooled probes. We have two
oxygen monitors. We have two CO monitors, and we will have a
supply of benzene and glass impingers in the event, and we
anticipate some breakage of the glass itself.
We will also have two pumps and two dry gas
meters, so if any of these units at all break down we can
replace them with the second unit.
DR. ENOS: And in the body of the text, when
you discussed the efficiency for determining the ability to
capture the TCDD from the stack effluents all the way to the
impinger system, did you have an opportunity to evaluate the
ability to concentrate benzene solutions containing TCDD to
determine whether or not there is an efficient process?
I didn't catch that.
MAJOR GOKELMAN:. Our chemist did analyze the
procedure. It's in the paper itself. It is actually contains
in Attachment 1, and it's a codistillation study the people
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Captain TerMaath
did, and we found that essentially the recovery ranged from
101.6 to 100.2 percent recovery after the evaporation.
"r '	'	. 1.
Yes, we can recover the TCDD after it is
evaporated.
DR. ENOS: Thank you, Major.
'	'	r
MR. MOLLOYs Are there any other questions?
(There was no response.)
tMR. MOLLOY: Thank you.
The next speaker is Captain Stephen TerMaath of
the Air Force Environmental Health Laboratory, Kelly Air
Force Base, Texas.
CAPTAIN TERMAATHr I am Captain Stephen G.
TerMaath. My current position is as consulting bioenviron-
mental engineer and sanitary engineer, United States Air
Force Environmental Health Laboratory at Kelly Air Force Base
in San Antonio, Texas.
I have a Master of Science Degree in
Environmental Health Engineering from the University of Texas
at Austin.
I am a member of the Texas and National Societi
of Professional Engineers, and the Water Pollution Control
Federation.
I was involved in conception and data analysis
of the drum-rinsing experiments, at the Marquardt Company in
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Captain TerMaath
September '74 experiments at Gulfport, Mississippi, which were
discussed in the Air Force's Final Environmental Statement.
In addition, I was officer in charge of the
drum-rinsing experiments conducted at the Naval Construction
Battalion Center in Gulfport, Mississippi from 7 to 12 April
of this year. The majority of the information which I will
present this morning was collected during this last study.
The paper 'I am presenting this morning is
entitled, Rinsing Procedures for Orange Herbicide Drums.
By way of introduction, the Federal Register
Vol.. 40, No'56, Monday 24r Mar 72 contains a "Receipt of
Application and Tentative Determination" as regards the Air
Force Application for an Ocean Dumping Permit of 9 Jan 75.
The "Tentative Determination" includes the following condition:
"(4) The drums from which the Herbicide Orange
\
is taken will be triple rinsed with solvent prior to disposal,
or otherwise cleaned to an equal degree by jet rinsing, and th<-
rinses will be added to the waste to be incinerated."
This is an extremely stringent condition and
could be appropriate if the drums were to be reused. A
triple rinse of a drained drum with clean solvent for each
rinse . will obviously result in a very clean drum. Reuse
of drums a3 containers for any type of material or for any
other conceivable use has never been considered by the Air
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Captain TerMaath
Force. Rather than a simple triple rinse requirement with no
plans |
maximum permissible residual and in view of the Air Force/for |
ultimate disposal, it would seem a much more realistic
condition would be one that allows a certain minimum of Orange !
residual regardless of the method used to achieve it. An
allowable herbicide residual would be specific to the Orange
disposal project and not simply a condition wich could be
applied universally.
As has been shown in the Final
Environmental/Statement, the amount of solvent per rinse and
the number of rinses has a tremendous bearing on the duration
and complexity of the disposal project - which translates to
increased cost to the taxpayer. Therefore, all efforts should
be directed toward attaining an environmentally acceptable
drum cleaning operation which applies specifically to the
Orange disposal project.
The drums generated by the disposal of Orange
herbicide will be recycled as "scrap" metal for the steel
manufacturing industry. Disposal as scrap rather than disposal
of unrinsed drums in a specially designated landfill is
considered more favorable from the long term environmental
standpoint because the Orange and its components would be
rapidly destroyed in the steel making process. As the scrap
drum metal is processed into new steel, it would be subjected
to high temperatures (Approximately 2900 degrees Fahrenheit)
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Captain TerMaath
for an extended period of time (Approximately 6 hours).which
was discussed in Part 2 E of the Final Environmental Statement,
and the other in April, 1975. This exposure is much more
severe than that which would be received if non-combustible
drums were aubjected to incineration in a pesticide incinerator
(2000 degrees Fahrenheit, 2 sec) as defined by EPA in 40 CFR
165.1. Recycling into steel conserves not only the drum metal
but also raw materials for steel manufacture. =The utilization
of one ton of scrap steel in the steel making process conserves
about 4 tons of iron ore, coal, and limestone. Therefore,
the recycling of 45,000 - 50 pound drums as scrap will
conserve approximately 4,500 tons of raw material. This
method of ultimate disposal will also preclude the return of
any Orange herbicide-drums to manufacturers, formulators, or
drum reconditioners for reuse.
The Air Force has never intended that the Orang^
herbicide drums be reconditioned for reuse. The negative
public relations aspect of reuse, the solvent requirements to
affect a triple rinse as recommended by the EPA prior to the
reuse of containers (40 CFR 165), and the concomitant
complication and expansion of the disposal project associated
with such rinsing operations are not desirable. The solvent
volume of 67,000 gallons necessary for a triple rinsing
represents greater than one-fourth the volume of the total
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Captain TerMaath
Orange herbicide stock. The incineration phase of the project
would be greatly expanded since the solvent rinse would
require incineration along with the herbicide. The frequency
of handling and the tremendous quantity of solvent involved
would increase the possibilities of a fire hazard and
spillage of the Orange-contaminated solvent. In addition, the
use of a large quantity of a petroleum solvent during a period
of emergy conservation and fuel shortages is not a prudent
action if it can be avoided without risk to the environment.
Early in the evaluation of various disposal
methods, the Air Force recognized the need for an
environmentally acceptable method of drum disposal and
considered the alternatives of disposal in a specially
designated landfill, reuse of drums, subjecting drums to
incineration in a pesticide incinerator, and recycle as scrap
steel. The last methods was selected as the best procedure
as regards the Orange herbicide disposal project. Realizing
that the drums to be recycled into steel manufacture require
storage and transportation, the drums should be rinsed to
remove as much of the residual herbicide as is environmentally,
economically and operationally feasible. The EPA recommended
requirement in 40 CFR 165 does -not clearly define the
procedures to be followed to effect a triple rinse. The
effectiveness of any rinse is dependent on many factors such
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Captain TerMaath
as 1) how well the container is drained prior to a rinse,
2) the method of application or agitation of the rinsing
material, 3) how long or how well the container is drained
between rinses, 4) the acceptable residual of pesticide which
is permitted to remain in the container after a triple rinse,
and 5) the ratio of surface area to volume of rinse material
because a wide range of container sizes may be encountered.
To explore an adequate drum rinsing procedure, three studies
of the efficacy of rinsing herbicide drums were cionducted
under Air Force auspices. One study was performed at the
Marquardt Company, Van Nuy$ California in December 1973 with
the support of United States Air Force Environmental Health
Laboratory (Kelly Air Force Base., Texas) personnel and the
results were included in Appendix E of the Air Force's
Final Environmental Statement. Two studies were conducted by
United States Air Force Environmental Health Laboratory
(Kelly) personnel at the Naval Construction Battalion Center,
Gulfport Mississippi — one in September 197 , which was
discussed in the Final Environmental Statement, and the other
in April 1975. The conclusions of these studies as they
relate to the methods of drum cleaning and disposal are set
out in the paper which 1 am submitting for the record.
This paper submitted for the record will go
in to slightly more detail and present some of our data
C. RAY BEEBE &
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ASSOCIATES
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Captain TerMaath
collected during the three experiments.
In summary, the drum rinse experiments have
shown that only about 30 grams (0.07 lbs) will remain in a
drum after a single two gallon pressure spray rinse. This is
less than the 68 grams (0.15 lbs) predicted by the Air Force's
Final Environmental Statement of December 1974. A residual
of 30 grams is deemed environmentally acceptable in view of
the subsequent destruction of the crushed drums and the
residual herbicide in a steel making furnace. The residual is
not considered a personnel safety hazard nor a potential
environmental insult during the shipment and storage. This
disposal procedure is specific for the Orange disposal
project and represents, in our judgment, an entirely prudent
course of action.
I will now briefly outline the rinsing
procedures which we do intend to follow in our two de-drum
facilities. There are about 16,000 drums which will be
de-drummed and rinsed at the Naval Construction Battalion
Center in Gulfport, Mississippi.
The de-drum/drum rinse sequence is conducted on
a roller conveyor. There are four identical conveyor lines
which are expected to handle a total.of 1,000 drums per day.
The first step.is the deheading operation, after which the
removed drum head is placed in a vat of diesel fuel to clean
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Captain TerMaath
off any remaining herbicide. Next, most of the Orange herbicic
is pumped from the deheaded drum. The few gallons remaining
are drained by inverting the drum. The drum is allowed to
drain into a collection trough under the conveyor for at
least five minutes. The. drum is then pushed along the
conveyor to a point over the spray nozzle for a 2 gallon spray-
rinse of diesel fuel. After draining for two minutes, the
rinsed drum is crushed.
On Johnston Island, where we have approximately
25,000 drums the following procedure will be used.
The full drums will be placed on either of two
separate racks which hold the drums at a 45 degree angle. A
notch will be placed at the lowest point of the lower head
and a vent hole punched at the highest point in the upper
head. The orange herbicide will be allowed to drain for at
least five minutes. Either an additional notch will be placed
in the upper portion of the previously notched head or the
bung will be removed if it is also located on the upper
portion of the head. The spray nozzle will be placed into the
drum through the upper notch or bunghole, and a two gallon
spray rinse administered. After a two minute drain, the
drum will be placed in temporary storage before crushing.
Thank you.
MR, MOLLOY: I have a few questions.
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Captain TerMaath
One is, what would you propose to do with the
contaminated spray rinse material?
CAPTAIN TERMAATH: It will go along with the
Or'ange herbicide and go aboard the ship for incineration.
I believe that was pointed out in the Pinal Environmental
Statemeht or paper.
MR. MOLLOY:. Secondly, have you made arrange-
ments or contacted any steel companies to take these drums?
CAPTAIN TERMAATH: There have been no formal
procedures outlined or contracts as regards the disposal of
the steel. One company was contacted, and they liad no
hesitation in accepting the material. It was done on an
informal basis, our contact with them.
MR. MOLLOY: Have you made arrangements for
transport, or considered the arrangements for transport of the
crushed drums from Johnston Island?
CAPTAIN TERMAATH: There have been no formal
arrangements as yet. There would obviously be sea shipment to
— designated by the disposal group, and that has not been
formally established as yet.
We cannot make any formal contracts or make
any formal bids, obviously, until we have a permit in hand.
MR. MOLLOY: I recognize that.
Have you made some informal contacts with
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Captain TerMaath
transportation companies or the Military Sea Transport Agency?
CAPTAIN TERMAATH: Possibly Mr. Merrill may
want to comment on that. I believe there have been.
MR. MOLLOY: Sir, could you identify yourself
and take a microphone?
* MR. KARL MERRILL:. I am Karl Merrill, Air Force,
¦ j	.
Assistant Deputy Chief of Staff, Distribution.
Air Force contacts have been made with the
Military Sea Transport Agency.as to Logistics of
transporting the drums. They see no particular problems in
that regard.
Informal contacts have also been made with the
Defense Disposal Agency here in Honolulu and other places,
and they see no particular problem with regard to the sale of
the drums as scrap steel.
So though we have not made formal contacts,
all informal contacts are positive.
MR. MOLLOY: Are there any other questions.
from the Panel?
DR. ENOS: Yes.
Have you calculated the amount of dioxin which
theoretically could still be retained in the drums, the total
amount?
CAPTAIN TERMAATH: In that 30 grams per drum,
C. RAY BEEBE 6t ASSOCIATES
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Captain TerMaath
for example?
DR. ENOS: Yes. If we assume a total . ....
destribution of two parts per million.
CAPTAIN TERMAATH: Right. I don't have that
calculation with me right now, but we'll run that out quickly.
I will run those out and submit them. We will
calculate it and submit that to you shortly.
DR. ENOS: All right.
Let's just consider the 30 grams that I think
you indicated would be retained'per drum, and we have got
something on the order of what, 44,000 drums on Johnston
Island now?
CAPTAIN TERMAATH: We have about 25,000 drums
on Johnston Island.
DR. ENOS: Twenty-five thousand?
CAPTAIN TERMAATH: We look at about 30 thousand
if you include drums that have gone bad during the storage
period and have had to be redrummed, so we have about 30 to
32,000 drums on the Island.
DR. DNOS: The 30 grams, then, of material
retained in the drums will then be subjected to some destructi<
in the process of reclaiming it?
CAPTAIN TERMAATH: It will be specified in the
contra.ct when the scrap steel is sold that it will used for
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Captain TerMaath
making new steel, so that it would required before these drums
could go anywhere they are going to have to go into a steel-
making furnace where they would be subjected, as I pointed out,
to about 2900 degrees Fahrenheit for about six hours in that.
In other words, the identity of the drum would be completely
lost.
DR. ENOS: Thank you.
DR. MACKENZIE* First of all, I would like to
give . notice that in the audience today is Mr. Harry Trask
from our Agency office for Solid Wastes Management, and I am
really serving him on a very short warning. I recognize that
I would like him to respond to a specific aspect of the
Captain's paper, and that would be the one that would refer
to the code of Federal Regulations that we have promulgated
with regard to disposal of pesticide containers.
But before I come to that I have a specific
question myself, and that is, in terms of the handling of
these drums, that.we have operations and the actions that
follow on thereafter, what provisions are made for the
protection of the,people thai will actually be carrying out
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this process in terms of protective equipment?
CAPTAIN TERMAATH: In handling the Orange, the
main type of protective equipment which we are planning on
using will be one that will protect from skin contact primarilj
C. RAY BEEBE & ASSOCIATES
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Major Gokelman
The studies thus far with the Orange herbicide have shown that
the vapor pressure is such that you cannot even reach the
threshhold limit value on the 2,4,5-T, and to be more specific,
I maybe had better ask Captain Jackson or Major Gokelman to
comment on the Orange and the protective equipment specifically
But the protective equipment is not foreseen as needed a lot,
and they can comment specifically on the industrial hygiene
aspects of the Orange.
MAJOR GOKELMAN: On industrial hygiene for
personal protection —
MR. MOLLOYj Could you identify yourself?
MAJOR GOKELMAN: I am Major Gokelman. 1 am
also from the.McCleilan Air Force Base Environmental Health
Lab. We have been given the job of providing both the
industrial hygiene coverage of all the personnel working with
the Orange Herbicide product during the de-drumming operation,
and we have provided them — we will provide them with masks,
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gloves, aprons, and if 7. am not mistaken, also boots —
coverlets or boots that will be impervious to Orange Herbicide.
So if that answers your question, they are
being provided for the people who will be dealing with the
herbicide itself.
We are also providing for some personnel
monitoring of these people while they are handling it.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Major Gokelman
, DR. MACKENZIE: Thank you very much.
Would it be appropriate at this time to ask
Mr* Trask if he would like to make some comment?
MR. MOLLOY: We have some questions from the
floor, so before we get to Mr. Trask, if I can get these
questions out.
Whoever asked the question# do you feel that
the questions have been answered? '
(There was no response.)
MR. MOLLOY: I will read the questions, then.
"What kind of protection is provided in the
drum draining at Gulfport?"
CAPTAIN TERMAATH? As Major Gokelman pointed
out, there will be coveralls, butyl rubber aprons, rubber
boots and face shields, and masks will be available if they
so desire. The masks are not necessary, but there is. an
odor involved with Orange that is objectionable to many
people, and that will be there for their optional use.
In addition, there will be industrial hygiene
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monitoring maintained on a daily basis, and we will be doing
analyses on the spot, utilizing the laboratory in Gulfport,
Mississippi, so personal protection we feel is well covered.
MR. MOLLOY: And the second question is,
"What is the possibility of Herbicide Orange contamination in
C. RAY BEEBE 6c ASSOCIATES
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Captain TerMaath
the immediate area?"
I take it that means from a spill from the
de-drum operations.
CAPTAIN TERMAATH: Since we will be handling
them in the drums and inside a concrete facility, no major
spill at the de-drum facility is anticipated. However, there,
as pointed out in Dr. Welch's opening remarks, we do have
absorbent material that will be on hand and available, and
contingency plans to take care of that. We feel we have it
covered.
MR. MOLLOY: Do you have plans to rinse down
the area also when you have completed?
CAPTAIN TERMAATHJ At the completion of the
project the facility will be rinsed with diesel fuel, and
any containers which have been used, such as tank cars for
transporting it, will also be rinsed with diesel fuel, and
this diesel fuel will be aboard along with the Orange for
shipboard incineration.
MR. MOLLOY: The final question that I have
here is, "What is the possible level in comparison with the
one tenth of one percent residue from the burn?"
I take it that means in the case of a spill ..
from the de-drumming operation, how would that relate to the
burn efficiency? Would it result in severe contamination?
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Captain TerMaath
If you did get a spill in ttie area, would it result in severe
contamination?
CAPTAIlJ TERMAATH: . No, not in the area of the
de-drumming on the naval facility, no. Obviously, it is
going to be transported in tank cars to the ship, and we have
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sufficient absorbent material and plans to move in if we
should have any type of spill.
MR. MOLLOY: Does that answer the questions,
whoever asked them?
FROM THE FLOOR: Yes. I asked the questions.
MR. ROGERS: Mr. Chairman, I have a couple of
questions.
MR. MOLLOY: Mr. Rogers.
MR. ROGERS: What would be the total liquid
quantity the Air Force will' be shipping from Gulfport,
including the rinse, including the Herbicide Orange and the
rinse?
CAPTAIN TERMAATH: 860,000 gallons.
MR. ROGERS: How does that relate to the
ship's capacity?
CAPTAIN TERMAATH: 860,000 gallons.
MR. ROGERS: So the ship will be up to —
CAPTAIN TERMAATH: We will be shipping a full
load from Gulfport.
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HONOLULU. HAWAII

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Captain TerMaath
MR. ROGERSt What happens if you have to use
more rinse?
CAPTAIN TERMAATH: More than our two-gallon
rinse capacity?
MR. ROGERS: r Right.
CAPTAIN TERMAATH: Well, we are obviously
going to have to re-evaluate the situation, and either
consider shipping Herbicide Orange having more than one load.
In other words, iLf there is a large amount of rinse water
required, I think that you are talking about — okay. If you
talk about a triple rinse you are talking about roughly 16.5
gallons under the EPA procedures, 16.5 gallons per drum, and
I think you are talking about an additional 30 percent.
MR. ROGERS: So you are saying you couldn't
triple rinse and put the rinse in with the herbicide and get
it all out of Gulfport?
CAPTAIN TERMAATH: Correct.
MR. ROGERS: But you think you could get it
all out if you used your procedure?
CAPTAIN TERMAATH: All but the possibility of
a very few drums, which we could ship.
MR. ROGERS: What have you been doing with the
drums in the occasions you had to redrum up to now?
CAPTAIN TERMAATH: They have been sitting in
C. RAY BEEBE & ASSOCIATES
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Captain TerMaath
storage at Johnston Island. They have been in storage.
MR. ROGERS: What about the ones at Gulfport?
Have they been re-drummed?
CAPTAIN TERMAATH: Wo, there has been no
re-drumming effort at Gulfport. Johnston Island being as it
is .wiUi the spray all the time, has a very corrosive atmosphere
there.	' "
MR. ROGERS: Thank you.
MR. MOLLOY: Are there any further questions?
DR., ENOS: Yes, I have.
What is the total number of drums that you have
at both locations?
CAPTAIN TERMAATHs About 45,000.
DR. ENOS: Forty-five thousand drums. Okay.
Thank you.
MR. ROGERS s I do have one other question I
forgot to ask. This relate8to the possibility of reprocessing.
If you do reprocess, decide to reprocess the herbicide, I
assume you have to take the chemical out of the drums at some
point, is that correct?
CAPTAIN TERMAATH: At some point. Since I am
not familiar with the proposals made by the reformulator
people, I presume that some of them may have said they would
accept it in drums. Others may have said that they would
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Mr. Trask
like bulk shipment, and I think if we go to reformulation we
would have to develop something with regard to that. .
MR. ROGERS: Maybe we should hold that question
until we get into that area later.
MR. MOLLOY: Now, Mr. Trask, if you can
comment on the Federal Code Regulations, and after Mr. Trask
we will break for lunch.
Thank you, Captain.
MR. HARRY TRASK: I am Harry- Trask. I am the
representative of the Office of Solid Waste Management Program!
of EPA in Washington. Our office did develop and publish
40 CFR 165, which relates to the storage and disposal of
pesticides and pesticide containers.
Section 165.9, I believe, of that publication
refers to methods of handling the containers, and it requires
the triple rinse procedure which Captain TerMaath just
described to you.
At other points in that particular code there
are exceptions or possibilities for exceptions, and we have
taken the position that a triple rinse or equivalent should be
the proper wording for that particular regulation.
That is called officially a recommended
procedure. Eowever, it has been determined that it is a
guideline, and therefore binding on all Federal Agencies.
C. RAY BEEBE & ASSOCIATES
'HONOLULU, HAWAII

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126
Mr. Trask
I do have a question for Captain TerMaath, or
perhaps for Carlton Williams, I'm not sure.
The Environmental Impact Statement in both the
draft and the final contains some data which showed that
approximately 1 to 1.2 pounds of Herbicide Orange would be
volatilized from each drum as it sat in storage on Johnston
Island.
My question is, what happens to the 30 grams
or the one ounce as it sits in storage on Johnston Island?
I assume that you would not be moving it immediately after
the drum has been rinsed.
I also am concerned as to the de-drumming
operation itself. If there is volatilization, are there any
provisions being made to contain these vapors? Otherwise, it
seems fairly clear to me that they are going to be released
into the atmosphere down there.
Perhaps you would want to comment on that after
lunch if you want to break for lunch, Mr. Molloy.
MR. MOLLOY: Is that all right with you, that
you comment on that after lunch?
DR. WELCH: Yes.. I would like to summarize
just briefly before you break, however.
MR. MOLLOY: . All right. Yes, Dr. Welch.
DR. WELCH: Mr. Chairman, my overview comments
C. RAY BEEBE & ASSOCIATES
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Dr. Welch
which attested to the safety of incinerating Herbicide Orange
at sea, have been further substantiated by the technical
comments just presented.
I might say, if this material was not called
Herbicide Orange or Agent Orange, as so many term it, it would
have either been used or destroyed by this time. Herbicide
Orange carries with it an emotional connotation of something
bad or sinister. There are groups who do not want the
material used at all — who would prefer that it be destroyed -
and the sooner the better. Nothing is assured concerning
Herbicide Orange, except perhaps controversy.
In this connection I want to comment briefly
on the resolution on the TTPI Environmental Board, and call to
their attention that Herbicide Orange is not, and I repeat
not, a poison gas. It is a herbicide, specifically intended
for controlling certain types of plant life. Products much
like it are legal for use in the United States, including the
Trust Territory. Where used, obviously, the exposure to
humans is far greater than the exposure from burning it
1,200.miles away. In our opinion, there is absolutely no
reason to believe that the products of combustion will even
be detectable in the Marshall Islands, that there will be any
threat to public health or that any Marshall Islanders would
ever become sick from any potential exposure to the products
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Dr. Welch
arising from combustion of Herbicide Orange on board the
Vulcanus.
I believe we have laid out for consideration a
very credible argument which should be sufficient to warrant
the issuance of a research permit.
We do have a problem in storage of this
material. It does cost money to maintain it. .The material'
that is stored on Johnston Island is stored as it was
received, in 55-gallon drums, but it is open storage.
Johnston Island is roughly 600 to 650 acres in total area,
with an average height of less than eight feet above sea level>
So it is a fairly corrosive environment, and we have a major
effort to maintain the integrity of the drums. During the past
year (April to April) we spent about $140,000 to remove the
herbicide from leaking and unsound drums and place it in
sound containers. As the storage time increases, the integrity
of the drums will continue to degrade. Salt spray and the
age of the drums continue to be a problem.
In order to preclude continued redrumming,
continued utilization of money for the redrumming efforts,
it is our desire and our charter, we think,: to dispose of the
problem in one way or the other: either by reprocessing into
products that, can be used or by destroying the material in
terms of incineration, either on the high seas or on Johnston
C. RAY BEEBE & ASSOCIATES
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Dr. Welch
Island. Our position has been laid out in the Environmental
Impact Statement. It is there for anyone to study, and we
think that the solutions are fairly self-evident. We see
the need to reach a conclusion on the option of reprocessing.
At the time the ocean incineration technique
came to our attention, reprocessing alternatives seemed
technically and legally infeasible. We have always recognized
that alternatives that returned the material to legal and
productive use, hopefully with a net return to the DOD, were
preferable if the problems could be overcome• In recent weeks,
there has been some progress in this area. Technical
proposals received by the Defense Supply Agency, surplus
property sales agent for the DOD, appear on paper to be
potentially feasible, based on largely experimental data.
The proposers have been requested to demonstrate their
techniques on a pilot plant scale on an expedited basis.
There are many questions - technical, legal,
economic and political - to be explored,with respect to
reprocessing. At the moment, we cannot say whether all or
any of the material can be reprocessed. We recognize that,
under the tentative decision, we. have the burden of demonstra-
ting to you that there are no technically feasible and
environmentally sound land-based alternatives to ocean
incineration. To allow sufficient time for this information
C. RAY BEEBE & ASSOCIATES
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Dr. Welch
to become available, we are asking that the hearings be
adjourned temporarily after the San Francisco session, to be
convened in Washington, D. C., within ten days of a request
by us. We will make this request as soon as there is
sufficient data to demonstrate the feasibility, or lack of it,
of reprocessing some or all of the herbicide. We do not expec
this to. be too long a period, hopefully no more than ninety
days. Let me underline that the Air Force is most anxious to
proceed with disposal of this material in an environmentally
acceptable manner at the earliest possible date. We understant
that the 180-day decision period will be suspended until the
hearing is reconvened;
Once again, we thank you for your indulgence
in having the opportunity to present to you the studies that
we have carried out, and as the day goes on we will be pleased
to try to answer any questions that might arise.
Thank you.
MR. MOLLOY: Thank you, Dr. Welch. There will
be some questions after lunch, so if we can break for lunch
now, it's one o'clock, and come back sometime before 2:15.
(The hearing was thereupon recessed, for
luncheon, from It00 p;m. to 2:15 p.m.)
oOo
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131
(The' hearing was reconvened at 2:17 p.m.)
MR. MOLLOY: We can reconvene the session now,
please. It is now 2:15.
•Before the break for. lunch Dr. Welch finished his
statement, and there had been some questions posed by Mr. Trask
to the Air Force.
Mr. Trask, could you repeat the questions, perhaps,
and then maybe they can respond to them.
MR. TRASK: The questions were, what would be the
fate of the 30 grams of material which would be left in each
drum according to, the instant data that you have presented?
The .earlier Environmental .Impact Statement
indicated that substantial volatilization would occur if the
drums are left in the open with material in them, and I am
wondering what if any material would volatilize from the
rinsed drums, and what' provisions are being made to contain
that? " - >'	•	' .
MR. MOLLOY': , Dr. Welch, could you answer that, or
have someone from the Air Force answer?
DR. WELCH: Well, let me 3tart it and see how we
make out.
As to the fate of the 30 grams left in the
drums, the drums would initially be crushed, and involved in
crushing would at some subsequent time, as yet undefined,
be moved to a smelter and recovered as scrap metal.
C. RAY BEEBE & ASSOCIATES
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Dr. Welch	.132
In the process of that recovery, fairly high
temperatures — the numbers escape me at the present time
but 2,900 degrees Fahrenheit, I am told, and some six hours of
exposure in the smelter would be utilized to smelt the drum
down for reuse.
Now, as to the amount of the 30 grams that
would be left in the drums, how much of that would be
volatilized, quite frankly I don't have the foggiest idea
right now.
MR. TRASK: The earlier data indicated about
90 per cent would volatize, and I am wondering if that's a
fair assumption to make now?
DR. WELCH: I don't think that, you know, one
could really comment upon that, because if the drums are
crushed, the surface area that's available for volatilization
would be considerably less, and the earlier data was on
uncrushed drums. And the amount of material that we are
talking about is something less than a total of about 2,000
V
pounds in the Johnston Island area, and substantially less
than that at Gulfport. -
MR. MOLLOY: Is that all the questions you have?
MR. TRASK: Yes.
MR. MOLLOY: Are there any other questions for
the Air Force from the Panel?
(No response.)
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Dr. Welch	133
MR. WASTLER: Mr. Molloy, I have a couple of
questions from the floor.
MR. MOLLOY: Sure. Why don't you speak them.
MR. WASTLER: What safety precautions will be
provided for personnel transporting the crushed drums and
personnel at steel plants?
OR. WELCH: The safety precautions that would be
provided would be those consistent with the type operation
involved. In other words, if it's an American firm that's
involved, they would be required, according to the contract,
to comply with the applicable occupational safety and health
standards.
Beyond that, one really doesn't see a
requirement for strong safety measures beyond what would be
required to the industry involved.
MR. WASTLER: Does the two-gallon rinse per drum
plus* the 860,000 gallons just happen to equal the total
capacity of the VULCANUS, or was the two-gallon amount for
rinse back-calculated from the ship's total capacity?
DR. WELCH: 1 am told that that's coincidental.
MR. WASTLER: Those are the only questions.
MR. MOLLOY: Thank you.
I am now going to call on Dr. Jake MacKenzie
to present a statement of EPA policy, and the. summarization
of that policy concerning the disposition of pesticide and
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Mr. MacKenzie	134
herbicide waste.
Or. MacKenzie is not the author of the
document, but he has kindly consented to read it and
summarize it for the members o£ the Panel and to the public
today.
Dr. MacKenzie.
DR. MACKENZIE: Thank you, Mr. Chairman.
I would like to submit this statement into
the record of this hearing.
I am today representing both Paul Duval1,
Regional Administrator of Region 9, EPA, and Deputy Assistant
Administrator Edwin Johnson of the Office of Pesticide
Programs in Washington, DC.
The Environmental Protection Agency disposal
policy for pesticides has been laid out in regulations
promulgated under Section 19 of the Federal Insecticide,
Fungicide and Rodenticide Act as amended.
This policy states, in brief, in considering
disposal techniques the first preference should be given to
procedures to recover some useful value from excess pesticides
in containers. In light of current shortages of critical
agricultural chemicals, including 2,4-D component of
Herbicide Orange, and consistent with the need to conserve
and reuse our natural resources this policy has been followed
S	:
in respect to disposal of Herbicide Orange.
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Mr. MacKenzie	135
To date the following milestones should be
noted.
The first series concern the consideration
of the option of reformulation, and that would be reformulation
of the existing Herbicide Orange with the present levels of
dioxin contamination.
First of all, manufacturers were not willing
to take the Herbicide Orange back.
Secondly, the Air Force would not dispose
of Herbicide Orange by sale to reformulators because allowable
i
levels of dioxin only permitted disposal of 30 per cent of
the total stocks.
I should mention here that this allowable
level represents 0.1 parts per million of the dioxin
contaminant.
Secondly, reformulation of the remaining
70 per cent of the stock containing the higher levels of the
dioxin would present unacceptable hazard to public health.
Therefore, reformulation was not considered to be a feasible
option.
Reprocessing represents the next alternative.
The Office of Pesticides Programs was at the time of the
decision to consider reprocessing in possession of general
information which indicated that the potential for
reprocessing did exist, which might destroy dioxin in the
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Mr. Mackenzie	13G
process or concentrate it into readily disposable waste
material*
Once reprocessing came under consideration,
the Air Force, through DSA, placed an offer for bids to
chemical.processors for purchase and conversion of existing
stocks of Herbicide Orange.,
Now, with regard to what has happened since
that time, actually three process descriptions in support of
i
bids to reprocess have been submitted. They have been
evaluated this month by the Evironmental Protection Agency
and Army Evironmental Hyigene Agency technical experts.
One particular process, or one process
appears particularly promising. One company proposes to
destroy via a selective chemical technique the dioxin present
as a manufacturing impurity in Herbicide Orange. The company
plans firstly to hydrolize the end butyl esters of 2,4-D and
2,4,5-T with caustic to cause the production of 2,4-D and
2,4,5-T salts and end butynol.
Separation of the acids from end butynol
will be accomplished by physical methods involving solvent
extraction, distillation.
The 2,4-D and 2,4,5-T acids produced will
contain less than 50 percent per billion dioxin, far superior
in quality to presently available similar registered Herbicide
formulations t
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. MacKenzie	137
Spent organic solvents containing less them
fifty parts per billion dioxin will be incinerated in an
approved incinerator.
Aqueous waste streams containing less than
225 parts per trillion dioxin will be trickled through
coconut charcoal before treated effluent containing no
detectable dioxin (Less than ten parts per trillion) will be
pumped to an existing brine disposal well.
Spent charcoal slurry will be combined with
the spent organic solvent and incinerated.
In the opinion of the above-mentioned experts,
the processors reviewed today appear promising, firstly, in
aspects of the 2,4-D and 2,4,5-T recovery, and secondly, in
terms of satisfactory destruction of the dioxin contaminant.
However, there were sufficient questions
related to dioxin disposal and to in-process destruction asped
which warrant a mandate for pilot studies, and a pilot study
would be considered to involve up to 150 gallons of the
actual Herbicide Orange I presume via processing.
What would this mandate include? It would
include an attempt to confirm process claims, to study the
effect of scale up on process efficiencies, to closely
evaluate dioxin destruction and disposal, and to obtain an
accurate estimate of possible dioxin environmental
contamination.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. MacKenzie	138
Now, with regards to the timing of this,
which is of interest, it is assumed that six months would be
ample to allow collection and evaluation of such data. All
reprocessors have indicated that upon acceptance of a bid
reprocessing could commence immediately.
What other considerations have to be reviewed!
Assurance of quality control over the
dioxin content of the reprocessed commercial products;
Probable level of dioxin refuse in waste
generated by the reprocessing;
Consideration of safe handling, transportatioi
storage and drum disposal associated with the transfer and
processing of the Herbicide Orange.
Finally, assurance of proper registration of
end use products.
In summary, recovery of useful value from
pesticides in a disposal situation must be determined to be
unfeasible before non-productive (Destructive) means can be
considered. In the case of Herbicide Orange reprocessing to
recover useful herbicidal value from the 2,4-0 and 2,4,5-T
components with concurrent destruction of the teratogenic
dioxin contamination component appear promising. Pilot plant
studies to accurately evaluate the chemical processes
involved in reprocessing are required at this time. They
probably can be completed in six months. EPA believes the
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. MacKenzie	139
reprocessing aspect is worthy of additional serious
consideration and if feasible it may well be preferred to
ultimate disposal. It might well, in light of current
estimates, return 2,4-D and 2,4,5-T to commercial channels
with lower dioxin content than that currently manufactured.
That ends the summary policy statement,
Mr. chairman.
MR. MOLLOY: Thank you, Dr. MacKenzie.
Are there any questions?
(No response.)
(Following is the text of the report dated
April 22, 1975, from Deputy Assistant Administrator, Office
of Pesticide Programs.)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUBJECT: Office of Pesticide Programs
Statement: Herbicide Orange Disposal
Option, Reprocessing
PROM: Deputy Assistant Administrator
Office of Pesticide Programs (WH-566)
TO:	Mr. Brian Molloy, Hearing Office
Herbicide Orange Hearings April 25/28, 1975
I. Background and Policy
In accord with Section 19-A of the amended FIFRA
: '	V
the Administrator of EPA is required to establish
procedures and regulations for the disposal or
storage of pesticides and excess amounts of such
C. RAY BEEBE 6t ASSOCIATES
HONOLULU, HAWAII

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Mr. Mackenzie
pesticides. Initial regulations.under Section 19
were published in the Federal Register on May 1, 1974
and additional rule-making is now under final
deliberation within the Agency.
The disposal policy embodied in these rules states,
"In considering disposal techniques the first
preference should be given to procedures designed
to recover some useful value from excess pesticides
and containers.w Under this policy at least 3
useful avenues of disposal can be identified.
These are:
1.	Use of the excess material for the purpose,
intended i.e., return of an Herbicide to
normal marketing channels in end use
Herbicide consumer products under legal
EPA labels.
2.	Return to manufacturer for potential reuse
or processing.
3.	Export of the material to countries where
use is both legal and desirable.
Only if none of the preceding are'applicable is
ultimate disposal by non-productive methods
considered.
In light of the current situation of shortages of
critical agricultural chemicals including the
C. RAY BEEBE & ASSOCIATES
HONOLULU;-HAWAII

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Mr. MacKenzie
2,4-D component of Herbicide Orange and consistent
with, the need to conserve and reuse our natural
resources this policy- has been followed with respect
to disposal of Herbicide Orange. To briefly
summarize progress to date the following milestones
should be noteds
1.	The manufacturers have not shown a desire
or willingness to accept the material, for:,
return to normal trade channels in their
own end use products.
2.	Although the Air Force had sufficient
data to obtain a Technical Product
Registration the material could not be
disposed of by sale to reformulators
because:
a.	Compliance with allowable level
of dioxin (TCDD) in the Technical
Product would allow only 30 percent
of the Herbicide Orange to be
disposable by this route.
b.	For Air Force to formulate end-use
products (lowering dioxin content
by dilution) would require end-use
label registration. Obtaining the
data required for such registration
C. RAY BEEBE & ASSOCIATES
. . HONOLULU, HAWAII -

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Mr. MacKenzie
and developing marketing channels
i'
for product disposal would be
beyond Air Forces capability and
would require, in all probability#
several years before fruition,
c.' Reformulation of Herbicide Orange
containing high levels of dioxin
tfould present an unacceptable
hazard to the public health. Even
were sufficient dilution practical
it would be virtually impossible to
monitor all reformulated products
dispersed by numerous reformulators
thus posing an unacceptable risk.
3.	Reformulation was considered unfeasible.
The decision was made to investigate the
next alternative, reprocessing. OPP was
in possession of general information at
the time of this decision which indicated
that a potential fee reprocessing Herbicide
Orange into commercial products which
might destroy dioxin in the process or
concentrate it into readily-disposable
wastes did exist.
4.	Air Force through DSA placed an offering
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. MacKenzie	143
for bids to chemical processors for purchase
and conversion of existing stocks of
Herbicide Orange.
II. Reprocessing
Four manufacturers have evidenced interest and
three also submitted process descriptions in
support of bids to reprocess Herbicide Orange.
The basic processes proposed all basically
attempt to selectively separate the valuable
components of.Herbicide Orange (2,4-Df2,4,5-T)
by classical chemical methods i.e. solvent
extraction, distillation or adsorption ,
with resultant concentration, and partial
destruction of dioxin in waste streams (and/or
on solid absorbents). The unreacted dioxin
impurity would then be disposed of by
incineration. The process descriptions have
been evaluated by EPA and Army Environmental
Hyigene Agency technical experts. In their
advised opinion the processes, one in
particular, appear promising in aspects of
2,4-D and 2,4,5-T recovery as well as
satisfactory destruction of the dioxin
contaminant. However, sufficient processing
questions were raised, particularly as related
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. MacKenzie	144
to dioxin disposal and in-process destruction
aspects to warrant a mandate for pilot studies
(Up to 150 gallon capacity) to be carried out
to: (1) confirm process claims, (2) determine
impact of scale up on process efficiencies,
(3) closely evaluate dioxin destruction and
disposal, (4) obtain an accurate estimation of
possible dioxin environmental contamination
probability in process.
III. Timing
Evaluations by the technical experts have been
turned over to DSA with summaries of specific
data required to be obtained in the pilot
plant operations. It is assumed that six
months should be ample to allow collection of
such data and final evaluation of reprocessing
as a feasible means of disposal to be made.
All reprocessors indicate capability to
initiate immediate disposal on acceptance of
bid. Pilot samples of Herbicide Orange have
already been transferred by A.F. to
prospective reprocessors.
ZV. Other Considerations
In addition to determination of process
feasibility, efficiency and time-framing EPA
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. MacKensie	145
will also be concerned with, consider, and
evaluate various aspects of;
1.	Assurance of adequate quality control
in the process so that careful
monitoring of dioxin levels in
commercial products manufactured from
recovered materials insures maintenance
below acceptable levels.
2.	Probable level of dioxin refuse and
other wastes generated by the reproces-
•' sing. Include in these considerations
are possible aerial emissions from
smokestacks, if incineration is
proposed, contamination via liquid vs.
solid refuse incineration resulting
from the processes and possible sources
: of on stream process losses in carbon
balance.
3.	Consideration of safe handling, storage,
and drum (or other container) disposal
associated with transfer and processing
of Herbicide Orange. Adequate safe-
guards must be apparent and eventual
container disposal executed in such a
manner as to obviate environmental risk.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. MacKenzie	146
4. "Assurance of proper registration of
end use products.
V. Summary
Recovery of useful value from pesticides in a
disposal situation must be determined to be
unfeasible before non-productive (Destructive)
means can be considered. In the case of
Herbicide Orange reprocessing to recover useful
Herbicidal value from the 2,4-D and 2,4,5-T
components with concurrent destruction of the
teratogenic dioxin contaminating component
appear promising. Pilot plant studies to
accurately evaluate the chemical processes
involved in reprocessing are required at this
time. They probably can be completed in six
months. EPA believes the reprocessing aspect
is worthy of additional serious consideration
and if feasible it may well be preferred to
ultimate disposal. It might well; in light of
current estimates, return 2,4-D and 2,4,5-T to
commercial channels with lower dioxin content
than that 9urrently manufactured.
s/Edwin L. Johnson
Edwin L. Johnson
MR. MOLLOY: Our next speaker is Manfred Braun.
C. RAY BEEBE 8c ASSOCIATES
HONOLULU, HAWAII

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Mr. Braun	147
He is representing the Ocean Cumbustion Service, which is
the owner of the vessel VULCANUS.
oOo
MR. MANFRED BRAUN: My name is Manfred Braun. I
am a citizen of West Germany, and I am employed by D.D.G.
Hansa, a West German Steamship Company, in the capacity of an
Owners' Representative for the United States and Canada and I
have offices in New York. Ocean Combustion Service in
Rotterdam, operators of the incineration vessel VULCANUS is a
wholly owned subsidiary of D.D.G. Hansa.
It was my intention to talk about the
construction, the capabilities and the performance record of
the ship. However, I will not read all of what I have here
because I feel that considerable part of it was adequately
covered by Colonel Williams as well as Dr. Welch.
The vessel was put in service in September
1972 in Rotterdam as a tanker designed to incinerate chlorinat<
hydrocarbon waste products which are produced in considerable
quantities by chemical industry/,and which axe extremely
difficult to dispose of on land due to the fact that: they
contain chloride. By burning at sea the otherwise harmful
fumes are deposited in the ocean in the form of hydrochloric
acid, which the sea can neutralize in considerable quantities
by its alkaline components without harm to marine life.
The vessel is constructed as a double hulled
C. RAY BEEBE 6c ASSOCIATES
HONOLULU, HAWAII

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Mr.'Braun	146
tanker, classed by Germanischer Lloyd and complies with IMCO
regulations on the carriage of dangerous chemicals in bulk at
sea. Because of her size of 4/768 dwt. she can operate
world-wide and is also capable of working in rough weather.
I particularly want to mention that because the question was
raised before that this ship is liable to sink, something of
that nature, whereas in actual working experience she has
worked in the North Sea at Wind Force 9, which translates
itself into 15 to 20 feet waves, and she does not only keep
afloat, she also keeps operating at that kind of weather.
She does not shut down her incinerators, not at that Wind
Force.
the
While/next paragraph is about the working
procedure on the vessel, I will skip that because it was
' «
covered before.
(The paragraph omitted by Mr. Braun is as follows:
She has two incinerators mounted at the
stern into which the wastes are fed from her 15 holding tanks.
Regular marine gas or diesel oil is used to bring the
combustion chambers up to the desired temperature. Only when
this temperature is reached will the pumps allow the wastes to
enter the chambers. The chambers will then be fed solely by
- *
the cargo, but in the event of tJie temperature falling below
the required level, the flow of waste is thermostatically
stopped. The average incineration temperature is 1400°C.
C. RAY BEEBE &
HONOLULU,*
ASSOCIATES
HAWAII

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Mr. Braun	149
Each chamber is fitted with three burners ensuring an even
L	'
distribution of combustion throughout the chambers. The
incinerators are equipped with fans that can supply up to
90,000 cubic meters of air per incinerator to achieve near
complete combustion. The vessel is equipped with a control
device that photographically records in 15 minute intervals
the location of the ship, time and date, temperature inside
i
the incinerators as well as the switching on and shutting off
of pumps and burners.)
MR. BRAUN: (Continuing) Since the vessel was
put into service, she incinerated a total of 97,400 metric
tons of chlorinated hydrocarbon waste in European coastal
waters. These wastes originated from Dutch, British, Belgium
and Scandanavian industrial plants. Before allowing such
operations, the Dutch government conducted extensive
monitoring of the vessel, the results of which showed a
combustion efficiency in excess of 99.99 per cent. The
monitoring report of the Dutch government has now become
available and is in our possession. It gives details on the ¦
type of monitoring done, techiniques used, analysis made and
their evaluation. I am submitting a copy of it for the
record.
Actually, this monitoring report consists of
two parts, and we have only been able to translate one into
English for lack of sufficient time. The second portion of
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. Braun	150
it I have submitted in Dutch, and we are working on a,
translation. As soon as that is completed we itfill also
submit that.
In addition, .the French government has also
conducted extensive monitoring on the vessel and her .
environment; independent from the Dutch government. The
French Ministry of the Environment made these studies in order
to formulate legislation on -the disposal of such organic
chloride compounds. Their findings confirmed the results of
the monitoring by the Dutch government, i.e. a near complete
combustion efficiency, and no adverse environmental impact.
This French report; is also in our possession and I have
submitted a copy for the record.
Actually, the translation of this was
just finished a few days ago in Washington, and at that time
a copy was already given to the Air Force.
The vessels operations in Europe are being
carried out under permits of the governments of Holland,
Great Britian and Belgium in coastal waters as close as
20 miles from the shoreline of populated coastal regions.
This is considered safe in Europe in line with'the results
of the monitoring done,,
In one instance, or in one particular
incineration site, incineration is actually done within
15 miles of the coast of Belgium, and that is actually upwind
C. RAY BEHBE 8c ASSOCIATES
HONOLULU, HAWAII

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Mr. Braun	151
from the coast. I want to mention this particularly because
that might answer a question that was asked before by one of
the speakers who wanted to incinerate Herbicide Orange in
Washington. I don't see him around anymore, but I think that
will answer his question.
During this activity over two and a .half
years, not- a single accident/ spillage or complaint about the
operation of the vessel or any environmental stress whatsoever
has occurred.
The performance record of the vessel further
includes the incineration of an additional 16,000 metric tons
of organic chloride wastes in American waters for Shell Chemici
Company, Deer Park, Texas in the Gulf of Mexico in 1974.
This operation was carried out in a federally approved
incineration site under the most extensive monitoring of the
Environmental Protection Agency, and also Shell Oil Company.
I do not have to go into the details of the results, because
they have been well documented by EPA; It suffices to say
that the results confirmed the findings in Europe with no
detectable quantities of unburned residues in the ocean at
the point of maximum fall out, a hydrogen chloride concentra-
tion at sea level of well below the 5 ppm standard set for
workers exposure in onshore industrial plants, a harmless PH
variation in the ocean water of well below 0.5, with no
adverse impact on zooplankton or phytoplankton, and no adverse
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. Braun	152 -
effect of the plume on migrating birds in the area. In short,
no environmental stress at all.
The product proposed for incineration near
Johnston Island is similar to the wastes that have been
sucessfully destroyed by the vessel, i.e. it consists of
organic chloride compounds. We have determined that based on
the characteristics of Herbicide Orange given to us by the
Air Force we will be able to safely handle and incinerate this
material. The VULCANUS satisfactorily completed an examinatioi
in Rotterdam by the United States Coast Guard after having
undergone a nuber of changes to comply with the United States
Coast Guard regulations. A letter of Compliance subsequently
issued by the Coast Guard to the vessel specifically names
Herbicide Orange as a product the vessel is equipped to safely
handle in accordance with Coast Guard regulations.
The preliminary requirements for the
incineration of Herbicide Orange as indicated by EPA in the
Federal Register of March 24 can all be met, and are well
within the performance record of the vessel. The National
Wildlife Federation has generally supported the concept of
ocean incineration of Herbicide Orange, as they had also done
withthe incineration of the Shell Chemical waste in the
Gulf of Mexico. They have,however, suggested that six
conditions be imposed on the permit applicant, as published in
the Federal Register of March 24. The first four of these
C. RAY BEEBE & ASSOCIATES
•HONOLULU, HAWAII

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Mr. Braun	.153
conditions, which are dealing with combustion temperature/
dwell time, fuel to air ratio and excess air, cannot only
be met but can be exceeded in accordance with past performance
of the vessel. The other two conditions suggested by the
National Wildlife Federation are to preheat Herbicide Orange
to at least 90°F and to inject the waste into the combustion
chambers with a radial slot type rather than a central poppet
type nozzle.
As to the preheating, we see no need for it,
since the vessel's pumps as well as its burners are designed to
handle a viscosity in excess of Herbicide Orange at the
ambient air temperature of 80OF prevailing at the proposed
incineration site.
As to the type of nozzle suggested, the
burners do not have any at all. Instead, the vessel uses a
much more efficient rotary burner which atomizes the fuel by
centrifugal force through: a rotary cup spinning at 5,000 rpm
with an excess air supply of..30,000 cbra per burner. This
allows to atomize liquids without any hazard of clogging which
is the case with nozzles. In our experience this burner is
more efficient than any other for the purpose.
We welcome any type of monitoring that is
desired to carry out this operation and that is physically
possible. I am sure that EPA's experience in this regard is
available to the Air Force, and I also have the assurance of
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. Braun	154
Shell Oil Company to cooperate with the Air Force in sharing
their monitoring experience of the VULCANUS made last year in
the Gulf of Mexicoo
Concluding, I would say if ocean incineratior
of Herbicide Orange is the disposal method elected for this
material by EPA, we believe that the VULCANUS is the proper
tool.
Thank You.
MR. MOLLOY: Mr. Braun, I have a few questions.
You say you have never had an accident or
a spill of any kind?
MR. BRAUN: That's right.
MR. MOLLOY: How far is the furthest distance off-
shore you have gone in the North Sea with the material to be
burned?
MR. BRAUN: A hundred miles.
MR. MOLLOY: And how far is it.that you go out in
the Gulf?
MR. BRAUN: In the Gulf of Mexico, you mean?
MR. MOLLOY: Yes.
»	. k	" -
MR. BRAUN: That was about two hundred miles. The
closed I think was 190 miles.
MR. MOLLOY: How many screws do you have on the
vessel for propulsion?
MR. BRAUN: How many screws?
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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155
• Mr. Braun
MR. MOLLOYs Yes.
NR. BRAUN: One. .
MR. MOLLOY: What safety features do you have on
the vessel that would tend to assure us that a spill would
not occur if you were say five hundred miles from shore?
r.
MR. BRAUNs Well, number one, there are no pumps
to — the way the vessel is designed is that the material is.
pumped into the holding tanks like a regular tank operation,
but there is no pump that can pump it back out unless it goes
into the incinerators. There is a possibility to pump it out
for safety, reasons, but that is sealed or can be sealed if
desired by the respective government agency in whichever
country this is done.
So, in other words, if anything is pumped out,
over board, it would be immediately known by the virtue of
the fact that a seal was broken.
MR. MOLLOYs How far can you travel with a full
load of cargo, fully fueled?
MR. BRAUN: You mean without refueling?
MR. MOLLOY2 Yes.
MR. BRAUN: Maybe Captain Borchers can answer
that.
CAPTAIN DIETER BORCHERS: One moment, please.
That's about twenty-eight days.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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156
Braun/Borehers
MR. MOLLOY: What does that translate into
miles?
CAPTAIN BORCHERS; That's 250, about 250 miles
a day.
MR./BRAUN? So that's about what, 16,000 miles?
CAPTAIN BORCHERS! Two hundred and fifty by —
about.
°	MR. MOLLOYi Then there is no apparent
necessity to refuel on the way from Gulfport to Johnston
Island?
MR. BRAUN: No, exoept that the ship would
have to refuel in Johnston Island in order to get back.
MR. MOLLOYs I have no further questions.
If there's anyone else on the Panel?
Mr. Enos.
DR. ENOSs In the last two experiences with
the Vulcanus, the question of whether or not the Vulc^nus
will be underway at the time of the burning to maintain the
plume behind the vessel was discussed. Yet, it was my
understanding from some of the testimony at that time that
there were occasions when the vessel drifted back through- the
plume. Does this present a hazard?'. Do you take some overt
measures to avoid this? Would you discuss that particular
problem?
C. RAY BEEBE & ASSOCIATES
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MR. BRAUN: Well, the vessel doesn't really
drift. The vessel is a mobile unit, and has the capability
of avoiding just that in proceeding against the wind, which
depends on the speed. .
I think the speed that we normally use is
three to four miles an hour, which is perfectly adequate
together with the wind not to get into the plume, and we
haven't had any problem with that in the past in the North Sea
where the weather is much, much wore^. than here.
'	v
DR. EN OS: So you era underway at all times when
you are burning?
MR. BRAUN: We stay out of the plume, yes.
MR. ROGERS; I have some questions, Mr. Chairma;
MR. MOLLOYs Go ahead, Mr. Rogers.
MR. ROGERS: Mr. Braun, we had quite a bit of
discussion during the Shell burn about the topic Dr. Enos
just raised, and your last response was one of the responses
we received during that burn. You said that you stay out of
the plume. But are you underway at all times? Do you steam
up and are you moving at all times? Because our man on board
the Vulcanus testified that while he was on board the ship was
not underway.
MR. BRAUNs We generally are, but whether we
are in all cases, I think Captain Borchers would be in a bettei
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position to answer.
CAPTAIN BORCHERS: That depends on the weather
conditions, wliat kind of wind you have. Is the wind strong
enough? Then it's not necessary to steam.
MR. MOLLOYs Sir, could you identify yourself,
please?
CAPTAIN BORCHERS: Yes. My name is Dieter
Borchers. I am one of the technical directors of Ocean
Combustion Service in Rotterdam.
MR. MOLLOYs I see. You are for the firm
owning the Vulcanus. All right. Thank you.
MR. BRAUN: This means, in other words, we
are keeping out of the plum& If weather conditions permit to
do so by not moving, then this can be done. But if otherwise
the ship does move in order to keep out of the plume.
MR. ROGERS: What does Wind Force 9 relate to
in layman's terras?
MR. BRAUN: Well, that's the measure in
Beaufort of the force of wind, and there is a scale from one
to twelve. The twelve is Hurricane, which is the highest, and
nine translate itself in the North Sea into 15 to 20 foot
waves, the height of the waves.
MR. ROGERS: Has the Vulcanus ever gone to
Port during a storm?
r •	•	'	.
c	,	,i
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at all.
no.
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Braun/Borcher s
MR. BBAUN: Not in that kind of weather. Not
CAPTAIN BORCHERS: Not up to now. Up to now,
MR. BRAUNs Not at all.
MRc ROGERS % So you would think it very unlikel]
that in a Pacific storm you would have to seek shelter or,
as implied in some of the other questions, you would have to
jettison some cargo?
MR. BRAUN: Unless it's a full-*scale Hurricane
that presents a real danger, but normal bad weather it is no
problem for the ship.
MR* ROGERS s Would you be in more danger with
a ship fully loaded than a ship half full in a full-scale
hurricane?
CAPTAIN BORCHERS: No. No, it's no different.
MR. ROGERSs So you would not need to jettison
cargo in a full storm?
CAPTAIN BORCHERS; That depends on the storm.
If the storm is too strong, it's better the ship's going back
to the harbor. "Storm" means really, Beaufort 12 and more.
MR. ROGERS; But are you saying you would not
foresee any occasion when you would have to jettison cargo,
during a Force 11, Force 12 storm?
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Braun/Borchers
MR. BRAUN: That is really a problem that .would
arise if the vessel would be so far removed from any shelter
that she would be in any real danger, but all incineration
sites that we have been working in, we are so close to shelter,
and in addition to that, this type of bad weather, especially
a hurricane# is predictable, so that the ship would not move
out in order to incinerate in the first place if such a
weather condition is predicted or anticipated.
MR. ROGERS: Now, I take it you will steam from
Gulfport through the Panama Canal?
MR. BRAUN: Yes.
MR. ROGERSt And into the disposal area.
Would you refuel then at Johnston Island?
MR. BRAUN: The ship would have to refuel at
Johnston Island, that's right. Yes.
Oh, you mean before the first burn?
"71
MR. ROGERS: Yes.
MR. BRAUNI Yes, also.
CAPTAIN BORCHERS: Yes.
MR.- ROGERS: Do you need any special clearance
to go through the Panama Canal?
MR. BRAUN: Not any.special clearance that we
don't have as far as the ship is concerned. I don't believe
so at this time. I don't know what we really need because we
C. RAY BEEBE & ASSOCIATES
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Braun/Borchers
haven't gone through the Panama Canal with the vessel, and I
couldn't really answer that question what we need in addition
to what we have.
MR. ROGERS: You mentioned that you had made
changes to meet Coast Guard Regulations?
MR. BRAUN: Yes.
MR. ROGERS: Could you quickly tell us what
those are?
MR. BRAUN: It was a number of changes that we
had to make. One was the piping system had to be changed,
and one thing in particular, which also relates to some of
these questions that were asked in terms of safety during
loading and escape of vapor into the air — the vessel had a
restricted gauging system, which is not allowed in this
country by the Coast Guard. What the Coast Guard wanted was
a closed gauging system which permits no release of air into
the atmosphere of gasses, and we had to install that. So
instead of opening, am outlet at the pipe, we had to install
a windowglass type gauging system through which one can see
the scale in the tank and read the outage of the tank without
opening anything. That was one of the particular requirements
was
of the Coast Guard which/installed in Rotterdam before we got
the letter of compliance.
MR. ROGERS: I am unfamiliar with what the
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Mr. Braun
Coast Guard jurisdiction is in this area. Do they issue a
general certificate of seaworthiness to a tanker such as yours?
MR. BRAUN: They don't issue a certificate of
seaworthiness. That's issued by the classification society
of the vessel.
What the Coast Guard is concerned with is
safety of loading in the United States port and safety of
carriage of cargo in United States waters, and their concern
in this case, was to make sure the ship can safely load this
material at.a United.States port without any possibility of
spillage or mishandling or bad handling, and also safely
r- c.	:
carry it. And those were the conditions that we had to
fulfill.
MR. ROGERS: How, the classification society
or group that issues, I would assume the classification, did
you receive such a classification, and what is it?
MR. BRAUN: Oh, yes. That's issued by
Germanischer Lloyd in Germany as to the seaworthiness of the
vessel, and that she — the classification societies have
certain stylets to be complied with and they have certain
grades of certificates that they issue, and we have the highes :
that Germanischer Lloyd issues at all for any type of ship
in terms of seaworthiness.
MR. ROGERS: Thank you.
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Mr. Braun
One final question, just out of curiosity.
What's your freeboard between your fully laden lowest point
of gunnel and your fully laden ship to the water? How much —
MR. BRAUN: The freeboard when she is down?
CAPTAIN BORCHERS: One meter and ten centimeterE
MR. ROGERS: That's what, about six feet?
MR. BRAUN: No, it's about three feet. A little
more, three and a half feet.
• , MR. ROGERS: Three feet from the lowest point
of the deck to the —
MR. BRAUN: To the waterline.
CAPTAIN BORCHERS: To the waterline.
' MR. ROGERS: Thank you. I have no further
questions.
MR. MOLLOY: I have one more. I apologize.
Is this a new vessel? You stated it went into
service in 1972. Is that when the vessel was built?
MR. BRAUN: No. She used to be a dry cargo
ship. We bought the ship and then converted her in a dry
dock in Rotterdam. We ripped everything out and put the tanks
in and the incineration plant.
MR. MOLLOY: And since it has been under your
control, has it ever been disabled in the sea? Whether or not
fully loaded or whether or not in a storm?
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164
¦ Mr. Braun
MR. BRAUN: No, it has not.
MR. MOLLOY: Thank you. I have no further
questions.
*lr. Biglane?
MR. BIGLANE: Yes.r :•
There was mention expressed in the following
line. You mentioned several countries for which you have
burned chemical wastes.
MR. BRAUN: Yes.
MR. BIGLANE: Now, what kind of monitoring
requirements did these countries assess on the Vulcanus for
such burns?
MR. BRAUNs None at all. The monitoring was
done initially be the Dutch government, and also by the
French government. And when we received the permissions of
the other countries, they based themselves on the monitoring
experiences particularly of the Dutch government and accepted
those. So there is no monitoring done currently, after that.
MR. BIGLANE: Were there any biological surveys
or other type of marine-type surveys conducted by the other
countries?
MR. BRAUN» By France, yes, and that's part of
that report that I submitted today.
MR. BIGLANE: And did they note any damages
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165
Mr.. Braun
from the incineration of wastes that you burned in those
areas?
MR. BRAUN: None at all. They concluded that
there was no environmental stress, and there was only one
" • / * _ r	.	'
qualification# and that is, as I recall, that they did not
recommend the incineration of wastes with heavy netals.
MR. BIGLANE: Do you recall whether or not any
of these countries had similar type criteria in areas of the
ocean where one ought to burn or incinerate wastes, that is,
areas of low productivity?
MR. BRAUN: I don't think that was a particular
criteria, for the simply reason that in Europe we don't have
that much space available to move anyplace, and it had to be
a site that is practical.
Also, from a weather point of view in the
North Sea there is more bad weather as here, and if we would
move a thousand miles away, which wouldn't be feasible in the
first place, so there were certain priorities that couldn't be
rearranged, for which reason it had to be done near densely-
near
populated areas. Not only that, but also very/shipping lanes,
which has produced no negative results during the last two and
a half years.
MR. BIGLANE: I think the burn that took place
in the Gulf of Mexico was about one hundred thirty miles off-
C. RAY BEEBE & ASSOCIATES
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Mr o Braun
shore. 1 Is that not: right, Mr. Wastler? .
. MR', WASTLER: It's one hundred forty nautical
miles t which my instant calculation shows to be about 170
statute miles.
MR. BIGLANE: What's the shortest distance
offshore that you have ever incinerated wastes?
MR.. BRAUN; Is that a question for. me?
MR. BIGLANEr What.is the shortest distance
offshore?
MR. BRAUN: In Europe?
MR. BXGLANEs In Europe.
MR. BRAUNs Fifteen miles.
CAPTAIN BQRCKERS; It's eighteen miles..
Correction.
MR. BRAUN; Correction, eighteen miles*
MR. BIGLANE: And was this done with considera-
tion of winds blowing toward the mainland or toward the coast,
or was	taken into consideration?
MR. BRAUNj Yes, it was taken into consideratio
because that entire coast of Western Europe is in the western
wind zone, so usually there is west winds which blow toward
the land.
MR. BIGLANEj Was there any atmospheric
fallout noted from such a short distance offshore?
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167
Mr. Braun
MR. BRAUN: None to our knowledge, and we would
certainly know if there were.
MR. MOLLOY: Are there any other questions?
Mr. Wastier?
MR0 WASTLERs I have one point that I seem to
be a little unclear about,,
I assume there is some mechanism for jettison-
ing cargo aboard the Vulcanus/ isn't there, as a safety
measure?
MR. BRAUN: Yes.
MR0 WASTLER: Could pu tell us what that is?
MR. BRAUN: I would prefer it if Captain
Borchers does that, because he is a master marine and he has
been running the ship himself. He would be more qualified to
s
specify that.
MR. MOLLOY: Could you come forward, sir, and
use the microphone.
(Discussion off the record between Captain
Borchers and Mr. Braun.)
MR. BRAUN: It's an emergency regulant
marine-type ballast pump that can pump the. material from the
holding tanks overboard, which is usually sealed if required.
MR. WASTLER: This'is connected to all fifteen
tanks?
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168
Mr. Braun
MR. BRAUN; Yes„ connected to all fifteen tanks
by a manifold system.
MR. WASTLER; Is it normally sealed or is there
a means.for putting a seal on it of some type?
MR.	BRAUNs Yes. It is normally sealed.
MR.	WASTLER: Okay. Thank you.
MR.	MOLLOYs I don't think there are any
further questions.
MR. ROGERS; I just have one question I forgot
to ask, Mr. Chairman.
Have you ever had an engine failure?
CAPTAIN BORCHERSs Wo.
MR. BRAUNs No.
MR. ROGERSs Is it a boiler system that you
have on the ship?
MR. BRAUN: Diesel engines.
MR. ROGERS i Diesel engines. Thank you.
MR. MOLLOYs I guess that's all.
The next speaker is Mr. James L. Boyland.
Deputy General Manager, Marquardt Corporation.
MR. JAMES L. BOYLAND: It looks like I am the
last one today.
Gentlemen, I am the Deputy General Manager
'1	-	'	* "	'
of the Environmental Systems Division of The Marquardt Company,
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169
Mr. Boyland
and I am here to present a prepared statement by the President
of Marquardt. I have submitted copies to the appropriate
people. I have an extra one if anybody particular wants one.
I think what I will do is summarize the report,
since a lot of it has been incorporated into the Environmental
Impact Statement as our comments, and can be referred in the
appropriate appendex. I don't remember which one it is
offhand.
My name is James L. Boyland, as I said. The
statement is prepared in the name of Mr. George Hanauer. He
is our President.
What I think I will do is just to summarize
some of the key points of the statement, and then read portion
of it in the interest of brevity, since a lot of it is going
to be rehash as to what's already been discussed.
*
Primarily, we notice today that there has been
a lot of conjectore, but still, as far as I am concerned,
have not reviewed data that does specifically establish a
combustion efficiency for the VULCANUS. It has been stated
that such reports exist, so I will not challenge or concur.
We think that there should be tests conducted
on the ship to determine its efficiency.
Our unit was tested at Marquardt under Air
Force's supervision. A very thorough test was conducted and
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Mr. Boyland
consisted of eight separate runs* We used a total of 1,540
gallons to conduct this test, and it was more than adequate
to obtain the data required.
We do concur with the ocean incineration
principle, under systems with proven efficiency, and we do
not object to research permit being granted to the VULCANUS
under restrictions.
We do disagree as to quantity. Z do not see
a need to burn a complete shipload to obtain data, and there
by run two incinerators.
We have, as I will1 mention when read the report
looked at available literature which is slightly off from the
numbers that were given today., but apparently there's fifteen
tanks on the ship. We feel that any one of these tanks,
whether the smallest or the largest, could be filled with the
herbicide, one incinerator used and sufficient data obtained
to evaluate how efficient the system is and how well it
destroys it without taken the risk of a whole 4,200 tons, I
believe it is.
So with that in mind, 1 think I will proceed
through the statements, paraphrasing.
This statement addresses itself to the United
States Air Force application for a special permit to
incinerate at sea the remaining stores of the compound known
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171
Mr. Boyland
as Herbicide Orange and the Environmental Protection Agency's
tentative determination as published in the Federal Register,
Volume 40 Number 57.
The Marquardt Company has successfully
incinerated Orange Herbicide for the United States Mr Force
under two separate contracts using, the patented Sudden Expansioi
— SUE for Sudden Expansion — burner.
The major objective of the second contract was
*
a joint investigation by the United States Mr Force,
Marquardt to "Determine the capability of an incineration
system to deetruct the 'Orange Herbicide' over a range of
selected incineration conditions."
Test data demonstrated that the Orange Herbicide
was effectively and safely destroyed by incineration. Four
of our test runs were done with the slot-type nozzle, which is
a different type of injection. The other four were done with
the poppet nozzle, which injects a different manner. The
four slot nozzles were the most effective, and generated
efficiency data of 99<,398 percent.
The contract objectives, Summary and
Selected Sections of the final report we are including as
Appendix A. The full report is included in the Environmental
Impact Study.
The United States Air Force stated in both the
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Mr.. Boyland
final report for the U. S. Air Force-Marquardt pilot
incineration program and the Final Environmental Statement
that the purpose of the joint contract was a pilot program
to obtain incinerator operational parameters that may be
appropriate to a commercial incinerator system.
I think the point — I will digress a minute.
I think the point has been belabored, but I will make it one
more time, and that is that two points should be clarified
in order to assess that statement.
The first is, the SUE burner used in1 the
subject pilot program is a unique type burner that operates
on a entirely different principle than the normal commercial
incinerator, the VULCANUS as just described, and that
statement is still factual.
The second point is, the SUE burner is a
ciommercial incinerator system in use in industry today. So
our system does meet the requirements of the contract as it
was stated.
All totally successful incineration runs in the
United States Air Force-Marquardt pilot program were made with
slot nozzles. Only a SUE burner can properly utilize slot
nozzles which inject the fuel at the point of expansion and
stabilizes the flame. Therefore, the reported 99.998 percent
efficiency is only applicable to a commercial incinerator
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173
. Mr. Boyland
system using a .SUE .burner, and that's in the strictest
technical sense. We are not saying; other incineraters can
or.cannot meet that requirement. All we are saying is, they
should be tested.
The remainder of thi3 section of the report
is basically our comments as submitted in the Impact
Statement, and I will bypass them.
I will reiterate what I stated in my opening
remarks. I will read our section of the report.
Available literature on the VULCANUS indicates
that the ship has fifteen (15) separate storage tanks that
feed two (2) separate incinerators at a rate of 12 metric tons
per hour each. Tank capacity varies from 110 cubic meters
to 600 cubic meters. I believe the exact number is slightly
less than six hundred.
If you translate this in .burn hours of Herbicide
Orange, you would have 12 hours for the 110 cubic meters and
66 hours with the 600 cubic meters, respectively, using one
incinerator. This arrangement lends itself to testing of one
of the two incinerators for a reasonable time.
It is our professional opinon that a 12-hour
run of one incinerator is adequate to complete the required
tests, and that 66 hours is the maximum that can be justified.
In addition to the proposed conditions and the
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3.74
Mr. 2oyland
contingencies stated in the Tentative Determination/ we
recommend, one, that the quantity be reduced to one tank and
one incinerator for testing. We also request that the
additional conditions be imposed as follows:
Demonstrate adequate preheat of the incinerator
chamber, smooth transition to the Orange Herbicide, and a
second smooth transition to a clean fuel for the purge cycle.
In other words, demonstrating the preheat that it has been
stated the ship is equipped with, demonstrate that it will
complete it3 burn and then demonstrate the shutdown. We were
required to do that in our test program.
The second condition is to demonstrate
emergency shutdown procedures to simulate a plugged waste fuel
line. In this event, a rapid transition to the clean fuel
should be made and the purge initiated. This procedure is
required to prevent release of raw or partially burned
Orange Herbicide to the atmosphere. This condition would
occur if the incinerator, in layman's terms, flamed out and
the pumps continued to pump herbicide in at a rate of — I
think it's six and two-thirds pounds per second, if I remember
the number* No mention has been made so far today as to
whether the VULCANUS has ever experienced plugged fuel lines.
We have no data on this. This is an interesting point. If
the line plugs, the flame goes out and then the plug comes out
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Mr„ Boyland
and continues to pump, you would release herbicide unless the
flame was reinitiated. Therefore, you should change to anothi
fuel to keep the flame going.
The Marquardt Company has no objections to the
incineration of Orange Herbicide at sea when an incineration
system with documented efficiency is utilized. However, the
company does strongly object to data obtained from their SUE
burner being applied to an entirely different type of
incineration system.
The Marquardt Company does concur with the
Environmental Protection Agency's published Tentative
Determination with respect to the application to the U. S.
Air Force for issuance of a modified, as we defined, research
permit pursuant to 40 CFR 220.3 (e) for conducting a test
burn of no more than 600 cubic meters — that is 718 metric
tons — °£ Orange Herbicide on board the MV VULCANUS at an
approved location.
The Marquardt Company is prepared to design,
install, check out, and operate a land based incineration
o
system using the SUE burner on Johnston Island. A scrubber
system can be incorporated with our land based system, and
this would comply with the stated requirements of the
Governor of Hawaii.
We appreciate this opportunity to comment on
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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Mr. Boyland
the Tentative Determination.
It's signed by George H. Hanuer, President of
Marquardt.
MR. MOLLOYs Are there any questions from the
Panel?
DR. ENOS: Yes.
In determining the .efficiency of the incineratoij-
would you consider that it would be acceptable to use a range
of materials, or would you require that the particular chemical,
under consideration would have to be evaluated each and every
time that particular incinerator was to be used?
MR. BOYLAND: I think in the case of something
in the category of Herbicide Orange, it should be tested
specifically. I think if you established a general pattern,
such as has been done with Shell, for a typical waste of a
refinery that generates basically the same type wastes over
and over again, once it's been tested it should be adequate.
DR. ENOS: Would you consider that the Shell
waste would be more difficult to burn, for example, than the
Agent Orange?
MR. 30YLAND: We have never handled the Shell
waste.
DR. ENOS: On the basis of thermodegradation
consideration, would you not consider that something containing
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Mr. Boyland
66 percent chlorine would be more difficult to incinerate
at 1,400 degrees than some materials which contain considerably
lower percentages of chlorine?
MR. BOYLAND: I don't think I could make a
determination on that raw data without knowing more specifics
of the compositions.
DR. ENOS: Even on a theoretical basis you
couldn't make that?
MR. BOYLAND: We could make such a determinati
if we had the analysis of material. We could run a computer
program as to what the by-products of combustion would be.
All I know, it's a chlorinated hydro carbon with si. heat
content somewhere in the neighborhood of 6,900 BTU's per
pound.
• DR. ENOS: Right.
MR. BOYLAND: That apparently burns. That's
v»
been established. Other than that, there is nothing that X
could say on that without having a constituent analysis.
DR. ENOS: Thank you.
MR. MOLLOY: Are there any questions on this
side?
MR. BIGLANEs I would like to ask a question.
How long would it take you to incinerate the
volume of Orange Herbicide that we are talking about here?
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Mr. Boyland
Say you had a system going. How long would it take you to
incinerate it?
MR. BOYLAND: The part I left out of the
statement indicates that the basic unit tested was a 12-inch
diameter can. This is a full-scale incinerator. We obtain
additional flow rate by adding additional cans rather than
building a larger unit. We don't try to scale.
I submitted a letter to Dr. Welch on September
23, 1974, which had a table, and if you assumed that the
maximum burn rate., using a 20-can unit, which is 20 12-inch
burners operating on.two shifts, ten hours a day six days a
¦j	¦
week, we estimated four months. We; gave them a matrix. You
can take any- type of --
MR." BIGLANE: Maybe I* missed something there.
Did you say operating on ships?
MR. BOYLAND: Oh shifts.
MR. BIGLANE: Shifts. Excuse me.
• MR; BOYLAND: First and second shift of ten
hours each, which is a twenty-hour burn day on six days per week
system, which you call a 2-10-6.
MR. BIGLANEs It would take four months to
burn?
MR. BOYLAND: The complete stockpile.
MR. BIGLANE; The stock we are talking about.
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Mr. Boyland
how long will it take?
MR. BOYLAND: I'm sorry, that's 2,300,000
gallons is the quantity we quoted on them, which is basically
a little bit less than the total, I think.
t
I didn't get your last question, sir.
MR. BIGLANEs Well, I should have asked this
question first, llow long would it.take you to construct a
unit?
MR. BOYLAND: ¦ Our. lead time is out of date at
this point.' It really right npw would depend upon the
availability of stainlesis steel. That would be the limiting
factor. I would not be able to answer the question without
checking the current mill runs. I don't think we could give
r t	m	¦
an estimate at this point. It's been too long since we checked
the job out*
I can tell you what we estimated the job to be
a year ago. I'm trying to find the right page.
We would be able to have a complete installed
system checked.out and institute a — have completed a
training program for the operating crew in nine months. That'3
from design of the system to installation at Johnston Island,
checking it out and training a crew to operate it if the .
government wished to operate it. That was nine months.
MR. BIGLANEs And then four months to burn?
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Mr. Boyland
MR. BOYLAND: That's correct.
MR. BIGLANE: Then what would you do with the
unit after you finished the burn? .
- MR. BOYLAND: You would then clean it up and
break it down for shipment back to the states for whatever
disposition "was required.	j
MR. BIGLANE: Thank you,
MR. MOLLOYj Mr. Rogers?
'MR. ROGERSs Yes. I have a couple of questions
Mr. Chairman.
How much would you charge the Air Force for
your services/ or is that something that is not public
information?
MR. BOYLANDWell/ I haven't heard any — I
prefer not to divulge that in public at this point since it
would probably become a competitive procurement/ and that
would be sort of giving the store away right now.
MR. ROGERS: Very candidly, you are in a
position of a competitor to the VULCANUS?
MR. BOYLAND: That is correct. We make no
bones about it.
MR. ROGERS: Your objections, it seems to me,
are that you feel there are too many things unknown about the
VULCANUS's operation vis-a-vis Herbicide Orange, is that
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;	Mr. Boyland
correct?	^
MR. BOYLAND: That is correct. We concur with
a research program to define it similar to the one we did.
Our point is, we don't think it takes a whole shipload of
material to do a research program.
/ -
ROGERS: Where would you burn your one
tank load? Where would you suggest the EPA allow it to be
burned?
MR. BOYLAND: That is not really in our
expertise, and I would prefer not to comment on that. We
find nothing wrong with what has been said today as far as
the burn sites. We are not qualified to make a judgement on
that.
MR. ROGERS: You mentioned that you would
propose using a scrubber. Has there been any thought of what
you would do with the scrubber wastes that would be generated?
And what would those wastes be?
MR. BOYLANDs Well, what you would have is,
if you use a caustic scrubbing system, you would then retain
the scrubber material, test it as we did at our plant,
neutralize once you have run a test to determine there is no
material left in the scrubber solution. You could then
neutralize it to a neutral pH , and I assume it would be
c
acceptable if you can meet all the requirements to discharge i
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Mr. Boyland
into the ocean. If not# it would have to be removed.
We have been able to successfully neutralize
any of the scrubber solutions that we have had as indicated
in the Environmental Impact Statement, and it was put in our
main holding reservoir, which eventually is discharged into
the Los Angeles sewer system, and this is very strictly
monitored before this is done.
We collected all the scrubber reservoir in
special holding tanks and did not release them from the
holding tanks until complete analysis was done of the solution
and it was neutralized.
MR. ROGERS: Would there be any dioxin in
the —
MR. BOYLANDs There was no detectable dioxin
in the scrubber solution in our test.
MR. MOLLOY: Mr. Wastler, do you have a
question?
MR. WASTLER: Yes, I do.
Am I to gather from your comments that you are
not questioning the data already collected on the efficiency
on tile VULCANUS with regard to other types of wastes?
MR« BOYLAHD: We have not reviewed it, sir.
We don't have any means of questioning.
MR. WASTLERs Have you, with your incineration
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Mr, Boyland
system, tested it on other types of wastes besides Herbicide
Orange?
MR. BOYLAND: Thait is correct, we have. We
have burned DDT in a solution of 5 percent and 20 percent
kerosene. We have burned hydrozene, toxic hydrozene propellanl
We have done other programs for different — they were not
wastes, but we have burned nitrous oxide, for example, as
part of another program for the Navy.
MR. WASTLER: And do you get essentially the
same type of efficiency, or does it change with the waste?
MR. BOYLAND: We have had the same type of
efficiency. The Orange program that we conducted for the
Air Force was the most thorough one that we have ever done.
There was mass balance done on the flows. It was an extremely
thorough approach to the system.
MR. WASTLER: Well, I find myself a little bit
at a lost, then. If you feel that your system will operate
consistently on different kinds of wastes, why do you feel
that the VULCANUS system will operate all right for other
kinds of wastes and won't operate satisfactorily for the
Herbicide Orange?
. MR. BOYLAND: That's not quite what I meant
to say. Maybe I did say it.
You asked us whether we had tested other types <
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wastes, and I answered, yes, x*e had and, yes, we had received
similar data. We have no reason to believe that the VULCANUS
wiil or will not operate as efficiently. What we are asking
for is a test to prove it as we would test any new material
before we went to a full-scale program.
MR.- WASTLER: You said, I believe, that you
would estimate on a land based incinerator on operating at
two shifts?
MR. BOYLAND: That's correct.-
i
MR. WASTLERs That is sixteen hours out of
twenty-four?
twenty-four,
MR. BOYLAND: No, that's twenty hours out of
MR. WASTLERs And then you let your incinerator
cool down after that?
MR. BOYLAND; We had assumed a working shift
for the purposes of putting together a matrix, of two ten-hour
shifts with a four-hour cycle for maintenance if it's required
normal servicing of any of the equipment. You have blowers,
pumps and other equipment that has to be serviced. There is
no reason to .assume you couldn't go on a full twenty-four-hour
a day three-shift operation. We just prepared a matrix for
the point of planning, and that was the assumptions that we
made.
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Mr. Boyland
MR. WASTLER: But you would let your incinerator
cool back down over that period?
MR. BOYLAND:. That's correct.
MR. WASTLER: You would have to purge at each
shift, then, wouldn't you?
MR. BOYLAND: No. It would be continuous
operation for twenty hours. You would not shut it down at
the midpoint/ but you would shut it down at the end of four
hours. In other words, it's completely automatic system.
Your operators are nothing more than on standby and monitoring.
So you could change shifts without shutting down the unit.
The only continuous operation would be the de-drumming and
filling the feed tank to the unit. That is not part of our
effort.
MR. WASTLER: But the point that worries me is,
if you are operating the incinerator for twenty hours, and it'3
down for four hours, it must be cooling off during that period
of time?
MR. BOYLAND: Well, you mean by that, how long
does it take to come to operating temperature? Is that your
question? .	¦ : -	'
MR. WASTLER: Well, what I am worried about is,
you were talking about unburned Herbicide Orange going out
through the system.
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MR. BOYL&ND: Let me explain how the system
operates, then. Our unit is a completely metal system. It
comes up to operating temperatures within five minutes on a
pilot fuel. You then do a transition from the pilot fuel to
the material.
At the end of the cycle, when you initiate the
stop sequence, the logic would then introduce the pilot fuel
again, cut off the herbicide flow or whatever material you are
burning, burn for some predetermined period of time to purge
the unit and flush it, and then shut off the pilot fuel.
I
The unit is metal. It would cool down rapidly and can come
back on stream in about five minutes.
MR. WASTLER: I see. Well, the VULCANUS, as
I remember, it takes about twelve hours to get up to operating
temperature, and then it can't be shut down — well, not
rapidly, so I don't quite see why the question of it suddenly
cooling off and releasing unburned herbicide is a matter of
concern in that type of operation.
MR. BOYLAND: We mentioned that is a fact
because it had not been discussed in the meeting so far. If
you shut off the feed supply to any unit and there is nothing
else being introduced to burn you have a flameout condition,
and then you start to cool. If the material is reintroduced
then and without an ignition sequence you could release
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Mr. Boyland
quantities of the material that you are burning before it
flamed up, especially in a system like the VULCANUS. It is
a firebrick system thats a long time to heat. You would have
a cold wall perhaps when the thing started up again. If you
had a plug situation where the nozzle — or the feed.pipe
pulgged and then the plug came out and it was reintroduced at
somefperiod of time later, I did not hear any discussion as to
how the system handled that condition.
. MR. WASTLER; Okay. Thank you.
MR. MOLLOYs I have one further question.
,	t
In your system are you continuously de-drumming
the Herbicide Orange or do you have a very large storage tank?
MR. BOYLAND: We can operate off of a feed
tank, and you could run a continuous de-drumming operation
and therefore illiminate the requirement for a very large
storage tank.
MR. MOLLOYs What system do you have — do you
propose? Do you propose continuously de-drumming or do you
propose a very large tank?
MR. BOYLAND: Our discussions with the Air
Force at that period of time revolved around a relatively
small feed tank on a continuous de-drumming. It would be
their decision on how they wanted to proceed. It would not
be ours.
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Mr; Boyland
MR. MOLLOY: Thank you. I have no further
questions.
Are there any more questions from the Panel?
(There was no response.)
MR. MOLLOY: Thank you.
MR. BOYLAND: Gentlemen, thank you.
MR. WASTLERs Mr. Molloy, I don't know whether
you consider it appropriate or not, but I would be very
interested to hear what Mr. Braun might have to say about this
flameout possibility, which I had not heard raised before.
MR. MOLLOYs Yes. Would one of the representa-
tives from the VULCANUS care to comment on the flameout
probability?
MR. BRAUN: I really think that this point,
though I thought it was covered in previous testimony this
morning when the operating procedure of the ship was described,
which is what we do in this vessel. We preheat the
incinerators with regular fuel that is used for the propulsion
of the vessel to the required temperature, which in this case
is 1,400 degrees Centigrade, and only then, when that level
is reached, is the fuel oilshut:off and the waste — Orange
in this case — is injected into the incinerators.
Now, if anything happens, like clogging of a
waste line, of a fuel line, and no fuel is introduced in the
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incinerators, then there is an automatic shutoff of all three
burners into that incinerator. If the waste is then to be
reinjected into the incinerators, this is not done when the
line is cleared. In that case, of course, the temperature
has gone down in the incinerators - Fuel would be reinjected
again, without any waste fceing injected until that required
temperature of 1,400 degrees, whatever the minimum for the
particular product is, is reached, and that may take up to
twelve hours, depending on how long the incinerator was out of
operation. And only then will the waste be reintroduced into
the incinerators.
MR. MOLLOYs So then you are saying that there
is an automatic shutdown in the event of a plugged herbicide
line, and that it cannot start up again then until the
temperature has been reached in the combustion chamber?
MR. BRAUNs That is correct, and that affects
all three burners in that same incinerator.
MR. MOLLOYs Is that adequate to you, Mr.
Wastler?
MR. WASTLERs I just have one additional
question.
Am I to understand that this is an automatic
control, that when the temperature drops below a certain level
the feed cuts off?
MR. BRAUN: That is correct.
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MR. WASTLER: Or if the feed cuts, off, then
the burner shuts down?
MR. BRAUN: That's thermostatically controlled.
If the temperature goes down it cuts off Automatically.
MR. WASTLER: Have you any idea how long it
would take the incinerators to cool, let's say, from an
operating temperature of say 1,450 down to about 1,200?
MR. BRAUN: From 1,400 to 1,200?
CAPTAIN BORCHERS: Two hours.
MR. BRAUN: Two hours.
MR. WASTLER: Okay. Thank you.
MR. MOLLOY: Are there any other questions?
(There was no response.)
MR. MOLLOY: Thank you, Mr. Braun.
Our last speaker today, the last one that has
indicated that they would like to speak, is Elaine W. Schwartz
of Honolulu.
MS. ELAINE W. SCHWARTZ: My name is Elaine W.
Schwartz.
I cannot list any academic qualifications,
since I have not taken even a junior high school course of
physics or chemistry. However, I am a member of the public,
and a citizen who has not been gulled into believing that I
lack the competency to make a judgement or the right to speak
on issues of public importance.
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Ms. Schwartz
You are a formidable group, and this has been
an instructive day. We have sat here today, technicians and
taxpayers, who have produced, used and paid for an abomination
against nature and other human beings. It is to our shame
that Agent Orange exists.
Will we now compound that by acting hastily
to rid ourselves of these chemicals purposely made toxic?
The ocean is a fragile and crucial environment.
The peoples of the Trust Territories are human beings to be
treasured. We do not really know our ecosystem.'s recovery
abilities. It is our one and only world, and our knowledge
is very limited.
Worse, perhaps, we don't even know if we are
capable of learning from this deadly lesson before us today
whether we will stop doing what we have been doing.
This hearing has been calm, scientific, rational.
I would like to speak for outrage and caution.
MR. MOLLOY: Thank you.
Is there anybody else who would like to speak?
MRS. MARGARET SCHMITT-HABEIN: Yes.
MR. MOLLOY: Go right ahead. If you could go
to the lecturn and introduce yourself it would help.
MRS. SCHMITT-HABEINi I introduce myself as a
grandmother of deep:concern. I have been in the peace
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movement fifty years. I was in college in World War 1.
I will never forget the dear friends that I
lost in the war in college.
I had an uncle, a Ph.D from Cragburg, who
demonstrated against World War 1. I have a cousin who went
to the moon.
I am not on this earth this afternoon.
I am awfully proud of the Air Force in taking
the lead in this issue and letting me hear this symposium.
I am delighted with what I have heard and what I have learned.
I just want to call your attention to a wonder-
ful book. I could name about four hundred in my bibliography,
but this one is a recent book. I have had it only about
four or five years. I have had five copies. This is the only
one left. I had lunch with the author, Seymour Hersh. I
think he is a correspondent now for the New York Times; a
brilliant man.
I'm not so worried about Herbicide Orange
as I am about the V-8 and some of the other things. I am
frantic in my worry about the ozone and plutonium.
Eighteen or so year's ago, with the American
Friends Service,Committee under the Quakers — I'm not a
Quaker. You know, George Bernard, Shaw gives even hell to
the Quakers in his last book called Geneva. That isn't why
I am not a Quaker. I haven't time to be a Quaker in my
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busy life, and now I have forgotten what I was going to tell
you.
But this book is a book I want you all to own
and read. And my worry about plutonium is what I wanted to
talk about. Eighteen or so years ago when I was filing for
the AFSC we demonstrated against the AEC. I have a" holy hate
for the AEC. They dropped their name of the AEC, but they
have just finished a fourth this year underground test in
Nevada.
I don't want my potatoes, and wonderful Idaho
potatoes, poisoned with plutonium. I love a good baked potato
MR. MOLLOYs 14a'am, I think you are going to
have to stick closer to the point, and we are concerned today
with the Herbicide Orange situation. Although we appreciate
you concerns about the Atomic Energy Commission, we really
have to stick to the point»
MRS. SCHMITT-HABEIN: Well, just work against
.the AEC, too..
MR. MOLLOYs Thank, you.
Are there any other people here today that
would like to speak?
MR. WASTLER: Mr. Chairman, there is one
question from the floor for the Air Force *
MR. MOLLOYs Would you read it, Mr. Wastler?
MR. WASTLER: "What will it cost the U. S.
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Government to burn versus reformulate all the Orange?n
MR. MOLLOYs. Dr. Welch, do you have a ready
answer for that?
DR. WELCHs No, I don't have a ready answer.
Let me just say relative to the cost of
burning it versus the potential impact of reprocessing, we
really do not at this point in time have a clear firm answer
on that. There are a lot of factors that would become
involved. For example, how long it might take for a reprocesso
to get ready to carry out the reprocessing, how long it would
take him to reprocess it, how much longer we might have to
restore it, how much additional transportation cost might be
incurred, ^	a wauie	ui things that would go
into arriving at tne bottom line. We are not far enough along
on that particular thing to say what the number would be.
MR. MOLLOY: Do you have any idea of the cost
of ocean incineration?
DR. WELCH? Well, I would suspect it's going
to be on the order of two to three million dollars when every-
thing is added up, by the time you look not only at the cost
of incineration per se, but the cost of de-drumming facilities,
transporting material from the storage site to the dock,
monitoring. You know, the whole thing, by the time it's all
in.
MRo MOLLOYs Thank you.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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195
Mr. Wastler, anything else?
MR. WASTLER: That was the only question.
MR. MOLLOY: If there are no additional
comments from the floor —
DR. WELCHs Could I say something before you
adjourn, very briefly?
MR. MOLLOY: Go right ahead.
DR. WELCH: We would like to express our
appreciation to the Environmental Protection Agency and their
Panel fortthe gracious way they held this hearing, and would
like to second the comments that you made this morning to the
gentleman from the State of Hawaii relative to the accommoda-
tions. I think they are outstanding.
MR. MOLLOY: Thank you. With no further
comments; then this hearing is recessed until Monday in.
San Francisco.
(The hearing was thereupon adjourned, at
3:40 p.m., to be resummed at San Francisco on Monday, April
28, 1975.)
oOo
Reported by:
Reginald D. Knipes, C.S.R.
C. RAY BEEBE & ASSOCIATES
HONOLULU, HAWAII

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