COPY
ENVIRONMENTAL PROTECTION AGENCY
In the Matter of the Hearing on
Disposal of HERBICIDE ORANGE
Monday, April 28, 1975
San Francisco, Ca.
Wm. E. Hendcrscheid & Associates
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
41 Sutter Street, Suite 312
San Francisco, Calif. S4104
TELEPHONE 433-77M
1121 west California Street
mill valley, Calif. 94901
TELEPHONE 383-1727

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ENVIRONMENTAL PROTECTION AGENCY
In the Matter of the
Hearing on Disposal of
HERBICIDE ORANGE
Conference Room A# Second Floor
100 California Street
San Francisco, California
Monday, April 28, 1975
The abcve-entitied matter came on for hearing at
MR. KENNETH BIGLANE, Director of the Division, of 011
and Special Materials Control,
EPA, Washington, D.C.
DR. JAKE MACKENZIE, Chief, Pesticides Branch, EPA',
Region, IX, San Francisco.
DR. HENRY ENOS,	Director of Equipment and
9:30 o'clock a.m.
BEFORE:
BRYAN MOLLOY, Chairman
PANEL MEMBERS:
Techniques Division, Office of
Research and Development, EPA
Washington, D.C.
REPORTED BY:
DON BISCHOFF
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 7766
MARIN COUNTY
393.1727

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Testimony:
Mr.
Biglane
Mr.
Rogers
Or.
MacKenzie
Dr.
Welch
Mr.
Boyland
INDEX
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E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
493 .7766
MARIN COUh
383 - 1727

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PROCEEDINGS
CHAIRMAN MOLLOY: Good morning.
My name 1s Bryan Molloy, Acting Deputy Assistant
Administrator for Water Enforcement, Environmental Protection
Agency, Washington, D. C.
I would like to open the hearing today on the
question of the disposition of Herbicide Orange.
1 would like to Introduce the panel.
On my left Is Mr. Kenneth Blglane, Director of the
Division of Oil and Special Materials Control of the
Environmental Protection Agency, Washington, D. C.
On my Immediate right 1s Dr. Jake Mackenzie, Chief,
Pesticides Branch, Environmental Protection Agency, Region
IX 1n San Francisco.
And on my far right 1s Dr. Henry Enos, Director of
the Equipment and Techniques Division, Office of Research
and Development, Environmental Protection Agency, Washington,
D. C.
I would like to now recognize Mr. Blglane.
Mr. Blglane?
KENNETH BIGLANE
appeared as a witness and testified as follows:
MR. BIGLANE: Thank you, Mr. Chairman.
I wanted to Identify for you the operating program
for Ocean Dumping.
E. HENDERSCHEID Be ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIE8
SAN FRANCISCO
433 - 7796
MARIN COUNTY
363-1727

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As the Chairman stated, I am the D1v1son Director
for the Division of 011 and Special Materials Control, and 1t
1s within this group that we have ocean dumping, the ocean
dumping program 1n addition to the spill response program,
responses to spills of oil and hazardous materials, the
Environmental Protection Agency Impact statement for water
program operations, the Environmental Protection Agency's
Involvement 1n IMCO, which means the Intergovernmental
Maritime Consultative Organization, also has to do with
bilateral agreements with Canada and 1n the foreseeable
future with Mexico.
My purpose 1n bringing these facts to your
attention, simply that the Dlvlson 1s Involved rather
heavily 1n the ocean, as well as 1n Inland waters.
I, additionally, asked for this opportunity to repori
to you last week on Mr. Wastler, who.is with us today,
Chief of the Marine Protection Branch within the Division,
and I received about an hour and a half of very penetrating
questions from joint sub-committees of the House Merchant
Marine and Fisheries Committee, 1n Washington on the subject
of ocean dumping.
This committee, as you know, 1s quite concerned
about the practice of ocean dumping 1n this country, and are
additionally concerned about the programs which the
Environmental Protection Agency conducts, the Coast Guard,
. E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES

SAN FRANCISCO	MARIN COUNTY
433 - 7766	363-1727

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NOAH, and the Corps of Engineers.
As I read the congress' feelings on this, they are
quite Interested 1n having as much reprocessing of wastes,
conserving of energy 1n this vein, and In addition to being
quite concerned about the regulatory aspects of the entire
ocean dumping program.
Again, my purpose 1n relating this 1s to Indicate
that since the passage of the Ocean Dumping Act, this
committee has exerted very close observations over the
federal agencies that conduct ocean dumping regulatory
programs 1n this country, and we receive their message very
loud, very clear, and what we do we want to become a matter
of detailed public record. And that 1s one of the reasons
for this public hearing. Thank you, Mr. Chairman.
CHAIRMAN MOLLOY: Thank you, Mr. Blglane.
This 1s the second session of this hearing. The
first session was held on Friday 1n Honolulu, and we expect
that there will probably be one more session at a later to-be-
named location In time.
The purpose of the hearing 1s to receive Information
on the application of the United States Air Force to dispose
of approximately two and one-quarter million gallons of a
chemical known as Herbicide Orange, by Incineration at sea.
The A1r Force has applied to the Environmental
Protection Agency for a permit pursuant to the Marine
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433.7766
MARIN COUNTY
389-1727

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Protection Research and Sanctuaries Act of 1972 to burn the
material about 120 miles west of Johnston Island 1n the
Pacific.
The Environmental Protection Agency has reviewed the
Information made available by the A1r Force, and other
Interested parties, and has made a tentative determination to
Issue a research permit to the A1r Force that would allow
4,200 metric tons of the material to be Incinerated 1n the
ocean under certain controlled conditions.
The conditions as set forth 1n the Environmental
Protection Agency's tentative determination are as follows:
1; The incineration will take place within the
disposal site, the coordlnants of which are set forth 1n the
Summary of the Application.
2.	The emission rates will not be 1n excess of
one-tenth of one percent of the total.
3.	The Herbicide Orange will be removed from the
storage drums and loaded on the Incineration vessel 1n such
a manner that no TCDD escapes to the environment In measurable
quantities, and the process of removal of Herbicide Orange
shall employ the best available technology.
4.	The drums from which the Herbicide Orange 1s
taken will be triple rinsed with solvent prior to disposal or
otherwise cleaned to an equal degree by jet rinsing, and the
rinses will be added to the wastes to be Incinerated.
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 7766
MARIN COUNTY
383 - 1727

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5.	The carrier will maintain a combustion
temperature 1n each Incinerator of at least 1400 degrees
Centlgrade.
6.	The feed rate of the Herbicide Orange Into the
combustion chambers will be as low as possible, and not 1n
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 monitoring
procedures as are requested by the Environmental Protection
Agency.
A final determination will be made following this,
and any subsequent hearings, and the receipt of public
comment on the proposal.
A major consideration before a permit can, be Issued
1s whether there are any other feasible alternatives to the
Incineration.
There will be statements made today on this
conslderatlon.
At the hearing 1n Honolulu on Friday, we heard
testimony from the A1r Force on the Incineration Itself, the
selection of the site, the monitoring provisions, and the
methods of removing the material from the drums.
Testimony was also received from representatives of
E. HENDERSCHEID ft ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
4)3 - 7764
MARIN COUh
389 - 1727

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Micronesia and environmental groups which tended to oppose the
location of the site.
Additionally, testimony was received from the owner
of the Incinerator vessel, the VULCANUS, and the Marquardt
Corporation. Today's hearing will not repeat that testimony.
Our proposed method of operating today will be for
several opening statements by the Environmental Protection
Agency, followed by a statement from the A1r Force, and then
opening up the hearing for comments and questions from the
floor.
The rules of today's hearing are as follows:
This 1s an Informal hearing and there will be no
cross-examination.
Written questions from the floor should:be handed to
one of the ladles by the door, and we will try to have all
germane questions, the answers to which will be given,
depending upon the restraints of time.
2.	Everybody should Identify themselves by name and
location.
3.	The orders of speakers, as far as practical, win
be, one, the Introductory remarks by the Environmental
Protection Agency, and then the A1r Force presentation, and
then we will take comments from any elected officials,
federal, state and local government, and followed by federal,
state and local agencies, and then groups and finally
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 776C
MARIN COUh
383 - 1727

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Individuals.
If anyone has a time problem, they should make this
problem known on the registration card, so we can shift the
order, 1f necessary.
If possible, we would appreciate 1t If statements
were made 1n writing, and then summarized when speaking. We
will take a 15-mlnute break at approximately 11:00 o'clock In
the morning.
A transcript of today's hearing 1s being made.
If written statements are available, please give a
copy to the court reporter^ and also to the panel, 1f you
have that many copies.
I would like to now call upon Mr. James Rogers, an
attorney with the Office of General Counsel of the
Environmental Protection Agency 1n Washington, O.C., who will
summarize the law under which we are working.
Mr. Rogers?
JAMES ROGERS
appeared as a witness and testified as follows:
MR. ROGERS: My name 1s J1m Rogers. I am a lawyer
with the Office of General Counsel 1n Washington.
I would like to very quickly give an outline of the
law as the staff used 1t, the law that would be applied 1n
this matter.
The basic statute under which this hearing 1s held,
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 7766
MARIN COUIS
363 - 1727

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and under which a permit would be Issued 1s the Marine
Protection Research and Sanctuaries Act of 1972. This Act
was passed 1n October of 1972, and amended 1n March of 1974,
so as to be consistent with the prevention of marine
pollution by dumping of wastes and other matter.
This 1s the second ocean Incineration matter that
has come before the Environmental Protection Agency.
The first application was received from the Shell
Chemical Company and related to the Organo-Chlorlne wastes
generated by the Deer Park, Texas, facility.
That application resulted 1n the Env1ronmental
Protection Agency's granting two research and one Interim
ocean disposal permits.
Those permits allowed the incineration of those
wastes for roughly three nine-day periods.
The reports that have been written by the Shell
Chemical Company, and by the Environmental Protection Agency
as a result of that experience have been entered Into the
record 1n this case.
It may be useful for me, quickly, to mention four
or five of the criteria that the Act sets out as matters that
must be considered by the Environmental Protection Agency
before 1t can grant a permit to dispose of matter In the
oceans.
These criteria are contained 1n Section 102A of the
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIE8
SAN FRANCISCO
433 - 7799
MARIN COUNTY
383.1727

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Act. In that section the Administrator Is required to
consider the 'heed for the proposed dumping, the effect of
such dumping on human health and welfare, Including economic,,
esthetic, and recreational values; the effect of such dumping
on fisheries resources, plankton, fish, shellfish, wildlife,
shorelines and beaches. The effect of such dumping on marine
ecosystems, particularly with respect to the transfer,
concentration and dispersion of such material and Its by-
products through biological, physical and chemical processes;
potential changes 1n marine ecosystem diversity, productivity,
and stability, and species and community population dynamics.8
As you can see, the Act 1s quite spedf1cs and I
think you will also see that the presentation by the Air
Force 1n many ways attracts the consideration that Congress
has required the Environmental Protection Agency to make
before granting an ocean disposal permit.
The first Is a need for the ocean dumping, and this
leads to the alternatives that may be available to show ocean
consideration.
One of the considerations, at least, viewed by the
staff 1s whether 1t 1s more environmentally compatible to
reprocess Herbicide Orange to make usable commercially
valuable pesticides.
I think you will hear some pertinent testimony by
both EPA and the A1r Force on that matter.
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
431 . 7766
MARIN COU*
383. 1727

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There Is a novel Issue as viewed by the staff, and
that Is whether the product of Incineration Is a chemical or
biological warfare agent, and 1f so, whether this fact would
prohibit the Environmental Protection Agency from granting a
permit.
The relevant section.of the Act says: "Except 1n
relation to dredged material, as provided for 1n Section 103
of this title, and In relation to radiological, chemical and
biological warfare agents, and high-level radioactive waste,
for which no permit will be Issued, the Administrator will
issue permits . .
The staff has made a tentative determination that
the very efficient Incineration and destruction of Herbicide
Orange on board the VULCANUS would not be In violation of the
Marine Protection, Research and Sanctuaries Act. Thank you.
CHAIRMAN MOLLOY: Thank you, Mr. Rogers.
I would like now to ask Dr. Jake MacKenzle to enter
Into the record and summarize an Environmental Protection
Agency statement on disposal of pesticides and herbicides.
I emphasize that Dr. MacKenzle 1s not the author of
this document, but he has kindly consented to enter 1t Into
the record and has summarized It.
Dr. MacKenzle?
DR. JAKE MacKENZIE
appeared as a witness and testified as follows:
E. HENDERSCHEID ft ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 . 7796
MARIN COUNTY
389.1727

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DR. MacKENZIE: Thank you, Mr. Chairman. I would
like to submit this statement for the record of this hearing.
I am today representing both Mr. Paul DeFalco,
Regional Administrator, Region 9, and Deputy Assistant
Administrator Edward Johnson, 0PP8 Washington, D.C.
The Environmental Protection Agency's disposal
policy for pesticides has been set out formally 1n regulations
promulgated under Section 19 of the Federal Insecticide,
Fungicide and Rodundlclde Act as amended.
This policy statement may be summarized as follows:
"In considering disposal techniques, the first
preference should be given to procedures designed to recover
some useful value from excess pesticides and pesticide
containers.
"In light of current shortages of critical
agricultural chemicals, Including the 24D component of
Herbicide Orange, and consistent with the need to conserve an<
reuse our natural resources, this policy has been followed
with respect to disposal of Herbicide Orange.
"To date, the following milestones should be noted:
"The first of these milestones concern consideration
of the reformulation option.
"First of all, manufacturers of Herbicide Orange
were not willing to take that material back.
"Secondly, the Air Force could not dispose of
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIE8
SAN FRANCISCO
433 . 7766
MARIN COUNTY
383 - 1727

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Herbicide Orange by sale to reformulators because, firstly,
allowable levels of dloxln would only permit disposal of 30
percent of the stock.
"Secondly, reformulation of the remaining 70 percent
of the stock, which contained high levels of the dloxln,
would present an unacceptable hazard to the public health.
"Therefore, 1t was felt that reformulation could not
be considered to be a feasible^option.
"Having disposed of that option, the next step was
to consider reprocessing.
"The Office of Pesticides Program was at the time of
the decision to consider reprocessing 1n possession of general
Information which Indicated that a potential for reprocessing
did exist which might destroy dloxln In the process or
concentrate 1t Into readily disposable wastes.
"Once reprocessing came under consideration, the
A1r Force, through the Defense Supply Agency, placed an
offering for bids to chemical processors to purchase and
conversion of stocks of Herbicide Orange.
"At this time, with regards to the reprocessing,
there have been three process, descriptions submitted In
support of bids. They have been evaluated by the Environ-
mental Protection Agency and the Army Environmental Hygiene
Agency technical experts.
"One process description appears particularly
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 . 7766
MARIN COUNTY
303 - 1727

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promising. One company proposes to destroy, vla ,a selective
chemical technique, the teratogen 2, 3, 7, 8-tetrachloro-
dlbenzoparadloxln (TCDD) present as a manufacturing impurity
In Herbicide Orange.
"The company plans, firstly, to hydrolyze the
N-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
N-butanol.
"Separation of the acids from N-butanol will be
accomplished by physical methods Involving solvent extraction
and distillation. The 2, 4-D and 2, 4, 5-T acids produced
will contain less than 50 ppb TCDD, far superior in quality
to presently available similar registered herbicide
formulations. Spent organic solvents containing less than
50 ppb TCDD will be incinerated 1n an approved Incinerator.
Acqueous waste streams containing less than 225 ppt TCDD will
be trickled through coconut charcoal, before treated effluent
containing no detectlble TCDD (less than 10 ppt) 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 experts above mentioned, the
processes do appear promising:
1. In aspects of 24D and 245T recovery, and also
as to the satisfactory destruction of the dloxln contaminant.

VM. E. HENDERSCHEID & ASSOCIATES	san Francisco	marin county
CERTIFIED SHORTHAND REPORTERS	HUH	433 £m	SM ,727
DEPOSITION NOTARIES

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"However, there were sufficient questions related to
dloxln disposal and to 1n-process destruction to warrant a
mandate for pilot studies, and these pilot studies would go up
to 150 gallons of the Herbicide Orange per processor.
"These studies would consider a confirmation of
process claims, study of the effect of scale up on process
efficiencies, close evaluation of dloxln destruction and
disposal, and finally obtaining an accurate estimate of
possible environmental contamination.
"Obviously, a key Issue here Is the timing of these
pilot studies.
"It 1s assumed by the Office of Pesticides Program
that a period of six months would be ample to allow
collection of such data.
"All processors Indicate that upon acceptance of a
bid, reprocessing could commence Immediately.
"Certain other considerations will have to be
reviewed while the pilot studies are 1n process.
"First of all, assurance of quality control over the
dloxln content of the reprocessed commercial products;
secondly, probable levels of dloxln In wastes generated by
reprocessing, and, thirdly, consideration of safe handling,
transportation, storage and drum disposal associated with the
processing of Herbicide Orange; and finally, assuring of
proper registration of end use product.
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIE8
SAN FRANCISCO
433 - 7766
MARIN COUfs
363 - 1727

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M5. Recovery of useful value from pesticides 1n 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 herblcldal value from the 2, 4-D and 2, 4, 5-T
components with concurrent destruction of the teratogenic
dloxln contaminating component appear promising.
"Pilot plant studies to accurately evaluate the
chemical processes Involved 1n reprocessing are required at
this time. They probably can be completed 1n six months.
"EPA believes the reprocessing aspect 1s worthy of
additional serious consideration, and If feasible 1t may well
be preferred to ultimate disposal.
"It might well, 1n light of current estimates,
return 2, 4tD and 2, 4, 5-T to commercial channels with lower
dloxln content than that currently manufactured."
Thank you, Mr. Chairman.
CHAIRMAN MOLLOY: Thank you, Dr. MacKenzle.
I would like to now call on Dr. Billy E. Welch,
Special Assistant to Environmental Quality to the Secretary
of the A1r Force, who will discuss the proposal from the
A1r Force's point of view.
Dr. Welch?
DR. BILLY E. WELCH
appeared as a witness and testified as follows:
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 7766
MARIN COUNTY
383-1727

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DR. WELCH: Thank you very much, Mr. Chairman.
Ladles and gentlemen.
It 1s a pleasure to be here this morning to discuss
this particular problem with you.
Our approach will not be to present the detailed
testimony that was presented 1n Hawaii on Friday, but to
summarize this 1n strictly an opening statement.
I would like to briefly recount some of the history
regarding orange herbicide and summarize Air Force actions
relating to disposal of this material 1n order to put this
problem Into the proper perspective.
First, we should recognize that herbicide orange 1s
an equal mixture (50:50'by volume) of two commercially
available agricultural products - namely 2,4,D1ch1orophenoxy-
acetlc acid and 2»4,5-Tr1chlorophenoxyacet1c acid - or as we
commonly refer to them - 2,4-D and 2,4,5-T. Herbicide Orange
consists of what 1s chemically called the normal butyl esters.
There are products registered by the EPA for use 1n 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 1s nearly Identical,
In April 1970, the U.S. Department of Agriculture,
HEW and the Department of the Interior suspended certain uses
of 2,4,5-T. Concurrently, the Department of Defense
suspended the use of orange herbicide. As a consequence of

VM. E. HENDERSCHEID & ASSOCIATES	apm	SAN paANCISca	MABIW COIII>ITV
CERT.F.ED SHORTHAND REPORTERS	RSgJ	SM ,727
DEPOSITION NOTARIES

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the suspension of some uses of 2,4,5-T, the U.S. Air Force,
acting as the agent for the Department of Defense, was left
with 1.5 million gallons of Herbicide Orange 1n Vietnam and
0.6 million gallons of Herbicide Orange at Gulfport,
Mississippi.
Following that suspension 1n April 1970, In
September 1971, the DOD directed the A1r Force to return this
material from Vietnam and to dispose of It In a .safe,
efficient manner.
Following that particular direction, the A1r Force
published a draft environmental statement 1n January 1972,
stating that Incineration appeared to be the best way of
resolving the problem, and that we had numerous types of
studies under way.
Due to the fact that these studies were under way
and had not yet been completed, 1t 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 1n
Vietnam was moved In April 1972 to Johnston Island for
storage, pending a final disposal decision.
Since that point 1n time, the A1r 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
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 7766
MARIN COUNTY
363-1727

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efforts has been documented 1n the environmental statement
which 1s 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
laboratory tests, to drum size tests conducted for the A1r
Force at a facility on the West Coast. The results of these
studies Indicated that the butyl esters of 2-4-D and 2,4,5-T
acids are destroyed between 550-700 degrees Centigrade, and
the tetrachlorod1benzo-p-d1ox1n or the TCDD 1s destroyed
between 980 and 1000 degrees Centigrade.
In addition to the Incineration studies, we looked
at the potential for use. This particular material 1s not a
registered herbicide; and, for 1t to be utilized, It would
have to be registered or reprocessed Into some other
material that would be useful.
At this point, somewhere 1n 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 1n terms of acceptability for use, and Indeed the
EPA had planned to hold public hearings 1n June 1974 to
evaluate the overall use of 2,4,5-T 1n this country. These
public hearings were subsequently cancelled with no decision
being reached due to the lack of sufficient Information on
which to base decisions.
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIE8
SAN FRANCISCO
433-7766
MARIN COUh
303-1727

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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 complete
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 reported they did not have the
capability nor the interest to reprocess the material.
Im May 1974, we published a draft environmental
impact statement in which we stated that incineration appears

VM. E. HENDERSCHEID & ASSOCIATES	SAN FRANCISCO	marin county
CERTIFIED SHORTHAND REPORTERS	PGiffl	M3-77M	3M 1727
DEPOSITION NOTARIES

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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 incin-
eration as 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 impact
statement, the EPA position was that incineration on the
high seas was not covered by the Ocean Dumping Act. Over
400 copies of the draft environmental impact statement
were distributed. An LO-2 rating was given to the EPA.
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 usual
ocean currents and the wind move from Hawaii to Johnston
Island and, thence, away from Johnston Island and from Hawaii.
WM. E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 776©
MARIN COUNTY
383-1727

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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 & 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 connection
with processing the Air Force application. The issues,
which the public was asked to comment upon, were:
1.	Whether feasible alternative methods of
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 following
incineration.
3.	Whether incineration of Herbicide Orange at
high combustion efficiency is compatible with 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.
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 7760
MARIN COUNTY
383-1727

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6. Whether the disposal site requested by the
"Air Force is an appropriate location for incineration
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 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. 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 2^4
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 .7766
MARIN COUNTY
383-1727

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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 following incineration. Within the meaning of the
Marine Protection, Research & 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 point: 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 incin-
eration 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
E. HENDERSCHE1D & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 -77««
MARIN COUNTY
303 - 1727

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be reasonably anticipated that any constituent of herbicide
orange will be detected in the mixing zone of the ocean
environment.
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 confident 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; tht the teflon line, when
properly heated, will transport the constituents from the
stack to the benzene impingers; and that the train will
essentially pick up 100% of the constituents entering the prob
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
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 . 7766
MARIN COUNTY
363.1727

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as to its capability to monitor for TCDD, 2,4,5,-T and 2,4-D
in the immediate marine environment during incineration.n
I emphasize "during incineration". There are no instruments
that we know of which will allow monitoring 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-D, 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
to detect these constituents 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 EPA to issue a permit for incineration of a
shipload of herbicide orange, and by the 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 conclude)
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
E. HENDERSCHEID a ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 7766
MARIN COUNTY
383 - 1727

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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 proposed designatio
of the site, stated that the proposed site is typical of
tropical open ocean areas which are unproductive 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
reason why such an area would not be suitable for ocean
incineration.
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.
My point in mentioning this is to indicate to you
M. E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS	Ru*]	MARIN COUNTY
DEPOSITION NOTARIES	KB	433 - 7766	383 - 1727

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Ithat this particular public hearing we are having today iB not
to discuss a problem that just surfaced, not to discuss
something that the public ha3 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 hearing, there were a
number of points addressed which are expected to be permit
requirements. Each of these will be mentioned and commented
upon.
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 is also a situation which bears discussion.
While we are confident the research burn will demonstrate tha :
the above limits can be achieved—what if it does not? Of
what significance would it be? Let me run over a few figures,
Our herbicide has an average concentration of 2 ppm of dioxin.
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 776C
MARIN COUNTY
383 - 1727

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For our some 24,000,000 pounds of herbicide, we calculate
that about 48 pounds of dioxin is to be incinerated. In
complying with the conditions 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 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 concentration 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 depositee
in the middle of the Pacific, in an area known to be unproduct
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. This material
is distributed over approximately; five million acreas at
a rate of about 50 micrograms per acre...". Again we see tha :
. E. HENDERSCHEID ft ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 7766
MARIN COUNTY
383 - 1727

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the permit restrictions will limit only the amound deposited
on an unproductive area to only four micrograms. Here again,
my point is that, while we will 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 larg<
the amount per acre would be even less,
I believe the next point regarding removing the
orange from the drums and loading of the vessel in a safe
manner has been covered, as has the requirment 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 de-drumming
and rinsing. These permit requirements will be no problem
and have already been incorporated in our planning documents.
Drums will be rinsed with a pressure spray of diesel oil
and will be burned.
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 application thatrelectric
waste pumps will not operate to feed herbicide on to the
incinerator 'burners of that combustion chamber in which the
temperature falls below 1400 degrees C. If such a situation
occurs, the incinerator malfunction is corrected, and the
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 - 7766
MARIN COUNTY
303 - 1727

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combustion chamber temperature is returned to above 1400 degre
C with conventional fuel before any herbicide is reintroduced.
Alsoithe burners for a particular incinerator are automaticall
shut down if any of the following conditions fall below
preset levels: the air feed pressure to a burner, the herbicid
feed rate to a burner, and the 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 require-
ment 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 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.
. E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES

SAN FRANCISCO	MARIN COUNTY
433-7766	383.1727

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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 good 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.
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 storeage 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-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 continues and
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, continue
E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
SAN FRANCISCO
433 .7766
MARIN COUNTY
383-1727

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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 Island.
Our position has been laid out in the Environmental Impact
Statement. It is there for anyone to study, if they so care
to; and we think that the solutions are fairly self-evident.
We see the need to reach a conclusion on the option of re-
processing.
At the time the ocean incineration technique came tc
our attention, reprocessing alternatives seemed technically
and legally infeasible. We have always recognized that
alternatives that returned the material'to legal and producti\
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 pilol
plant scale and on an expedited basis.
There "are many questions—technical, legal, economi<
and political—to be explored with respect to reprocessing.
At the moment, we cannot say whether all or any of the materi<
tM. E. HENDERSCHEID & ASSOCIATES	EMI	....	.. „
CERTIFIED SHORTHAND REPORTERS	Mud	43? 7»«i	l« ,«TV
DEPOSITION NOTARIES	383-1727

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can be reprocessed. We recognize that, under the tentative
decision, we have the burden of demonstrating that there are
no technically feasible and; environmentally sound land-based
alternatives to ocean incineration. To allow sufficient time
for this information 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 the applicant. 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 expect this to be too long a period
hopefully no more than ninety days. Let me underline that th<
Air Force is most anxious to proceed with disposal of this
material in an environmentally acceptable manner at the earlL
possible date. We understand that.the 180-day decision
period will be suspended until the third hearing is held.
This concludes the Air Force presentation.
We will pursue this some vigor in an attempt to
bring this matter to a head so that disposal either by
destruction or by reuse can become a reality and this
matter resolved. Thank you.
CHAIRMAN MOLLOYt Thank you very much, Doctor
Welch,
I had a few questions.
I realize that some or all of these points are
E. HENDERSCHEIO Be ASSOCIATES
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probably covered very well in the EIS or other documents
that are on the record, that is the environmental impact
statement/ but I wonder if you would, either you or members
of the Air Force team try to answer them today.
The first question is: How long will it take you
to analyze the samples and get the results from the monitoring
program on the vessel if you go to ocean incineration? That
is from the time you take the samples from the vessel to
the time you get a result?
DR. WELCH: Our concept and approach to monitoring
the stack gases of the VULCANUS would be to sample approximate
three times per day, gather the sample in the collection
train that we have discussed, keep the sample on board the
VULCANUS until the termination of that shipload of material,
take the sample at Johnston Island, concentrate it down,
move it by air to our laboratory, environmental health
laboratory at Kelly Air Force Base, San Antonio, Texas.
So depending upon whether you are talking about
the first sample that was taken at the start of the burn,
or the last sample, it would be roughly a nine-day period,
there.
Following that last sample, we would anticipate
that it would be something in the order of maybe five days
per data.
CHAIRMAN MOLLOY: Dp you know the total time frame
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that we are discussing here from the time that the vessel
would pick up the material in Gulfport, take it to the
Pacific, incinerate all the material, and then return to
Johnston Island? Do you have a feeling for the total time?
DR. WELCH; Well, are you alluding now to the entire
2.3 million gallons?
CHAIRMAN MOLLOY: Yes.
DR. WELCH: Roughly 27 days of burn time and then
the steaming time from Gulfport to Johnston Island—
MR. MERRILL; It will take about 90 days.
DR. WELCH: A total of 90 days, is the estimate.
We can break that down for you.
CHAIRMAN MOLLOY: No. That is fine.
Could you indicate any potential problems that
you see that if instead of burning one third of the material,
roughly, on the initial burn, you burn, say, only ten percent
of it, and then analyze the sample to determine whether or
not you were getting the efficiency you had anticipated, and
then, either, assuming it was acceptable, then continuing
the burn? Can you anticipate any problems from that approach/
DR. WELCH: Well, if you approach it in the context
of our permit application, which speaks to incineration of
the material west of Johnston Island, which is west of Hawaii
and I presume, from San Francisco nobody knows where Hawaii ii
It is a long ways away.
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Our concept was that the vessel which is based in
Holland, would call at Gulfport, Mississippi, load the materie
that is stored there, steam to Johnston Island, destroy that
load, and then load up approximately 2 more loads, which woulc
take care of the products stored on Johnston Island.
Now, if she called at Gulfport, and picked up 10
percent —
CHAIRMAN MOLLOY: No. I would anticipate they woulc
pick all of it up and only burn 10 percent or so.
DR. WELCH: That might be a possible thing to do,
though my logestician friends tell me that you don't load
something iip if you don't know where you are going to put it
down.
We have not given a great deal of thought to that
due to the distances involved.
CHAIRMAN MOLLOY: Finally, again, I know, though it
is in the Environmental Impact Statement, could you outline
some of the pros and cons that you found of the onland
incineration versus the incineration in the ocean?
DR. WELCH: Yes. We looked at the question of on-
land incineration and most of the — initially, we had hoped
that a commercial incinerator in the business of destroying
commercial waste could be contracted to do this particular
job for us.
It appears that those companies are located in rath«

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congested areas, and this raises certain concerns about safety
and this type of thing, bringing it into a given area like
that.
WS also express some concern that ,if the incineratio
were not very very good, on the order of 99.9 or greater, that
you conceiveably could get herbicide damage due to some
very sensitive plant material that could be growing.
For example, we looked at one place as a potential
to do a test, and we looked around there and there was
tomatoe plants and bean plants and things like that, which
said to us that that would not be the best place to either
do a test burn or to do that type of thing, since plant
material would be sensitive to it.
And that combined with the emotional aspects of
"don't try it in here and do it somewhere else, but don't
do it where I live", or something like this, led us to
believe that the best way of resolving the problem was to
do it in a remote area.
After all, if one was available, and the ocean-goinc
incineration concept does give you a remote area in which to
do the job, then why not take advantage of it?
CHAIRMAN MOLLOY: What about the proposals that
burn it on land at Johnston Island?
DR, WELCH: Well, we considered Johnston Island to
be a remote area, initially, to begin with, point one, and
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point two, it .has no civilian population as such there.
It is strictly a contract operation.
It is a U. S.-owned island. So you know it is an
industrial site,' so it could be done there.
The herbicide is stored at the downwind portion of
the island. So you would have little difficulty or little
problems with controlling the plume back up over the populated
area.
And due to the fact that we are downwind, we would
not anticipate that it would have any adverse impact on the
plant material that is there.
CHAIRMAN MOLLOY: So that is still an open option.
Is that correct? You are still considering that or do you
feel the ocean incineration is better?
DR. WELCH: Well, our analyses indicated that the
potential for environmental impact was less in ocean considers
than on the island.
Number one, you've got a lagoon that is there that
is reasonably productive in terms of sea life, said, number
two, right off of the end of the island where the herbicide
is stored, and where the incineration would take place, there
is a restructure there that some of our technical advisors
felt that could be adversely affected by the continuous hydro-
chloric acid plume encountering the water at that particular
spot, since it would be a stationary incinerator, and it turno
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out that it would be an area that we would predict not a
significantly high, but the highest concentration of hydro-
chloric acid to hit the water at that point.
So we felt, plus it is a small island, so it is
roughly a square mile, 640 acres, and the approach that we
looked at with the Marquardt Corporation, for example, using
a number of their sudden expansion burners ganging together
would be fairly noisy, and this would be something going on
continuously without a lot of room getting away from us.
So we just felt it was better all around to do it
on the high seas.
CHAIRMAN MOLLOY: Thank you. Any other questions
from the panel?
Mr. Rogers? No? Thank you.
At this time I would like to enter into the record
a letter dated April 23, 1975, addressed to Mr. Paul DeFalco,
Regional Administrator, United States Environmental Protection
Agency, Region IX, San Francisco, California.
It is from Mr. Kenneth S. Camlet, Counsel to the
National Wildlife Administration.
Mr. Camlet discusses the alternative of reprocessinc
the herbicide orange, and sets out several considerations that
he believes are important and should be considered by the
Environmental Protection Agency before any decision is made.
He then states that "if the indicated steps and
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precautions are taken by the Environmental Protection Agency,
it is possible that reprocessing and reuse of the Agent Orange
can be carried out safely.
While we would not endorse, we would not opposo this
course of action under tho3© circun^stances.
On the other hand, w© could endorse ocean
incineration carried out in the scanner we have previously
suggested as environmentally sound."
Ha then finally suggests that, "unless the
Environmental Protection Agency decides that the risk of
reprocessing are unacceptably great, a course it should
consider seriously, it might b© appropriate to recess the
Konolulu-San Francisco hearings until pilot plant testing can
be completed on the reprocessing alternative."
Appended to Mr. Camlet's letter are the positions
taken by the National Wildlife Federation previously on the
proposal to incinerate herbicide orange."
I have only person who has indicated a desire to
speak today.
If there ..are any others, please fill out on© of the
registration cards.
The one person who has indicated he would like to
spealc is Mr. J. L. Eoyland, Deputy General Manager Environment
Systems Division, of the Marquardt Corporation.
Kit. Boyland?
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MR. BOYLAND: Do you wish to go into that now
or are you going to Bake the same presentation that you
mads in Hawaii?
CHAIRMAN MOLLOY: Wo. VJg are not. We have just
completed our presentation, and so you are the only person
who has indicated he would like to speak.
PRESENTATION BY MR. JAMES L. BOYL&ND,
Deputy General Manager,
Environmental Systems Division
Marquardt Corporation
MR. BOYLANDi My name is James L. Soyland, X am
Deputy General Manager of the Environmental SystemsqDivision
of the Marquardt Corporation.
We are the company that did the pilot incineration
work for the Air Force to establish parameters.
Our statement was read and presented into the
record, and so I am going to hit only the key points o£
that statexaent, and will not go through it again.
Part of your comments are incorporated into the
comments section on the Environmental Impact Statement.
Basically, which has not come up in this meeting,
is that our burner ia not a typical commercial incinerator.
It works on a different principle, but it is a
cosmarcial unit that is in use today, but it does satisfy
the terms of1 the ircpact statement, in that it is a commercial
incinerator,.
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Zt was mentioned, the governor°e representative
made a statement in Hawaii„ that he would like the ineinerati
process to be scrubbed„
Our aysteia can incorporate a scrubber if it is
mounted on Johnston Island.
Dra Welch commented about the noise application of
th® land-based unite
I would point out that such a unit is mounted on
a pink bake oven in th® Ford Motor Company at Louisville«
Kentucky and operates within the noise limits0
Z believe that our section in th© report dealing
with noise was on&tted from the appendix report in the
Environmental Impact Statement; but I think you will find
that it falls within the guidelineso
It will be acceptable from a noise level,
BAsically, our position on the incineration on the
VULCANUS „ is simply thiss we have no position at this point
asi.to whether it is a good or bad idea*
Our only statement is that the burn be limited to
a reasonable amount of material that will allow the testing
to be completed before a complete shipload is incinerated.
Dr. welch mentioned this ntoming it would take
about 9 dayso We constant®d in our published statement that
one tank, either the smallest to the largest; be used for
a trial purpose, and that is all that would be loaded on the
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ship until the results are known.
Xf the unit does check out to be 99.9 percent
efficient, or whatever acceptable limit? then we have no
objections»
It was stated earlier in the EPA meeting that the
ship cannot be off-loaded, therefore to take on a whole load
and then run a small test* If you find out that it didn't
work as well, you then have a problem; in fact, you have a
shipload of material.
1 do not have any further comments at this point
to make. I thank you for this opportunity to speak.
CHAIRMAN MOLLOY: Thank you, Dr» Boyland.
Are there any questions from the panel?
Yes, Or. Enos?
DIU.ENQSs In evaluating a system like the
VULCANU3, our concern, of course, has been primarily focused
onr the TCDD emissions, because this represents one of the
snost tonic organic synthetic compounds man has ever produced.
And in so doing, and considering the temperature
requirements for complete destruction of that particular
molecule, we have spent a good deal of time concerning our-
selves with the* efficiency of collecting the vapors of the
material from'the is tacks.
Do you have any other suggestions relative to the
monitoring of the stacks or would you be satisfied with data
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which addressed that particular compound along with the
24 D or the 245 T?
MRo BOYLAND: Z think if the similar testa were
run as well as the ones that were run on our unit* the data
would be approved and that would be it.
DRo BNOSs Thank you0
CHAIRMAN MOLLOY: Any other questions from the
panel staff?
Thank you, Mr« Boyland0
I guess there arc no further questionsa
we have no e©re cards indicating people desiring
to speako
Are there any poiopl© here today who would like to
speak?
MR. HERZj Is it possible sinply to direct a few
questions to the people who have spoken today?
CHAXR^tK MOLLOY: I guess so, if they are not too
complicated«
Could you go to the podiuxn? Identify yourself;
please, and go to one of the microphoneso
MRo HERZs Ky name is Mike Hers. I am from the
San Francisco Say Chapter of the Oceanic Society. In our
comments on the Draft Environmental Impact.Statement, w©
raised a couple of points»
Not having heard what went on in Hawaii, I am not

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sura what of these were covered, but I would like to
raise them hero.
They have to do with the possible difficulties
and accidents involved in the transferring of the materials
Particularly, in terms of the reprocessing alternati
in tems of moving large amounts of materials across various
states, moving than for example, moving some of the material
from Johnston l3land where the largest portion is stored, to
this country.
I think the incineration alternative involves the
smallest number of moves, and as the Mr Force representative
already Indicated, the containers that are sitting on
Johnston Island, and Z would assume those in Gulfport too,
although to a lesser extent, are corroding away as the/
bureaucracy moves slowly towards solving this problem.
X really see one of the big problems, in addition
to the ones discussed in great detail, having to do with the
components, the very simple mechanical problems of moving
these things around from one location to another, or one
set of containers to another, and if it ever comes to the
point of moving it to a reprocessing plant in this country,
the problems of moving it by train, truck, what have you,
across the country, and the amount otopposition that I am
sure would be encountered by all the state and local
governments involved, whose territory was being covered.
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I wonder if some of the members of the panel could
address themselves to these issues»
Thank you.
CHAIRMAN MOLLQY: Dr. Welch? Can anyone from the
Air Force discuss that?
DRo WELCHs Well, in thinking, in thinking over the
rather broad number of issues that you have raised, I think
we can not give you a hard and fast detailed plan today,
that would be a 1, 2, 3, 4-type thing, that somebody could
look at and says "you covered the whole thing".
I think we have looked at the requirement for
being alert to and attempting to control spills from the
point of view of the de-drumming area, the point of view
of the movement of the material from its storage site to a
vessel for subsequent incineration.
We have not given it yet as much thought to the
problems of transporting the material to a reprocessing
site, since, A«, a reprocessing site has not been as yet
identified.
It could be inland, and it could be on the coast,
so it is kind of difficult to say what we would do.
Mr. Merrill, sitting to my right here, is in the
logistics business, and he assures me that we are going to
have an argux&ent if we try to push him to move the material
in ooae of the present containers, because he doesn't feel
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that th© containers are sufficiently sound, and that if the
material is moved to reprocessing, and moved in druiss to
reprocessing sites, we will have to do a significant amount
of redruraraing to put tho material into sound containers before
it happens.
(Continued on the following page)
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Ultimately. It would be to redrum 1t and ship It in bulk,
either by boat or by rail, depending upon where the sites
might be.
So we are not unmindful of the problem, but there
Is sufficient unknowns that I think the only thing we can say
is that we are aware of It.
CHAIRMAN MOLLQY: I am also going to ask Or.
MacKenzle to outline some of the considerations that would go
Into the reprocessing alternative. Or. MacKenzle?
OR. fMCKENZIE: Yes. fir. Herz, I will try to
give you a very short bureaucratic answer to your question.
We do recognize 1n the Environmental Protection
Agency that consideration of the safe handling, storage, drum
disposal and other potential dangers associated with the
reprocessing option do exist, and recognize this In our
policy statement, that as the material would be looked at 1n
the pilot stage 1n terms of the actual reprocessing Itself,
that there would also have to be a consideration of these
problems, and that adequate safeguards must be apparent
before the reprocessing could be given the final approval.
I don't think we could say any more to that at this
time, any more than Dr. Welch or his team could, but they
certainly would be given full consideration.
CHAIRMAN MOLLOY: Mr. Braun, I see you there, and
we have some questions on technical operation of the
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VULCANUS.
While we can't require you to answer them, 1t would
be helpful 1f you would agree to try to answer them anyway.
Would you go to a microphone?
MR. BRAUM: My name Is Manfred Braun, and I am with
the owners of the VULCAilUS.
CHAIRMAN MQLLOY: There are six questions and a
couple of subquestlons.
Be ready.
MR. BRAUN: Okay.
CHAIRMAN MOLLOY: There are three burners per
Incinerator: Is there any control that monitors each burner
and will cause corrective action If one burner flames out.
I.e.. Is there an Independent flame sensor for each burner,
a total of six?
MR. BRAUN: I think. 1f you'll ,Just excuse me for a
minute.
Captain Vogt, he 1s the-technical director of the
company 1n Rotterdam, and he 1s a Master Marine, and he has
been running the ship temporarily. I think he would be
better qualified to answer that.
(Remarks soto voce between Mr. Braun and Captain
Vogt)
MR. BRAUM: Okay. Each burner has an Individual
acoustic and optical alarm that shuts off the particular
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burner 1f either the temperature falls below the required
preset level, or If the flame goes out.
CHAIRMAN MOLLOY: Question number two.
CAh the main chamber continue operation on two of
the three burners, and If yes, what Is the effect on system
efficiency?
(Remarks soto voce between Mr. Braun and Captain
Vogt)
MR. 3RAUH: Well, the incinerators can continue
operating with only two burners, yas, but this 1s generally
not done.
The efficiency will suffer and the temperature 1n
the Incinerator will gradually decline, so 1t Is preferable
to work with three burners at a titne in one incinerator.
CHAIRMAN MOLLOY: What do you do whan that occurs?.
(Remarks soto voce between Mr. Braun and Captain
Vogt)
HR. BRAUN: When that occurs? If that occurs, then
all the three burners are being shut off, and the problem Is
rectified on whichever burner has a problem, and If the
temperature has fallen by then, it will be raised again with
diesel Oil or gas oil or when the preset level, gas level,
Is reached, then all the three burners will start operating
again.
CHAIRMAN MOLLOY: The next question Is: chamber
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(oven) temperature 1s mentioned by means of a thermo couple
In the exhaust.
(a) What 1s the response time of the Instruments?
(Remarks soto voce between Mr. Broun and Captain
Vogt)
MR. 3RAUN: 1 don't think we quite understood your
question. Do you mean the time between -- from — the thermo
couples, the time that the thermo couples need to transfer
the data Into that black box that reads the temperature?
CHAIRMAN MOLLOY: I would assume the question Is,
How long is 1t before the temperature drops below 14Q0
degrees? Ooes It take until the thermo couple registers the
reduction 1n temperature and shuts down the operation?
HR. BRAUN: Well, that 1s Immediately.
If the temperature drops below 1400 degrees, 1t 1s
shut off Immediately.
OR. ENOS: What the gentleman's question 1s trying
to get at Is what 1s the lac; time.
The thermo couples are embedded a few centimeters
into the wall, and there is a lag time.
It says amissions. I assume he doesn't really
mean a thermo couple up at the stacks, but really the thermo
couple that controls Is down 1n the box itself, right, 1n the
central portion of the Incinerator?
HR. BRAUN: In the Incinerator wall.
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OR. ENOS: And It Is a few centimeters back.
What 1s the lag time before that would sense the
temperature dropping Inside the Incinerator, you know* below
the 1100 degree mark?
(Remarks soto voce between Mr. 8raun and Captain
Vogt)
HR. 8RAUN: Okay. I think we got It now.
The thermo couples are set 1n the wall, as we said,
about one centimeter inside from the inner surface of the
wall, and there is, of course, a difference in temperature
anyway between that particular location where the thermo
couple Is 1n the wall, and the center of the fireball In the
Incinerator, and the difference Is approximately 200 degrees.
So whan you have a temperature of 1400 degrees In
the center of the fireball, you would only have 1200 degrees
that 1s physically shown through the thermo couples because
of that difference.
And when that falls below the 1200 1n that case,
that the thermo couple shows, It would shut off so there
Is no lag time. Because the temperature measured In the wall
1s less than what Is in the flroball.
CHAIRMAN MOLLQY: The next half of that question
Is, does a drop 1n chamber (oven) temperature activate an
automatic control system that Introduces clean fuel Into the
chamber for a purge cycle?
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(Remarks soto voce between Mr. Braun and Captain
Vogt)
MR. BRAUM: Ho. When 1t Is shut off, nothing is
Injected Into the chambers, nothing at all, only air. A1r
1s continued to bo blown into the Incinerators 1n order to
cool the cups which would otherwise bum out because of the
temperature.
CHAIRMAN MOLLOY: The next question there 1s: What
actions are taken and how fast If a temperature drop Is
experienced?
That 1s» the Herbicide Orange 1s stopped from
entering the system, and air Is Introduced? Is that the
entire sequence of events?
MR. 8RAUN: No. What happens 1s that all three
burners shut off thermostatically, and no herbicide or other
waste that Is being burned Is being Injected through the
burners, except air, and that 1s only to retain the cooling
of the rotating cups 1n order to keep thera from burning.
So, 1n other words, nothing goes through the burner
and the burners are being opened then, whichever has a prob-
lem, If that occurs, and that is rectified.
CHAIRHAN M01L0Y: Haste material feed lines to the
incinerator are subject to plugging. What-1s the history of
feed line plugging during operations, and what is the correc-
tive actions taken?
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(Remarks soto voce between Mr. Sraun and Captain
Vogt)
MR. SRAUN: Wall, there have been only two occurren-
ces, and one, as you know, was 1n the Gulf of Mexico, when
we did this burn for Shell.
The other one was In Europe, which was simply a
clogging that did not have to be opened, and when that
occurred, and the burner was shut off, the material 1n the
line was pumped back Into the holding tank, and was then
pumped again Into the Incinerator In the direction of the
burner, and It cleared Itself.
The second occurrence was In the Gulf of Mexico,
which was a little eiore difficult because a previous material
that was burned 1n Holland did not -- was not quite 1n
accordance with the constituents which were given to us
before.
It has hardened 1n the lines, and had completely
clogged one of the lines.
It had turned Into a tar-11ke material* So what we
had to do, we lost, I think, two days In the Shell burn. We
had to open and replace lines which was done on the ocean, an<
those lines were replaced, and then the operation was con-
tinued.
Those were the only two occurrences that we had.
CHAIRMAN MOLLOY: When that occurred, did you have
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any of the waste material Incinerated, at a lower temperature?
MR. BRAUN: None at alii
CHAIRMAN MOLLOY: The next question 1s: Is the
ship underway at all times during normal Incineration
operations?
MR. BRAUN: Hot at all times. She normally Is,
which depends on the wind condition.
What the ship tries to do 1s stay out of the plume,
and 1f there 1s no wind at all, the ship has to move at a
speed of about two, three, four knots, 1n order to keep out
of the plume, but If there Is a strong headwind, then 1t
happens that she moves on the stand spot or sits on the same
spot without moving.
CHAIRMAN MOLLOY: The last question 1s: If the
ship lies dead In the water and utilizes the wind to carry
the plume away from the ship, what 1s the effect on the ocean
of concentrated absorption of emission products, and was any
monitoring and water sampling conducted when the ship was
burning and not underway at all?
I don't think you have to try to answer the questlo
of what are the effects on the water, but do you know of any
monitoring that was done?
(Remarks soto voce between Mr. Braun and Captain
Vogt)
HR. BRAUH: I believe that what we had submitted In
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the record 1n Hawaii would show that.
I do not recall that the monitoring that was done
was done while the ship did not move or whether It was done
only while the ship moved.
On three occasions we have done monitoring, one
which was done on the Gulf of Mexico, and the other two by
the Outch Government, and the Government of France. Do you
know?
(Mr. Braun directs this question to Captain Vogt)
MR. BRAUN: Yes. I understand that on one occasion
the ship was evan anchored, so she was at a standstill when
the monitoring was done 1n Europe.
CHAIRMAN MOLLOY: And those are available In the
record, the French and Dutch reports, I believe, that were
put Into the record In Honolulu.
Thank you» Mr. Braun. There are no further question
Again, we have no further Indication -- I hold that.
These look like A1r Force questions.
I will just read thera out, Or. Welch, and you can
pick somebody who can answer thew.
1. Has there been an energy Impact analysis done
for the various methods of disposal (Including energy to
produce an equivalent amount of 2, 4, D and 2, 4, 5, T If the
burning option Is chosen)?
DR. WELCH: No.
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CHAIRMAN MOllOY: Number two has a comparative
economic study bean completed for each disposal option? If
so, could a general description bo given?
DR. WELCH: Yes. A comparative* an overall
comparative economic analysis has been roade,.
Lot na say that we prefer not to get Involved 1n a
detailed discussion of economics, inasmuch as the ultimate
means of disposal of this material has not been decided
upon, contracts have not been signed, and It 1s a rather
ticklish position to operate In a completely open environment
when you are still at the mercy of the bottom line on the
contract.
CHAIRMAN MOLLOY: I take 1t» you have not entered
Into any contracts whatsoever, for ultimate disposal of the
material?
OR. WELCH: That's correct.
CHAIRMAN MOLLOY: Question number three. Do you
have a feeling or Idea why commercial raprocessors have
taken so long to become interested 1n the reprocessing
option, or 1s there any new technology around?
DR. WELCH: To answer that would be very obvious.
I wouldn't put a dime Into trying to figure out how to use
2, 4, 5T a year ago, when the Environmental Protection Agency
might be putting It off the market completely.
CHAIRMAN HQLLOY: The last question 1s not
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addressed to the Air Force.
And maybe Or. Enos, you can take a stab at this
one.
4. What was monitoring used for Shell 011 burning?
What 1s proposed for monitoring of Johnston Island burn?
Are they essentially the same or how do they compare?
DR. ENOS: The Shell burn monitoring program breaks
down Into two categories:
The monitoring that we attempted' to pursue 1n the
first sailing of the VULCANUSi which was only moderately
successful, and the monitoring program which Involved the
second sailing of the VULCANUS, which, I thought, was very
successfuli
The monitoring categories that one has to consider
1s, first, the monitoring of the tnarlne environment, and,
secondly, the operational monitoring aboard the vessel, which
Is essentially the observer on the ship during the burn, and,
third, the monitoring of the stack gases. If anyone 1s
Interested In the breakdown of the marine monitoring, I would
ask Or. Hastier to address that particular point.
I will discuss Just briefly the kinds of monitoring
that we put Into operation, and requested Shell to carry out
during both the first and second burn.
On a relatively short notice, for a lot of reasons
I won't go Into, we find ourselves having to address ourselve
WM. E. HENDERSCHEID & ASSOCIATES
CERTIFIED SHORTHAND REPORTERS
DEPOSITION NOTARIES
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to the question of monitoring In an extremely hostile
environment.
I would point out that monitoring In this kind of
environment has never been carried out before, even with a
reasonable period of time to consider the problems.
Shell Chemical attempted to run a line from the
sample port to one of the stacks in the Incinerator, Into the
side port of the vessel, and worked out an extensive
aionitorlng train which was capable of handling the hydro-
chloric add, measuring the carbon monoxide level and
measuring the hydrocarbon emissions.
In addition, they had a sample 1mp1nger train,which
was designed to trap for subsequent analysis any organo-
chlorlne emissions from the stack.
The backup equipment that should have been availa-
ble for this kind of operation was not, 1n fact, available.
And the scrubbing devices and the heated lines, and
so forth, that one would associate with monitoring activities
of this kind were marginal at best.
When the vessel went out for the second burn, they
had themselves fairly well organized.
The had a glass Insert for the stack emission
sample, they had heated lines.
In addition to that, in the laboratory, and again,
on board the vessel, they evaluated the sampling line in
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terms of Its ability to transmit the organo-chlorlne wastes
of the kind they were burning to the Implngers.
The efficiency of this operation varied between
70 and 90 percent.
In addition, they had duplicate Instruments for
measuring carbon monoxide on a continuous basis, they had
Implngers for trapping the hydrochloric acid vapors.
The samples for the orgaho-chlorlne analysis had
to be analyzed subsequent to the burn, and they were analyzed
back in the laboratory.
Shell has Indicated In its own reportwh1 ch 1s
a matter of record 1n this proceeding, as appendix A to
the Environmental Protection Agency's summary of Its experi-
ences 1n raonitorlng around the VUICANUS on the two research
permits, Shell has pointed out the extreme problems Involved
and has summarized this information, and I think 1n an
admirable fashion, so that 1t once and for ell documents the
kinds of problems and how one approaches them 1n this situa-
tion.
Trading on these experiences* we have worked with
the technical people that the airport has indicated would be
involved In the stack monitoring, -Mr. Gokelman and Mr.
Rodriguez, and my own background 1s 1n specified residue
analysis and dloxine analysis 1s not unfamiliar to me.
We have devised a system which has since been
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tested by the Air Force for determining and trapping TCDD
which 1s the compound I an primarily Interested In: the
2, 40 and 2, 4, 5T would automatically fall 1n place because
If you road the Environmental Impact Statement, you will note
that that sampling train has already been evaluated for those
two compounds.
There was a paucity of data on TCDD, I think, none
in the Environmental Impact Statement, but I knew that some
was available for that particular sampling train.
The uncertainty was whether or not the TCDD could
be transmitted successfully from the sampling port Incinera-
tor to the sampling train.
Laboratory experiments which are documented in this
hearing by the Air Force, indicate that even at a lower stack
gas emission temperature than they would actually be experi-
encing 1n the field, they wore able successfully to transmit
the TCDD down the 41 feet of teflon tubing into the 1a»p1nger.
If someone would like toask further questions, I
will be glad to expand, but most of the Information that I
can give at this point In t1r,ie is in the record.
CHAIRMAN MOLLOY: I would like to point out that th
Envlronmental Protection Agency 1s preparing a report on the
Incineration of the Shell wastes.
This report was entered into the record 1n draft
foria, and whsn It 1s finalized, 1t will be available on
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request.
You can get a copy of it by writing to the 011 and
Special Materials Control Division (WH443), attention Chief,
Marine Protection Branch, Environmental Protection Agency,
Washington, Q.C., 204G0.
DR. ENOS: I might add Just one more thing.
Since it came up earlier, some question relatively
to the plume, or I surmise that there was an intent to cover
that problem. When we were considering the permit for
Incinerating organo-chlorlne wastes In the Sulf of Mexico,
and there was great concern for the hazard that might be
involved for hydrochloric acid vapors impacting on birds 1n
the transmigration mode, and since there is no visible plume
from the V5JLCAHUS, It became of soma concern to determine
precisely the shape and condition of the plume.
We brought In modelers from our research laboratori
Research Triangle Park in Raleigh, North Carolina, and they
propose two alternatives to us: the question then was which
of the alternatives truly described the case.
In one alternative it was conceivable in the worst
case condition that we could have significant concentrations
of hydrochloric acid above the vessel.
In the first burn we attempted to fly 3ome missions
over the vessel 4n<* Murphy's Law prevailed* and I won't go
through the unbelievable number of failures in motors,
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Instruments and operational procedures that prevented us from
doing that* but on the second burn we actually flew three
Missions and transcepted that and traversed the plume 1n all
directions, and provided sufficient data to establish that
1t Is essentially a plume which 1s somewhere between an eddy
current dlfuslon plume, and the standard plume that one
considers 1n atmospheric modeling on land, which means 1t
spreads out behind the vessel at some low altitude and then
Impacts on the surface of the ocean.
The concentrations that we encounterd 1n flying a
continuous monitoring device, which has just been perfected
for the Space Agency, we never entered concentrations above
three parts per million In the plume, and we actually had
flights that not only transsected the plume, but ran the
middle line of the plume of the vessel and never encountered
concentrations 1n excess of three parts per million.
CHAIRMAN HOLLOY: We have another question again
directed to Br. Braun.
It 1s about the thermo couple.
Norraally shielded thermo couple response Is measure
In terms of functions of a second or seconds. Burled thermo
(Continued on following page/
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Buried thamso couples have much slower response
tiKVSiSo
Has the response of buried tharxno. couple been
sieaaurad?
(Remarks soto voce between Mr»
braun and Captain Vogt.)
KRo BRAUN: No. We don't have such data.
It has not been measured=
CKAIHMAM MALLOY: Thank you.
I have no further questions. You have a question.
MR. BRAUW: I just have a suggestion to make.
In the interest of expedience it was mentioned by
one of the previous speakers that it would not be preferable
to make a burn of the entire shipload of 1,200 tons but
rather of one tank only,.
It doesn't appear practical or expedient for us to
send an ocean tanker from Rotter darn to Johnston Island with
a couple of tons on it and sit around and wait for the
results o
He are currently negotiating with Shell Oil Company
again. We have expressed interest in the incineration of
another couple of ship loads which we have done last year at
another site, and they will be submitting an application to
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tile Enviornciental Protection Agency very soon.
It occurred to mo that on that particular occasion
it i&ight be possible for the ship„ or it will be possible for
tiis ship to pick up a faw tons of Herbicide Orange in
Gulfport, Mississippi, and do that test burn in the Gulf of
Mexico, provided that would be considered by the Enviornmentai.
Protection Agency.
The smallest tank of the vessel is 115 cubic meters
which could be loaded up — or lass than that — and that
would give enough time to do this test, and to evaluate the
results without the ship sitting around in Johnston Island,
waiting.
CHAIRMAN MOLLOY: Thank you, Mr. Braun.
X can't think of all the problems that would occur.
I am sure many of them, but that is a very con-
structive suggestion and X an sure we will consider it.
Thank you.
1 have no further indications of questions.
Do any of the panel raeinbers have question or
comments„
Without any further questions or comments, this
session of the hearing is adjourned.
(VThereupon at the hour of 11:30
o'clock the San Francisco Session
of the Enviornnental Protestion
Agency's hearings on the Ocean
Disposal of Herbicide Orange was
Adjourned.)
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