I
13
14
15
16
V
•
13
19
20
21
22
23
24
25
ENVIRONMENTAL PROTECTION AGENCY
HEARING ON U. S. All* FORCE OCEAN INCINERATION
OF HSRB'ff^TDAL "ORANGE
WASHINGTON, D.C.
GSA Building
18th & F Streets
(Main Auditorium)
Washington, D.C.
9•00 A.M.
A?
-------
o
7
- <• (
.2
13
H
15
16
17
18
IS
2C
21
22
23
24
25
2
uses
KENNETH E. BIGLANE — Chairman
Director of Oil and Special
Materials Control,
Division of EPA
Panelists;
Dr. Henry Enos, Director,
Equipment Techniques„Division
Office of Monitoring Systems
Office of Research and Development
COL CHARLES E. SELL,
Assistant to the Director
Office of Federal Activities
MR. EDWIN L. JOHNSON
Acting Deputy Assistant Administrator
For Pesticide Programs
Mr. James Rogers,
Attorney
Office of General Counsel
Mr. T. A. Wastler, Chief,
Marine Protection Branch
Oil and Special Materials Control Civision
¦,f£B¦'iS.Vl'J
r.
-------
.i
z'l
O
5
7
f>
9
10
i
..13
14
15
IS
17
13
J9
20
21
22
23
24
25
2-A
J P <¦ ^
AMWiWA -i_- ItTTiVnna
i) J 0 Q
IUZZ) $33*^3$*'
\
CONTENTS
STATEMENT OF: PAGE
|
Kenneth E. Biglane, ]
Director, Oil and Special Materials j
Control Division, EPA 4 1
Edwin L. Johnson, '
Acting Deputy Assistant j
Administrator for Pesticide Programs,EPA 8 j
j
James Rogers, i
Attorney at Law, i
Office of General Counsel, EPA 14 j
Dr. B. E. Welsh,
Specialist Assistant for
Environmental Quality, ;
Office of the Secretary, U.S. Air Force 16 i
s
i
Kenneth E. Kamlet,
National Wildlife Federation 23 (
5
Mrs. Nancy Shower,
Center for Law and Social Policy 31
Donald D. Carruth, j
President, American Eagle Foundation 32 !
-------
1
p
3
4
5
S
7
3
9
10
:j
12
13
14
15
16
17
18
19
20
21
22
23
24
25
L2L2.2JLE.H.I.5L2.S
CHAIRMAN BIGLANE: It is at least 9:30. We
will expect one more panel member to arrive shortly. I
think we should get started.
Good morning, ladies and gentlemen. I am Kenneth
E. Biglane, Director of the Oil and Special Materials Contro
Division of EPA. It is my pleasure to welcome you to this
public meeting concerning the application of the U.S. Air
Force to dispose of Herbicide Orange by ocean incineration.
EPA panelists sitting with me are, from my .right.
Dr. Henry Enos, Director, Equipment and Techniques, Division,
Office of Monitoring Systems, Office of Research and
Development? Colonel Charles E. Sell, Assistant to the.
Director, Office of Federal Activities; Mr. Edwin L.
Johnson, Acting Deputy Assistant Administrator for Pesticidd
Programs; Mr. James Rogers, Attorney, Office of General
Counsel, who will be with us shortly; and Mr. T. A. Wastler,
Chief, Marine Protection Branch, Oil and Special Materials
Control Division.
This meeting has been called to solicit public
participation and input at the earliest stage into a decisic
which EPA must make concerning the ultimate disposal of
Herbicide Orange stocks now being stored by the U.S. Air
Force at Gulfport, Mississippi, and on Johnston Island in
the Pacific Ocean. A record is being made of these
S^eporitng C^om.fja.ny
<20!J «28-4«)aH
-------
'7
-¦
4
f't
o
7
s
fl
5C"
11
12
13
14
15
16
11
18
19
20
21
22
23
24
25
5
proceedings and all comments made here will be carefully
considered in reaching a decision on this matter,,
The U.S. Air Force has approximately 2,300,000
gallons of Herbicide Orange stored at Gulfport, and on
Johnston Island. Herbicide Orange is a misture of equal
parts 2, 4-D and 2,4,5-T with approximately 2 ppm of dioxin,
a very toxic organic compound as a contaminant. The materia!
is presently stored in drums which deteriorate over long
periods of time, thus necessitating re-drumming to prevent
leakage to the environment. This is a costly procedure and
the risk of leakage increases as the average ag© of the
drums becomes greater. Some means of ultimate disposal in
the near future is highly desirable.
The U.S. Air Force has prepared an environmental
impact statement on the disposal of Herbicide Orange, in
which a number of disposal alternatives were explored.
Based on the results stated in the environmental impact
statement, the Air Force has filed with the EPA an
application for an ocean dumping permit to allow disposal
by ocean incineration; at the same time, however, the
feasibility of ultimate disposal by reformulation or
reprocessing to obtain a commercially usable product is
still being explored, and the Air Force has asked EPA
to assist in evaluating the feasibility of this alterna-
tive to ocean incineration.
-------
1 ]
2
3
i
h
8
'?
3
9
5,0
H
JiS
13
n
15
Va
11
18
19
20
21
22
23
24
"£&
6 j
This public meeting is intended to be a forum !
i
i!
in which the public can both receive and provide informa- j
t
tion relative to the ultimate disposition of Herbicide j
I
Orange. As outlined in the announcement in the Federal !
1
Register of February 4, 1975, the Agency invites comments •:
from the public on the following: I
i
1. Whether feasible alternative methods of j
i
disposal exist. I
i
2. Whether Herbicide Orange is a "chemical" j
l
or "biological warfare agent" within the meaning of j
the Act, and whether it retains this character j
following incineration. j
3. Whether incineration of Herbicide Orange at
high combustion efficiency is compatible with the
Act, assuming the compound is a weir fare agent.
4. Whether adequate techniques exist with which
to monitor the incineration of Herbicide Oran^S^
5. Whether incineration is a feasible and
environmentally safe means of disposal of Herbicide
Orange.
6. Whether the disposal site requested by the
Air Force is an appropriate location for incineration
of this waste.
The request by the Air Force tq ERA to dispose
of Herbicide Orange impacts two major program areas of
"is
'[2-0K»
-------
2
3
6
7
S
9
10
^
j. jL
12
13
14
15
16
1?
18
19
20
21
22
23
24
25
EPA: the Office of Pesticides Programs, which is responsi- i
ble for the regulation of pesticides for commercial use, !
and the Office of Water Program Operations, which is j
responsible for the Ocean Dumping Permit Program. Today
I
you will hear representatives of both of these offices j
present program positions on this subject. You will also i
hear the Air Force present its position on ultimate dis- j
posal of Herbicide Orange. After these presentations \
statements will be invited from those who have indicated j
on the registration cards that they wish to make statements.
This meeting will then be open to clarifying ques-!
tions from the floor to EPA, the Air Force, or anyone who
has made a formed statement.
We would like to have presentations from elected
officials or their representatives, from other Federal
agencies, from State agencies, from groups, and then from
individuals. This is the order we would prefer.
I would like to emphasize that no decision, i
tentative or otherwise, has been made by EPA on this matter<
EPA has responsibilities for protection of the entire
environment and the final decision on how to dispose of |
Herbicide Orange will be made in recognition of the EPA j
commitment to the protection of the total environment.
We believe that this public meeting at an early !
state in our evaluation of this permit application for
1
-------
J.
2
o
•4'
¦ 5
6
7
8
9
10
21
12
13
14
15
16
17
18
19
20
21
22
23
24
25
8 !
ocean incineration of the Herbicide, will foster full I
consideration of all aspects of the proposal that affect i
the public interest and allow us to explore fully the ;
'I
J
consequences of the alternative means of disposal being |
considered.
We expect the product from this meeting to be
a record which will reflect the public concern about the
disposal of Herbicide Orange. The areas of concern stated j
in the meeting will be brought to the Administrator's I
attnetion to assist him in making future decisions on the |
disposal of Herbicide Orange. }
At thi3 point, I would like to make a few general |
announcements:
1. Comfort Break at 10s45 - the court reporter
is uppermost in mind. Reassemble at lis00 a.m. ;
2. Assuming that the meeting will go into the
afternoon, we will recess at 12s00 p.m. and reassemble
at lsl5 p.m.
3. Public eating facilities are listed on the
sheet which you received when you registered. If you
did not receive such a sheet, they are available at
the registration desk. ;
4. The rules of this building prohibit smoking. j
in the auditorium. !
i
5. We have not reserved the building for tomorrow
-------
1
2
3
4
5
6
7
3
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
if the meeting runs to latie in the evening, I will
announce 15 minute comfort breaks about every hour
and one-half, a one-hour dinner break at 5:15 p.m.,
and we will go on into the night if necessary.
6. In any event, the record will be held open
until March 5, 1975 and your submissions should be
sent to EPA in care of Mr. T. A. Wastler, Marine
Protection Branch, 401 M Street, S.W., Washington,
D.C. 20460.
7. There is a microphone and lectern in the
auditorium aisle to my right. Those from the audi-
ence wishing to make statements should do so at
this lectern, and please state your name clearly so
that the court reporter can list it correctly.
8. All those present should have filled out a
registration card and indicated whether or not they
wish to make a statement. If you have not filled out
a card, please do so at the registration table in the
rear of the room.
Now, I will ask Mr. Johnson, to outline the pro-
gram area of the Office of the Pesticides Programs with
regard to the feasibility of reprocessing or formulating
Herbicide Orange.
MR. JOHNSON: The Federal function aside - the
Insecticide and Rodenticide At, as amended in 1972, which
-------
J.
2
o
4
5
6
7
8
9
10
11
12,
13
14
15
16
17
18
19
20
21
22
23
24
25
10 ;
;i
is administered by the Environmental Protection Agency, |
jl
requires EPA to regulate the distribution, sale, and use j
!
of pesticies, in the disposal of pesticies and containers. ;
The composition, intended purpose, and other
ii
characteristics of Herbicide Orange clearly bring it within
the definition of a pesticide under the Act, and thereby !
subject to regulation. i
Specifically, Section 19-A of the amended Act j]
|
requires the Administrator of EPA to establish procedures |
i;
and regulations for the disposal or storage of insecticides ;j
1
and excess amounts of such pesticides. Initial regulations |
under Section 19 were published in the Federal Register on
Hay 1, 1974, and additional rule making is now under final !
deliberation within the Agency,
In promulgating these regulations, consistent with;
the need to conserve and reuse our natural resources, a |
policy with respect to disposal was established: wIn j
considering diposal techniques the first preference should
be given to procedures designed to recover some useful j
value from excess pesticides and containers. Where large :
quantities are involved, one of the first recommendations j
is the excess material be used for the purpose intended, j
provided the use is legal. Another alternative is to returnj
the material to the manufacturer for potential reuse or j
processing. A third alternative in some cases may be the i
" i
-------
2
3
4
<
6
7
8
9
10
II
12
13
14
15
18
17
18
19
20
21
22
23
24
25
11 i
export of the material to countries where its use is desired
and legal.
"Should these alternatives be inapplicable, the i
ultimate disposal method should be determined by the type |
of material." i
The preamble then goes on to discuss various
methods of ultimate disposal. It is clear methods of
disposal which are environmentally sound are preferred to
simply throwing resources away. This consideration is
particularly germane during this time of shortages and
projected shortages of many materials, particularly those
products derived from petroleum feedstocks? included
among materials predicted to be in short supply are usual
herbicides, which are used in growing our grain crops.
There are chemical methods and procedures which
will degrade and modify the chemical characteristics of
some pesticides. The forms which are not hazardous to
the environment. However, practical methods are not avail-
able for all groups of pesticides.
In this case, however, the Office of Pesticides
Programs has general information available to indicate the
potential for chemically reprocessing Herbicide Grange into
commercial products such as 2,4-D, chlorine, hydrochloric
acid, or into such commercial products, including dioxin
containing wastes.
43(083
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12'
Informal discussions have also indicated an
economic as well as a physical feasibility. Our general
counsel has advised that Herbicide Orange reprocessing can
be considered a form of disposal under Section 18 of the
FIFRA. However, to exercise the Section 19 rule, EPA must
be satisfied that the dioxin content of the Herbicide Orange
can be safely removed and dealt with.
In order to fully and properly consider any
reformlation processes, EPA would need to know and to
considers
1. The potential processing firm and its
location ?
2. The physical facilities available to reformu-
late the herbicide?
3. The exact chemical process to be utilized
in removing the dioxin content or in other ways
modifying the chemical structure?
4. The chemical makeup and the probably level
of dioxin in the reformulated substances;
5. The probably level of dioxin refuse and
other wasts from the reformulation process, includ-
ing possible aerial emissions from smokestacks,
for instance, and the liquid or solid refuse resulting
from the process?
6. Additionally, if the reformulation compound
Reporting Company
(202) 038*4883
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
13
is intended for pesticidal use, then either a
-
registration-application would need to be sub-
mitted to the EPA by the processor or the name
and registration numbers of products already regis- |
tered in which the material would, be used must be jj
supplied. j
Quality control would also be of prime importance jj
and testing would be necessaucy to assure this, i
In addition, should a specific method look :
!!
promising, and when a processor has expressed interest, it j
would be most likely that one or perhaps more trial batches I
would have to be processed under carefully monitored
conditions to assure performance before proceeding with a
major undertaking. j
The Air Force was advised of these agency views j
on chemical reprocessing in a January 21, 1975 letter, <
responding to an inquiry made by the Air Force on this i
subject in November of 1974. A copy of this letter will j
be provided as part of the record of this meeting. j
In addition, the assistance of EPA scientists j
has been offered to the Air Force in evaluating proposed
processes for chemical reformulation. In short, the Office ;
of Pesticide programs believes that the option of chemical j
reprocessing of Herbicide Orange into usable products is
worthy of additional serious consideration and if feasible !
(Jgsr-*;) <«©^393 1
-------
>
2
3
4.
5
5
7
S
9
10
11
12
13
14
15
18
n
18
19
20
21
22
23
24--
25
I
it may be well be preferred to ultimate disposal.
In his opening remarks, EPA, however, has made
no decision as yet in this matter. To make an intelligent j
one, the EPA needs full information on all alternatives
potentially available. }
Thank you.
CHAIRMAII BIGLANE: Thank you, Mr. Johnson.
Now, I will ask fir. Rogers to outline the !
statutory requirements as such requirements govern the
position of EPA's Ocean Dumping Permit Program with regard
to the issuance of a permit for the ocean incineration.
Rogers. j
MR. ROGERS: The law that this hearing is held
under and the further provisions under this application that
i
are contemplated, is the Marine Protection Research and |i
i;
Sanctuaries Act of 1972, Public Law 92-532. The basic I
outline of the statutory requirements that we have to j
i,
operate under, the EPA, are as followss We have to start [
with the presumption that the dumping of materials without '
a permit from the Environmental Protection Agency is pro-
hibited. j;
The Act then states several criteria which the ji
Agency must consider in acting upon applications to dispose i
of materials in the oceans.
One of the unique features about this application,
I;
^Msms i;
J302J
-------
1
2
3
4
5
6
7
8
9
10
11
312
13
14
15
IS
17
S8
19
20
21
22
23
24
25
16
Conincident with that tentative determination we
will issue — if the determination is to issue a license
or to deny a license, we will issue notice of opportunity
for hearing, public hearing. We will then hold a public
hearing if people request that hearing in a timely fashion.
Based on the complete record the Agency will render a final
decision on the permanent application.
CHAIRMAN BIGLANE: Thank you, Mr. Rogers.
Now, at this point I would ask the Air Force to
present their position and findings on the alternative
means of disposal. I see Dr. Welsh in the audience. I
presume he is going to lead the discussion.
DR. WELSH: Mr. Biglane, members of the Panel,
ladies and gentlemen, I would like just very briefly to
recound some history for you, if I might.
I am Dr. B. E. Welsh, Specialist Assistant for
Environmental Quality, Office of the Secretary of the Air
Force.
I would like to briefly recount some of the
history that has led us to where we currently are, and
to see if we can put this problem into the right type of
perspective.
First, starting roughly in April of 1970, the
U.S. Department of Agriculture, HEW, Department of Interior,
at that time, suspended certain use of 2,4,5-T. As a
«at>2) <323-4808
-------
1
2
3
4
5
S
1
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24'
25
i'
|
17
consequence of the suspension of the 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
Ordane in Vietnam and 0.8 million gallons of Herbicide
Orange at Gulport.
Following that suspension in April of 1970r on
September of *71, the DOD elected we return this material
from Vietnam and we dispose of it in a safe, efficient
manner. Following that particular direction the Air Force
published a draft environmental statement in January of
1972, stating that incineration appeared to be the best
vay of resolving the problem, and that we had numerous
types of studies underway. Due to the fact that these
studies were underway and have not yet been completed,
it was felt that discretion was the better part of valor
and the studies should be completed prior to the time we
moved forward.
As a result of that, the material that was stored
in Vietnam then in April of 1972 was moved to Johnston
Island for storage arid pending a final disposal decision.
Since that point in 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. We conducted
incineration tests ranging from static tests in the
jMsmer-
iS.OS.'l 323-409B ' '
-------
1
2
3
4
5
6.
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
18
laboratory, to small scale tests to be studied in the
laboratory, to drum size tests conducted by the Air Force
at a facility on the West Coast,
The results of these studies indicated that the
D and T acids are destroyed somewhere around 330 to 360
degrees Centigrade, and the dioxin or the CDD destroyed
somewhere around 980 and 1000 degrees Centigrade.
In addition to the incineration studies, we
looked at the potential for use. As pointed out, this
particular material is not a registered herbicide and for
it to be utilized it would have to be registered or re-
formulated 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 acceptibility for use, and
indeed the EPA had planned to hold public hearings in June
of 1974 to evaluate the overall use of 2,4,5-T in this
country. These public hearings were subsequently cancelled
with no decision being reached due to the lack of suf-
ficient information on which to base decisions.
We looked at the deep well disposal. We looked
at the prospect of putting the material in nuclear.test
cavities, we looked at the prospect of buying it, and
molecular reduction, subsequent destruction of the dioxi^.
(20SD 830-4099
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
19
we looked at the concept of chlorinolisis, complete
chlorinization of the molecule and phosgene, carbon
tetrachloride and hydrochloric acid.
We looked extensively at 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
and breaking it down.
We also looked at the question of return to the
manuf acturer «
In March of 1972 we contacted the original manu-
facturers of the material and inquired if they had any
interest in the material* Whether they could reprocess it
to remove impurities and reuse it. This created what might
be known as a wide wave of dissent a&t that particular
point in time.
Subsequently, in August of 1974, following EPA* s
decision in June of 1974, we contacted the manufacturers
again with the same type of results. They do not have
the capability nor the interest to reprocess this material.
In May of 1974 vie published a draft environmental
impact statement in which we said something like this:
that incineration appeared to be the best way of destroying
the material. If we were going to incinerate it it appeared
that incineration at a remote site was preferable to
sQcme f^epurting (^ompanif
(ZOZ) 523-4699
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
20 i
incineration in the continental United States. j
i
Accordingly, we said that incineration on or v/est j
of Johnston Island would be preferable0 We looked at the
incineration at sea west of Johnston Island as having the
least prospect of causing environmental damage. Inciner- |
ationon Johnston Island, handled by building a facility
there that would be environmentally acceptable, but had
the opportunity for potential greater impact than inciner-
ation on the high seas
At the time that we filed the draft environmental
impact statement, the EPA position was that incineration j
on the high seas was not covered by the Ocean Dumping Act, j
The draft environmental impact statement was sent out to J
j
something like over 400 people, or over 400 copies 1
were distributed, and was given and LO-2 rating by the
EPA.
Subsequently, in.December of 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. I guess for the benefit of those j
that may riot know where Johnston Island is, it is something
on the order of 800 miles west of Hawaii. From the proposec
site of incineration downwind it is something like 1,000
miles to the next land mass, and that land mass consists of!
a chain of fairly small islands. ,
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
21
As I said in December of 1974,.we published the
final environmental impact statement, again saying inciner-
ation was our primary choice of the destruction of the
material„ again saying incineration on the high seas, the
primary option if we destroyed it, and incineration on
Johnston Island was the second method, assuming incineration
on the high seas was not a feasible thing to accomplish.
We distributed something like 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.
My pdint in mentioning this is to indicate to
you that this particular public meeting we are having today
is not to discuss a problem that just surfaced, not 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.
I might say regarding the problem of permit or
the question.of permit, the fact that we have applied for an
ocean dumping permit does not necessarily mean we.agree
completely with the EPA position that an ocean dumping
4cme Reporting dotrtpany
(202) 628*4638
-------
I
2
3
4
5
6
7
8
9
.10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
22
permit is required. We are, however,' complying by applying
for a permit.
As Mr® Biglane said, we do have a problem in
storage of this material, I does cost money to maintain it
The material that is stored on Johnston Island is stored
as it got there in 55 gallon drums, but it is open storage,
Johnston Island is roughly 600 to 650 acres in total area,
and I would suspect that the elevation is something on the
order of six to 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 due to the fairly
corrosive environment that is there.
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 reformulation
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 trie re for anyone
to study, if they so care, and we think that the solutions
are fairly self-evident,
I think, Mr. Biglane, that is all we would care
to say on that at this particular point in time.
^eportinq (S.'ompantj
(202) 628*4888
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
IS
17
18
19
20
21
22
23
24
25
23 j
CHAIRMAN BIGLANE: Thank you, Dr. Welsh, for that I
i
statement to the record. j
At this point, following our formula that we laid
out earlier, this meeting will be open to clarifying question
I
from the floor to EPA, the Air Force or anyone who wants to j
i
make a formal statement. We then gave our order we would liki
|
to see such presentations. i
I have just been informed, and you might correct j
)
i
this if this is wrong, there are no federal or state elected j
officials present herein. Do we have comments from other
federal agencies at this time?
Do we have comments from state agencies?
I have received notice that we have from groups,
three individuals who want to make statements. Mr. Ken
Kamlet, counsel for the National Wildlife Federation. At
this time, Ken?
STATEMENT OF KENNETH E. KAMLET, ON BEHALF
OF THE NATIONAL WILDLIFE FEDERATION
MR. KAMLET: Thank you. My name is Kenneth E.
Kamlet. I appear at this meeting on behalf of the National
Wildlife Federation as an attorney and a biologist. The
National Wildlife Federation, headquartered in Washington,
D. C., is the world's largest non-governmental conservation
organization with 3.5 million members and supporters through©}
the United States, Guam, the Virgin Islands, and Puerto RicoJ
^¦sporiimt} C-ismipziwg
1202) asa-asae
-------
1
2
3
4
5
¦n
o
1
8
9
10
II
12
13
14
15
IS
17
18
19
20
21
22
23
24
25
24 '•
Z would ask at this tine that my prepared statement]
and two attachments be entered into the record.
We are assembled here today to consider a proposal
by the United States Air Force to dispose of 2.3 million
gallons of Agent Orange herbicide by ocean incineration on
1
!
board a specially designed incinerator ship. The incinera-
tion would take place during three seven- to nine-day periods
in a designated area 50-60 miles clear of normal shipping
lanes and on the open tropical sea downwind (west) of
Johnston Island. The proposed disposal location is 120 miles
from the nearest land.
The disposal of Agent Orange is a matter of great
environmental significance, because a contaminant present in
the Orange — 2, 3, 7, 8-tetrachlorodibenzo-p-dioxin, otherwis
I
birth defects in experimental animals. It has also been impli
cated in the increased incidence of human birth deformities is
Vietnam in the late 1960s, as a result of the widespread mili-
tary use of Agent Orange during the Vietnam War. It is unclea:
to what, if any, extent the individual herbicide components os
I
Agent Orange — 2, 4, -D and 2, 4, 5$ -T — may themselves be
teratogenic or otherwise toxic to man and beast. But see foot
note la and Appendix I, although both these effects have been j
demonstrated in laboratory animals for purified forms of both j
\
these herbicides. '
known as "TCOD" or simply, "dioxin" — has been shown to cause
-------
1
2
3
4
5
6
7
S
9
n
12
:i3
14
15
16
17
18
19
20
21
22
23
24
25
i
!
25
In the interest of prudence, the Secretaries of
Agriculture/ HEW and Interior jointly announced in mid-April
1970, the suspension of the registration of 2,4,5,-T for mos-:
uses. In September 1971, the Secretary of Defense directed
the Joint Chiefs of Staff to dispose of both U.S. and Vietnaijn
stocks of Agent Orange. The Air Force, which was assigned
this responsibility, favors ocean incineration as the
preferred method of disposal, although it would presumably nit
i
be averse to reformulation and resale of the Orange if the ;
!
necessary FIFRA certification were forthcoming# and I take it,
I
assuming there were not significant delays in allowing that |
to occur. J
The National Wildlife Federation feels a responsi-
bility to participate in the deliberations over the Air
Force's ocean disposal proposal, both because of our concern
for the marine environment and because of our role in estab-
lishing EPA'3 regulatory jurisdiction over ocean incineration
|
activities. Thus, in large part, as a result of the Federa-
tion's efforts, the Shell Chemical Company was required
several months ago to secure EPA ocean dumping permits for
the ocean incineration of four shiploads of organochlorine
wastes. Based on a review of available European studies which
|
showed the efficiency of organochlorine destruction to be
great and the environmental impact of the resultant exhaust 1
i
i
vapors to be negligible, we gave our qualified support to !
P t- f
cm? ®mjpainv}. j
-------
1
2
3
4
5
S
1
a
B
30
n
:i2
<13
14
15
18
17
18
19
20
21
22
33
24
25
26 |
Shell's ocean dumping permit request. This support was j
expressly conditioned by our insistence that "every aspect of
!
the incineration process and its aftermath be followed,
measured, supervised, and evaluated, and that the operation
be aborted at the first sign of anything untoward." Zt would
almost be understatement to describe as "exhaustive" the
research and monitoring effort that accompanied the first two
Shell incinerator runs — carried out under a circumscribed
"research permit." The results of these studies unequivocally
I
confirmed the complete safety of an appropriately conditioned
and executed high-temperature ocean incineration operation ]
!
when applied to organochlorine wastes of the Shell type. j
Ocean incineration is no panacea, however. In the!
i
H
view of the National Wildlife Federation its use is appropri-
ii
ate only under the following three circumstances: [>
(1) The waste to be disposed of must be susceptible
I
to essentially complete combustion. Wastes containing sig- f
nificant quantities of heavy metals and other inherently non-
degradable materials are not suitable candidates for ;
i
i
incineration absent adequate pre-treatment or stack scrubbing
to remove materials refractory to thermal destruction. ]
(2) There must be available no environmentally |
more acceptable treatment, disposal, or recycling alternative.
If a valuable resource can be salvaged without environmental
risk, this option should be pursued in preference to disposajl
-------
1
2
3
4
8
n
o
7
8
9
10
II
12
13
14
15
IS
17
18
20
21
22
23
24
25
!
27 !
f
J
or destruction. j
}
(3) Each waste for which incineration at sea is j
being considered must be evaluated on its own merits. Wastej
combustion efficiencies and exhaust gas toxicities will vary!
i
t
from waste to waste and must be determined and monitored on a
i
i
case by case basis. i
i
Thus, the mere fact that the Shell operation was ¦
i
successful should not alone allow the unqualified approval o.
the Air Force proposal. Appropriate disposal locations must
also be selected in each individual case.
In consideration of the above principles, the
National Wildlife Federation does not object, from a strictly
technical and environmental standpoint, to the Air Force's
properly-conditioned ocean incineration of Agent Orange.
Extensive Air Force tests, employing land-based incinerators,
justify the expectation of shipboard destruction efficienciei
i
of well over 99 percent. And, although reformulation or 1
reprocessing of the Orange with recovery of herbicide for
sale and reuse may be technically feasible, in our opinion
there are twoo many uncertainties surrounding the herbicides;
involved to justify the environmental and health risks of |
n
their further dissemination without careful deliberation and
study. From the standpoint of the environment, destruction by
incineration on the open ocean may be the best course of
action for the remaining stores of Agent Orange.
^¦sr^oriir^ ^'arn^anij
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
I
I
i
281
This technical analysis does not end the inquiry, j
however. Under the Marine Protection, Research, and Sanctu-|
aries Act — the ocean dumping law — there may be no ocean j
i
dumping of even trace amounts of any chemical warfare agent.¦
3
Since Agent Orange is indisputably a chemical warfare agent,
long used as a defoliant in the Vietnam War, it may be
i!
disposed of at sea only if no detectable traces enter ocean
waters. The Air Force's proposal must be weighed against
this legal criterion.
The results of two laboratory, two full-scale, and^
ij
one industrial prototype scale, incineration studies on Agent
Orange are summarized in the Air Force's environmental impact
statement.
A Mississippi State/DSDA laboratory study inciner-
ated 5-6 grams of Agent Orange at temperatures in the 700° to
1000° C range. No herbicide was detected in benzene
impingers through which combustion gases were passed. Howevo
2,4,-D and 2,4,5,-T free acids in the 2.0-200 ppb range and
2,4,5,-T isoocytyl ester in the 0.70 to 370 ppb range were
found in extracts of particulates in a pyrex wool particulate
trap. These results indicate that, at 1000° C, traces of
herbicides may be volatilized and carried out of the burning
range of the furnace. Complete combustion of the Agent
Orange starting material appears nevertheless to have been
achieved. We ^ave reviewed these studies.
I., tyn.i.
Viu'ipws'.yj
(zvv.h
-------
2
3
4
K
¦iS
¦5
1
3
3
10
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 |
Although the Marguardt Company's General Manager j
has stated, and the Air Force has agreed/ that "data from on&
type of combustion system cannot be assumed to apply to a j
l
different type or. size combustion system without extensive j
t
»
testing to validate the assumption" (EIS, pp. 0-64, 0-68)/ we
j
believe the data available to us make it probable that full-j
k
scale incineration of Agent Orange can be carried out to j
below detectable limits when the following conditions are raej:
(1) Combustion temperatures exceed 2280® F (1246®C
(2) Dwell time exceeds 0.14 sees.;
(3) Fuel-to-air ratio i3 approximately 0.1?
(4) Excess air exceeds 30 percent;
(5) Agent Orange is preheated to at least 90° (and
preferably to 175° F); and
(6) Agent Orange is injected into the combustion
chamber by a radial slot-type/ rather than a central poppet-3
type, nozzle. (EIS, pp. 17, 0-11, E-33, E-54).
If EPA determines that these conditions can be met!
by the "Vulcanus" — and on the basis of evidence available
to us there appears to be no reason why they cannot — we
believe that the proposed ocean incineration activity can be
reconciled with the letter and spirit of the ocean dumping j
law and carried out with safety to human health and the marin
environment.
We believe, however, that prudence requires that a-
A ?&> r* S*
-------
8
t
JL
2
3
4
5
0
7
8
9
10
11
12
13
14
15
16
17
13
19
20
21
22
23
24
25
i
t
i
i
t
i
30 !
j
least the first shipload of Agent Orange be incinerated under
a narrowly circumscribed research permit and with close |
monitoring of combustion efficiencies, Agent Orange destruc-
tion completeness, TCDD release, and phytotoxicity to marine
plankton.
The National Wildlife Federation would support the
Air Force proposal under the indicated circumstances as
environmentally sound„ consistent with the law, and compatibL
with the best interests of the public.
Thank you.
(The prepared statement and attachments follow:)
023-4330
-------
¦vm '•
'• i ..
^vT'UW-
' National Wildlife Federation
. 12 16TH ST, N.VV . WASMINCir >N\ DC 20036
Phono 202-483-15 SO
STATEMENT OF KENNETH S. KAMLET
Ort 6EHALF OF THE NATIONAL WILDLIFE
FEDERATION AT EPA TECHNICAL MEETING
ON OCEAN INCINERATION, WASHINGTON
FEBRUARY 19, 1975
/O^)
%.c. (U^J
My name is Kenneth S. Kamlet. I appear at this meeting on
behalf of the National Wildlife Federation as an attorney and a
biologist. The National Wildlife Federation, headquartered in
Washington, D.C., is the world's largest non-governmental conservation
organization with 3.5 million members and supporters throughout the
4S
.United States, Guam, the Virgin Islands, and Puerto Ricoh*^'
Federation is dedicated to the perpetuation and wise use ofy£he
natural resources of the North American Continent. We h>rve followed
closely the Federal ocean dumping program over the^tfast year
and-a-half and nave repeatedly spoken out^ertjainst the dumping of
harmful wast1? materials and in fav>«fof recycling of useful materials
an<
.ner less damaqirTC
:er nat i\
5
are assembled here today to consider a proposal by the
United States Air Force to dispose of 2.3 million gallons of Agent
Orange nerbicide oy ocean incineration on board a specially designed
incinerator shio. The incineration would take place during three 7-
to 9-Jay periods in a designated area 50-60 miles clear of norna.l
i ;'i.ng lanes end on the open tropical sea downwind (west) of
Jonnston IslnnH. ,1HT —i»f'. i~,—3-r—T&T. The proposed disoosal. location
is 120 •nil"'" f r O'n r he nearest land.
-------
National Wildlife Federation
-2-
I'he disposal of Agent Orange is a matter of great
environmental significance, because a contaminant present in the
Orange—2 , 3,7,8-tetrachlorodibenzo-p-dioxin, otherwise known as "TCOD"
or simply, "dioxin" — has been shown to cause birth defects in
exDer imental animals. It has also been implicated in the increased
incidence of human birth deformities in Vietnam in the late 1960's. as
a result of the widespread military use of Agent Orange during the
Vietnam | war. " 14—It is unclear to what, if any, extent
the individual herbicide components of Agent Orange -- 2,4,-D and
2,4,5,-T — may themselves be teratogenic or otherwise toxic to man
^ \ But s«e -fooiootc U. aaA ftffeMoiX-d)
and beast.^ In the interest of prudence, the Secretaries of
Agriculture, HErt and Interior jointly announced in mid-April 1970 the
suspension of the registration of 2,4,5,-T for most uses. In
September 19.71, the Secretary of Defense directed the Joint Chiefs of
Staff to dispose of both U.S. and Vietnam stocks of Agent Orange. The
Air Force, which was assigned this responsibility, favors ocean
incineration as the preferred method of disposal^ j^al though it would
pr^numa'Dly not be averse to reformulation and resale of the Orange if
tiie necessary FIFTlA certification were forthcoming^^
Tne National wildlife Federation feels a responsibility to
participate in the deliberations over the Air Force's ocean disposal
proposal, both because of our concern for the marine environment and
I
because |of out role in establishing EPA's regulatory jurisdiction over
ocean in-'.iner =ition activities. Thus, in large part, as a result of
the federation's efforts the Shell Chemical Comoany was required
-------
National Wildlife Federation _3_
.•several -.1011 Mis aao to secure KPk ocean dumping nermi ts^|^> for the
oc3an incineration of 4 ship loads of organochlor ine wastes. Based on
a review of available European studies which showed the efficiency of
organochlorine destruction to be great and the environmental impact of
the resultant exhaust vapors to be negligible, we gave our qualified
support to| Shell's ocean dumping permit request. This support was
expressly conditioned by our insistence that "every aspect of the
incineration process and its aftermath be followed, measured,
supervised, and evaluated, and that the operation be abocted at the
first sign of anything untoward." It would almost be understatement
to describe as "exhaustive" the research and monitoring effort that
accompanied the first 2 Shell incinerator runs — carried out under a
circumscribed "research permit". The results of these studies
unequivocally confirmed the complete safety of an approptiately
conditioned and executed high-temperature ocean incineration ooecation
when applied to organochlorine wastes of the Shell type.
Ocean incineration is no panacea, however. In the view of
the National -iildlife Federation its usa is appropriate only under the
following three circumstances: (1) The waste to be disposed of must
be susceptible to essentially complete combustion. Wastes containing
significant quantities of heavy metals and other inherently
non-cleg r ad able materials are not suitable candidates for incineration
absent adequate ore-treatment or stack scrubbing to remove materials
refractory to thermal destruction. (2) There must be available no
environmentally more acceptable treatment, disposal, or recycling
-------
National Wildlife Federation
alternative. If a valuable resource can be salvaged without
environmental risk, this option should be pursued in preference to
disposalj or destruction. (3) Each waste for which incineration at
sea is beijng considered must be evaluated on its own merits. Waste
combustion! efficiencies and exhaust gas toxicities will vary from
waste to w,aste and must be determined and monitored on a case by case
basi*s{<^Apjpropr iate disposal locations must also be selected in each
individual case.
In consideration of the above principles, the National
Wildlife Federation does not object, from a strictly technical and
environmental standpoint, to the Air Force's properly-conditioned
ocean incineration of Agent Orange. Extensive Air Force tests,
1
enploying land-based incinerators, justify the expectation of
shipboard destruction efficiencies of well over 99%. And, although
reformulation or reprocessing of the Orange with recovery of herbicide
for sale and reuse may be technically feasible, in our opinion there
3r? too many uncertainties surrounding the herbicides involved to
i
IMotity the environmental and health risks of their further
dissemination without careful deliberation and studv. From the
I
standpoint of the environment, destruction by incineration on the ooen
ocean ntay. oe the best course of action for the renainin
-------
National Wildlife Federation
-5-°
ocean .'lu.noinq low -- there may be no ocean dumping of even trace
ivnounts o|f any chemical warfare agent. Since Agent Orange is
indisputably a chemical warfare agent, .long used as a defoliant in the
Vietnam w|ar, it may be disposed of at sea only if no detectable traces
enter oce|an waters. The Air Force's proporal must be weighed
against this legal criterion.
The results of 2 laboratory, 2 full-scale, and 1 industrial
prototype scale, incineration studies on Agent Orange are summarized
in the Ait Force's environmental impact statement.
A Mississippi State/USDA laboratory study incinerated 5-6
i
grams of Agent Orange at temperatures in the 700° to 1000° C range.
No heroiclide was detected in benzene impingers through which
combustion gases were passed. However, 2,4,-D and 2,4,5,-T free acids
in the 2.0-200 ppb range and 2,4,5,-T isoocytyl ester in the 0.70 to
3 70 ppb range were found in extracts of particulates in a pyrex wool
particulate trao. These results indicate that, at 1000° C, traces of
herbicides may be volatilized and carried out of the burning range of
the furnace. Complete combustion of the Agent Orange starting
'oatecial areoear« nevertheless to have been achieved. 3"~/"—( D10 , .
D-3 ) .
Another iffSnratory study, this time conducted at Kelly Air
Force Base, inc iner atedNe total of 14.12 ml of Agent Orange at
combustion temperatures of\7 4 0 to 950O c. At 920° C, total discharges
of 2,
-------
National Wildlife Federation _6_
l Oif!
: he I rAii-rno r ized results whether any identifiable Aqent Oranqe
wa
present in the discharges. (EIS, o. ,D-6).
A full-scale study, carried
incinerated 37 gallons of Oranqe (dur
temperatures ranging from 1730° to 23
Combustion gas analyses of condensibl
samples yielded no detectable herbicide components. For one run using
out by the Marquardt Company,
ing Phase II testing) at
60° F (943° to 1293° C).
products in ten 14-liter
herbicide concentration of 19
dducts. It is unclear from the
a sample yolume of 140 liters a total
ppm was detected in the combustion pr
summarized results whether any identifiable Aqent Orange was present
in the exhaust gases even with this large sample volume. (EI3, o.
D-8) .
A second full-scale study w.is carried out bv the (iarauardt
Company in conjunction with the Air FDrce on 28 drums (1540 gals.) of
Orange incinerated at temperatures ranging from 2273° to 2772° F
(1245^ tol-1522° C). In this study, wpich appears to be most directly
co.ny'arable to incineration conditions
"Yulcanus", no heroicide constituent v
etf.luent v^hen operating with slot type
D-10 - 0-.11; Appendix E).
on the incinerator ship
as detected in any system
injection nozzles. (EIo, pp.
Finally, an industrial prototype scale study was conducted
by Combustion Power Company on a total of 39 gallons of Oranqe
incinetaat fluidized bed temperatures ranging from 1490° to 1530°
F (010n to H32° C). Maximum herbicide concentrations in the exhaust
-------
National Wildlife Federation 7
q.3 5?s w? rje 0.3196 to '1. 063 ppb for 2,/,-D and D. 5418 to 10.9G npb for
2,4,5,-T. In no case did relative^, 4 ,-D and 2,4,5,-T levels
correspond to those of raw Agent^)r ange (EIS, op. 0-15, E-(I-l)).
Although the Marquardt Company's General Manager has stated,
and the /Jir Force has agreed, that " [d]ata from one type of combustion
system cajnnot be assumed to apply to a different type or size
combustioln system without extensive testing to validate the
assumptio|n" (SIS, pp. 0-64, 0-68 ), we believe the data available to us
make it probable that full-scale incineration of Agent Orange can be
carried out to below detectable limits when the following conditions
are roe t:
(1) Combustion temperatures exceed 2280° F (1246° C) ;
(2) Dwell ti"ie exceeds 0.14 sees.;
(3) Fuel-to-air ratio is approximately 0.1;
(4) F
-------
National Wildlife Federation _Q_
If up A 'Jetennines that these conditions can be met by the
"Vulcnnus" -- and on the basis of evidence available to us there
appears to oe no reason why they cannot 5_/ — we believe that the
proposed ocean incineration activity can be reconciled with the letter
and spirit of the ocean dumping law and carried out with safety to
human health and the marine environment.
We believe, however, that prudence requires that at^ least
the firstjshipload of Agent Orange be incinerated under a narrowly
I
circumscribed research permit and with close monitoring of combustion
efficiencies. Agent Orange destruction completeness, TCDD release, and
ohytotoxicity to marine plankton. 6 /
(The National Wildlife Federation would support -.he Air Force
proposal under the indicated circumstances as environmentally sound,
consistent! with the law, and compatible with the best interests of the
public .
-------
National Wildlife Federation
-9-
footnotes
1 / 3y legal memorandum of January 23, 1974, EPA took the position
that the ion-ship disposal of wastes at sea by incineration was not
"ocean dumping" within the meaning of the Marine Protection, Research,
and Sanctuaries Act of 1972. It therefore disclaimed regulatory
jurisdiction over an ocean incineration plan of the Shell Chemical
Company, j Subsequently, in September 1974, after the National Wildlife
Federation challenged this position, EPA reversed itself and assumed
jurisdiction over the Shell disposal operation.
la/ One promising reprocessing; alternative,' which recovers 2,k-D
es"ter andj other marketable materials, has recently been called to
our attention by Paul E. Des Rosiers, E^A Office of Research and
Development. According to Mr. Des Rosiers, this technique would
allow 2,^-D ester to be distilled out of the Agent Orange mixture
free of dioxin contaminant (within limits of detection). The
dioxin and 2,4,5-T residues would then be subjected to exhaustive
chlorination, permitting the recovery of marketable carbon tetra-
chloride ,Jhvdrochloric acid, and carbonvl chloride (phosgene).
In the view of the National Wildlife Federation, consjderation of
this alternative by EDA as a means of disposition for the Air Force's
present Agent Orange stores must, in addition to technological
considerations, take into account: (1) The length of additional
storage t!lme reauired before Drocessing facilities are on line and
the risks!of spillage, etc. during this interval: and (2) The
environmental risks associated with the dissemination of large
amounts o'f even totallv "pure" 2,4-D herbicide.
\'i thi regard to environmental risks, laboratory studies have
shown thajt purified 2,4-D can cause birth defects in hamsters, mice,
and chick! enbrvos. I attach as_ Appendix I to this statement an
unpublished research report by Dr. -Tacaueline Verrett of the Food
and Drug Administration. Dr. Verrett's studies demonstrated the
induction) of abnormalities in chick embryos when l.bS milligrams of
purified '2,'i-D was injected into eggs (aoorox. 30 oom). On the
other hand, it is doubtless true that "most chemicals under suitable
laboratorjv conditions could probably be demonstrated to have
teratogenic effects ... if dosage were raised high enough . . . ."
(ELS, r. fel).
If EPA chooses the renrocessing r<~>ute, it should do so on the
basis of a careful weighing of associated risks and benefit".
2 / The jocean dumping law, in section 101(d), unqualifiedly prohibits
the ;]umpi;ng of any radiological, chemical, or biological warfare
agent. Unlike "The Convention on the Prevention of Marine Pollution
by Dumping of Wastes and Other Matter," the U.S. statute contains no
exemption; for warfare agents that are "rapidly rendered harmless" when
dissolved; in seawater, or are present merely as "trace contaminants",
nevertheless, it would be unreasonable to extend the ban on dumoing of
wacfare agents to levels of these materials below the best state-of-
t'v^-ari: ljimits of detection (for Agent Orange, the detection limit is
in c:. i-ar t-per-Lr ill ion/par t-par-bi 11 ion range).
-------
National WiSdliie Federation
-10-
3 / <>gent Orange is a mixture of: two herbicides, 2,4,-D ana 2,4,5,-T,
present in an average initial ratio of 50.9 to 43. 78 (by we in . L).
(EI.S, pp. j E-(G-3), E-(I-l)). Since only the parent mixture has a
known history of chemical warfare use, the presence of traces of
2,4,-D and 2,4,5,-T in incinerator exhaust gases invokes the warfare
agent prohibition only when these components are discharged in a
proportion characteristic of Agent Orange. The different heats of
formation|(EIS, pp. 39, E(A-l)) and chlorine content of 2,4,-D and
2,4,5,-T almost insures that thermal dechlorination and pyrolytic
cleavage of these two compounds will occur at different rates and to
differentjdegrees, resulting in a progressively greater divergence
from the starting ratio of uncombusted herbicide. Volatilization
without combustion of the two herbicides without altering their
starting ratio would also appear unlikely. It should be noted that
the ocean'dumping criteria (section 227.31 (b)(5)) require strict
regulation of herbicide dumping in whatever levels or proportions.
The necessity of close regulation is not at issue; only the necessity
of total prohibition.
i
4 / "Pre'rieat of 'Orange' Herbicide fuel prior to injection in the
combustion chamber [is] an important combustion efficiency parameter.
The RP£ [Relative Pyrolysis Efficiency] [is] improved significantly
where the |'Orange' Herbicide fuel was preheated to 175° F. Preheat of
'Orange' Hecbicide fuel to at least 90° F [is] required to accomplish
acceotabl-^ fuel injection characteristics." (EIS, p. D-ll). The high
viscosit/ of Agent Orange necessitates preheating "to obtain the fluid
properties necessary to achieve rated fuel mass flow rates." (EIS.
PP. E-29, 'i-l ). See also CIS, pp. 13-10, *-36, tf-37, E-41, E-48, S-52,
2(3-13), E- 54. If amoient temperatures in che disposal area
during incileration runs by the "Vulcanus" are insufficient to
maintain tjhe Agent Orange at 90° F, a "fuel tank preheater" (EIS, p.
'-10) nay
have to oe installed.
5 / For Shell-type or]anochlorine wastes, the "Vulcanus" is caoable
of flame temperatures of at least 1360 to 1560° C, and of excess air
1evels of j2 5-100%.
_6_ / The most obvious environmental impact parameter to monitor for a
herbicide jas potent as Agent Orame is toxicity to marine
phytoolankton. Thus, data presented at CIS, pp. 55 , 56, indicate that
ohenoxy herbicide concentrations of 50 to 300 opm caused -a 50%
reduc tion
der ivative
in growtnof unicellular marine algae, and certain 2,4,-D
s caused up to a 41)% decrease in CO2 fixation by
.•>hytool an kit on. Radioactive carbon (C.14) uptake studies would be
expected t'.o afford te greatest measurement sensitivity. "We recom-nen:)
that iio'ii toting of the i ic irer a t ion operation include studies of
jmoact on
tos yithet ic r>r oduc t ivi ty by the uptake method.
-------
X.
The Effects of 2,4-D, 2,4,5-T and Their
Contaminants on the Developing Chicken
Embryo.
H. Jacqueline Verrett, Ph.D.
Reproductive Physiology Branca
Division of Toxicology/ADS
Bureau of Foods
Food and Drug Administration
-------
TABLE 1
Effects of 2,4-D and 2,4,5-T
on Developing Chicken Embryos
LD-50
(mg/egg)
LD-50 (mg/egg)
LD-50 (mg/egg)
Mortality
vs Dose
One or More
Abnormalities vs
Dose
Two or More
Abnormalities vs
Dose
Treatment at
Treatr.'snt at
Treatment at
C\* "'.ooup.d
0 Hours
96 Hours
0 Hours
0 Hours
2,4-D (Ir.pure)
*
0.189
2.33
793.5
2,4-D (Purified)
**
0.593
1.46
3.992
2,4,5-T (Impure)
0.113
0.0488
**
234.2
2,4,5-T (Regular)
11.37
0.403
5.25
6661.2
2,4,5-T (Purified)
*
0.467
2.50
**
* Slope of line is negative
•:*Slope of line is not significantly different frcm zero p=0.05
-------
DEPARTMENT OF THE AIR P?»CE
WASHINGTON 20330
OFPICX O* I Ml" Ar,c;|S I AN 1 SrC^f.FARY
February 18, 1975
Dear ^r. Kamlet:
In our conversation last week, I mentioned that I
would (address your three questions in writing. I have
attempted to answer these questions in a straight-forward
mannerj; however, as you know from reading our impact
statement, much more technical data is available.
I
Wje expect to have our technical personnel in town
this week; and should you want further explanation, I am
sure a|meeting can be arranged.
Sincerely,
Enclosures-3 f/ BILLY E. WELCH, Ph.D.
Special Assistant for
Environmental Quality
Mr. Kenneth Kamlet
Resources for Defense
National Wildlife Federation
Room 22>0
1412 16ith Street, N. W.
Washington, D. C. 20036
-------
In the development of effective herbicides for tactical
purposes, research was conducted over a period of many years.
As an example, over 26,000 chemical compounds, including every
herbicide that had been marketed up to about 1969 in the U. S.,
as well as many from foreign sources, were evaluated. These
evaluations did include various forms of 2,4-D and 2,4,5-T.
However, we can find no evidence that 2,4-D and 2,4,5-T were
separately used in operational systems for tactical purposes.
ATTACHMENT #1
-------
Incineration or combustion, in the sense we are discussing
it, is a | form of rapid oxidation. When we burn common fuels
consisting of carbon and hydrogen in various combinations, we
can, in tlheory, obtain complete combustion, producing com-
bustion products consisting of carbon dioxide (CO2) and water
(H2O). Usually, however, the combustion is not 1007,, complete.
In this case, a breakdown of the fuel will occur, and a partial
chemical reaction takes place; i.e., the carbon was released
from the jfuel to combine with oxygen to form carbon monoxide or
pyrolyzates of the original material. It is thus often con-
fusing to|refer to a combustion process in terms of efficiency,
though it |is useful to do so for calculation purposes.
In tble case of Herbicide Orange, the hydrocarbon has had
chlorine a'dded. The products of combustion will, in theory, be
CO2, H2O and HCL. Here, too, the combustion will be less than
1007o compl'ete, even though we do expect the molecules of Orange
to be broken down. some CO will be formed; and, when the mole-
cule is not completely broken down, various forms of the basic
constituents will result. In our case, something other than
i
Herbicide Orange will result, as evidenced by the data reported
in the environmental impact statement. ,
Although Herbicide Orange is a 50/50 mixture of 2,4-D and
2,4,5-T, it is not likely that the same type of breakdown will
ATTACHMENT #2
-------
occur in flu* molecules of both the 2,4-D and the 2,4,5-T. We
really cannot comment further on this, since our results did
not show either 2,4-D or 2,4,5-T in the combustion gas.
Even if some form of 2,4-D and 2,4,5-T were to emerge
from the stack, they would not be, in all probability, in a
one tn one ratio nor could one call the gaseous effluent of
these projducts Herbicide Orange.
-2-
-------
Thjere were two studies conducted by the Marquardt Company.
The fir|st study in 1972 determined that use of the SUE burner
to destroy Herbicide Orange was feasible, but the proper
operating parameters to insure efficient combustion were not
determined. In the follow-on study (reported in Appendix E),
it was determined that Herbicide Orange can be effectively and
safely destroyed. Acceptable operating parameters were
selected as: measured combustion chamber temperatures of
2400°-28|00°F; dwell time equal to or greater than 0.14 seconds;
fuel-to-air mass ratio of about 0.1; and excess air greater
than 30%'. For a system operating within these parameters, it
was determined in the test program that the combustion gas is
free of Herbicide esters, acids and TCDD at the detection limit
I '
for each compound.
The (amount of material in the combustion gas stream that
can be de|tected depends on the ability of the analytical
instrumen|tation to see a certain amount of the material and
the length of time a sample of the combustion gas is collected.
The amount of material which would have to be injected
into the analytical instrumentation was determined (see Page
E-G-2). It was found in the case of dioxin that the injected
sample muslt contain at least 22 nanograms in order to be
detected. If one liter of combustion gas was collected and if
ATTACHMENT #3
-------
it contained 22 nanograms, the instrumentation would detect
the dioxin, and we would report the concentration in the com-
bustion gas as 22 nanograms per liter. If the concentration
in the gas stream was only 11 nanograms per liter, then two
liters of the combustion gas would have to be sampled to
collect 22 nanograms and so on. Since we do not know in advance
what the; concentration is likely to be, we draw the combustion
air through our sampler for a long enough period of time to
hopefully accumulate enough material for it to be detectable.
The actual concentration per liter of combustion air which
would have to be present to be detected can then be calculated.
As an example, from Table D-4, Page E-(D-23) select Run IV
i
for the Combustion Gas and find that a sample was collected for
60 minutes at a rate of 4.17 liters per minute (column headed
STP). Thlus a total of 250.2 liters of combustion gas was passed
through o'ur sampler. Our detectable level in the analytical
instrumentation is 22 nanograms. By dividing the analytical
detectable limit (22) by the total number of liters collected
(250.2), we can determine that the concentration of TCDD in the
combustion gas would have to be 0.087 nanogram/liter to be
detected. This is the lower detectable limit shown for dioxin
in Table G-2, Page E-(G-13), but rounded to 0.09. This means
that, if the concentration of TCDD in the combustion gas was
-2-
-------
0.09 nanograms per liter, by collecting 250.2 liters, we can
accumulate 22 nanograms for injection into our instruments,
and it would be detected.
-3-
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
31
CHAIRMAN BIGLANE: Ken, thank you for your usual
well researched statement.
Mrs. Nancy Shower (phonetic) of the Center for Law
and Social Policy has indicated her intention to make a
formal' statement.
STATEMENT OF MRS. NANCY SHOWER, CENTER
FOR LAW AND SOCIAL POLICY
MRS. SHOWERt I am Nancy Shower from the Center for
Law and Social Policy. As Dr. Welsh mentioned earlier, he
has heard comments from our Center, from Dick Frank, who
unfortunately is unable to be here today. I would like to
make a brief statement.
It is our considered opinion that the concerns of
the Ocean Dumping Law should be focused on what comes out of
the incinerator,, rather than what goes into the incinerator
It is our position that Herbicide Orange, after incineration,
does not retain the chemical or biologic warfare characteris-
tic. With that regard we support the Air Force's environ-
mental impact statement.
Thank you.
CHAIRMAN BIGLANE: Mr. Donald D. Carruth,
representing the American Eagle Foundation, has indicated he
wishes to make a statement.
^$cme f^cporting nij
5202) «20-48Sa j
-------
1
2
3
4
5
8
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
32
STATEMENT OP DONALD D. CARRDTH, PRESIDENT,
AMERICAN EAGLE FOUNDATION
MR. CAJtKDTH: Mr. Chairmanr ladies and gentlemen,
toy name is Donald D. Car ruth, President of the American Eagle
Foundation in; Rosslyn, Virginia. I do not have by intention
a written, prepared statement for presentation today. Our
statement will come to you prior to March 5.
I would like to say, however, in support of the
two witnesses, Mr. Kamlet and Miss Nancy Shower, that we
feel and have reason, good reason to feel, that incineration
of Herbicide Orange should be given reasonable consideration
by EPA as it relates to the issuance of the required type
permit for the destruction of Herbicide Orange.
We say this on the basis that after careful review
of both the April 1974 publication of the revised draft of
the environmental impact statement relating to the destruc-
tion of Herbicide Orange by incineration and also the formal
EIS statement that went to the Council on Environmental
Quality, that there appears to us to be a justifiable basis
for the destruction of this Herbicide Orange, particularly
if it 18"* found that reformulation does not produce the resuli
that are intended to be reached through the reformulation
process.
It is also my understanding that the chemical
companies, four chemical companies, have some degree of
4f/n« Reporting Company
{202) 628-4836
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
33
reluctance to attempt the reformulation on their own, or the
recycling of Agent Orange, per se.
Z would also like to state that there was a real
degree of concern on a large number of people, by a large
number of people, as it related to the monitoring of the firs
two shiploads of Shell chemical Company's waste produced at
the Deer Park facility of the Shell Chemical complex. Exten-•
sive monitoring under the jurisdiction of the EPA, which was
supported by at least seven major areas of interest as to the
determination as to what really was coming out of the stacks
and what potentially was the environmental degradation on the
marine environment, was of extreme interest to an awful lot
of people, particularly those in the Gulf area.
Further, I would like to say that EPA has done a
very fine job of overseeing and coordinating the monitoring
of these first two shiploads of Shell Chemical Company waste
by the motor vessel "Volcanus."
Some of you have attended the conference that was
held on February 3, 4, and 5, at the Mayflower Hotel here in
the city, having to do with the general subject relating to
the treatment or disposal of various types of chemical waste
waters. I will include a copy of that presentation that I
made along with our formal comments to be submitted to you
prior to March 5.
Thank you.
f^cporlin^ (Company
<202) 626-4088
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
34
CHAIRMAN BIGLANE: Thank you, Mr. Carruth.
Now, are there individuals or other groups who
would like to make a formal statement at this time? If so,
would like to see your hands.
Seeing no other person, then, are there those who
wish to ask clarifying questions at this time?
Ken Kamlet.
MR. KAMLET: The environmental impact statement
Indicated that there are viscosity problems with the. Agent
Orange. At low temperatures, below 90° F. there are problem!
injecting this material into the incinerator, and as you
increase the pre-heat temperature prior to injection, you
improve both the efficiency of injection and also the effic-
iency of incineration.
I would like to ask the Air Force people, repre-
sentatives of the corporations, or EPA, anyone who is familic
with the situation, whether ambient air temperatures off
Johnston Island at the time the disposal operation would tak<
place are such that one would anticipate that the temperature
of th.e fuel, the herbicide fuel prior to injection, would be
expected to exceed 90°, and whether pre-heaters could be
installed to further elevate that temperature to say 175°, i:
that were determined to be desirable?
CHAIRMAN BIGLANE: Fine. Dr. Welsh, would you lik(
to answer that?
^Icmc ^sporting dotnpcinij
1202) 626-4886
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
35
DR. WELSH: Z can start that. No. lr you have to
keep in mind that in the work we were doing in the impact
statement, the ambient air temperature in Los Angeles was
about 56 or 55 degrees F. as I recall. We would not antici-
pate the ambient air temperature or the ocean temperature at
Johnston Island would exceed 90°. It would be in the range
o£ 82 to 84, something like that, at that particular point in
time.
How, Z can't answer whether or not had the tempera-
ture in LA been 82, we would have felt the need to heat this
stuff. This stuff solidifies something on the order of 45°P,
MR. KAMLET: Could a pre-heater be installed, were
one considered necessary?
DR. WELSH: Z can't answer a particular question
like that.
MR. KAMLET: Do you know what type of injection
nozzle is present on the ship, and whether the nozzle compare
favorably with the type of nozzle that was found to give the
best results in the studies reported in the impact statements
DR. WELSH: Our people would look at the type of
system they had for introducing the contaminant. We had
people that would drive out and take care of these details.
It was their professional opinion this would handle the type
of material we are talking about, the type of viscosity
involved.
sQcms Reporting dotnpany
(202) 628-4083
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
V.4
25
36
CHAIRMAN BIGLANE: Could you speak up, Doctor?
DR. WELSH: My apologies.
MR. KAMLET: I would suggest, Mr. Biglane, you
look into .those questions further before making the final
decision.
CHAIRMAN BIGLANE: Thank you.
Yes? Could you step to the lectern and give your
name?
MR. MITCHELL: My name is William Mitchell. I am
President of a chemical company in Newark, Hew Jersey, being
formally owned by Diamond Shamrock, one of the original
producers of the defoliant Orange.
My question is, does this application and the
intent or purpose of this meeting preclude any future or
further interest in the recycling of the product?
My company at its own expense has developed a
process for the reclamation of the product, reformulating it
into usable and much needed raw materials to go back into th
production of food for this country and other countries.
In summary my question is, is the current considex
tion precluding further consideration of recycling?
MR. JOHNSON: I believe the points in my opening
remarks were we at EPA would like to consider further re-
cycling. We cannot evaluate recycling without additional
information over and above what we currently have. We cannc
-y$cme f^eporiing (^ompanij
. <202) 626-4883
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
37
order the Air Force to go into a recycling mode. The initia
tive to do it would have to come from the Air Force.
MR. MITCHELL: Thank you very much. I did not get
your opening remarks, due to being tardy.
MR. ROGERS: Would you take a few questions?
MR. MITCHELL: If I could.
MR. ROGERS: Would you mind telling us the name of
your company?
MR. MITCHELL: The name of the company is .Chemic-
land:." Corporation, 80 Lister Avenue, Newark, New Jersey.
I am President and owner of that company.
MR. ROGERS: Your company was one of the original
manufacturers of what exact chemical?
MR. MITCHELL: This plant was owned by Diamond
Alkali. I acquired this facility in 1971. I converted a
portion of the facility to the manufacture of alcohol. We
have a distillation unit which lends itself to this conver-
sion. The plant is still basically 2,4,-D producing unit,
which has been reactivated.
MR. ROGERS: When you said you have a process for
reformulating the product, what would be the product of the
reformulation process?
MR. MITCHELL: The end product would be a formula-
tion utilizing the sodium salts of 2,4,-D and 2,4,5,-T,
which would come from the reclamation. This would be used
^4cme
'<30?.j
-------
1
2
3
4
5
6
7
S
9
10
31
12
13
U
15
16
.17
18
19
20
21
22
23
24
25
38 !
primarily as a brush killer.
Now, this would be normally decontaminated of
dioxin due to our process.
MR. ROGERS: Would you have a dioxin residue?
of 1974, has fairly well established to our satisfaction
that the dioxin content can be reduced, certainly to accept-
able standards, established by the EPA or the Air Force.
MR. ROGERS: Would you be able to reprocess in
quantity terms the entire amount of herbicide Orange?
MR. MITCHELL: Yes. We would expect it would take
us two years to carry out this reprocessing, in addition to
our normal production of 2,4,-D.
MR. ROGERS: You would have no waste product from
that reprocessing?
MR. MITCHELL: No, sir. j
MR. ROGERS: I take it there is a market for your
end product, or you would not be interested in it? j
MR. MITCHELL: There is an extreme shortage in thej
world today of 2,4,-D, particularly, and 2,4,5,-T products, j
In the United States today, Dow Chemical Company is
the major producer of 2,4,-D. My plant has the capacity, we|
f
aren't up to full capacity; my plant has the capacity of |
MR. MITCHELL: No, sir
Based on our research, which started prior to July
being the second largest producer of 2,4,-D in the United !
-------
i
2
3
4
5
0
7
8
B
10
11
12
33
'14
15
IS
17
28
19
20
21
22
23
24
25
39
States. Transvalve, in Jacksonville, Arkansas, has a
capacity of eight million pounds, which would make them No. 3
And Chipman is in the business. I am not aware of their
capacity. That is the extent of the capacity, to my knowledg
in the country.
Now, the overseas demand is dire. The demand is
such that our production is sold out for 1975. Now, the
industry last year experienced critical shortages of raw
material going into the make-up of 2,4,-D. Basically, it is
Chlorine, caustic, and acetic acid. There has been some
relief in these raw materials this year. We don't know how
long the raw materials will be available. We feel very
strongly against the destruction of approximately 23 million]
i
pounds of raw materials which could be reprocessed into a
usable product which would go towards the production of food
MR. ROGERS: Mr. Mitchell, just one or two final
questions, if I may.
In your end product, would it be possible to segre
gate the usable chemicals into products containing 2,4,-D and
products containing 2,4,5,-T?
MR. MITCHELL: It is possible. We have accomplish]
this, but this is not economically feasible, frankly. It is
possible, to an sire r your question. Further, a study on our
part and the markets might change the economic feasibility ojf
breaking the ingredients down.
dismps.xwp
{302) 320-4338
-------
1
2
3
4
5,
6,
7
8
9
10
II
12
13
14
16
17
18
19
20
21
22
23
24
25
t
40
MR. ROGERS: Thank you.
MR. JOHNSON: Have you made known to the Air Force
the details of your process and what your expectations would
be with respect to the composition of the final materials?
MR. MITCHELL: We have had the cooperation of Dr.
Welsh, as well as his staff. We have been in communications
with them as recently as last Wednesday. We have not dis-
closed to Dr. Welsh or his staff the details of our process
which we consider proprietary. We would expect at some poin:.
in time, if our interest could be brought to fruition, that
we would make full disclosures. But bear in mind that all oi?
this development work has been done essentially by a small
business with its own resources.
I would compliment Dr. Welsh and his staff on the
cooperation they have given us, and we hope to continue to
work with and towards a positive goal rather than a negative
goal of the destruction of the material.
Now, I would like to again go on record and repeat
what was stated to Dr. Welsh last week as to my company's
position, and that is that we are confident that we can
recycle the material. We are not so confident as many other
small businesses are or are not today that we could be
restricted by severe regulations unduly imposed.
We have to operate for a profit. Our proposition
would return a profit to the Air Force so that there would be
s$cmc $eportin
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
41
a recovery to them, but the monitoring and the amount of
public meetings and so forth and red tape involved could-pre-
clude our interest in this project which could cost the*
government the loss of considerable amounts of money, as well,
as loss of valuable raw materials going into an incinerator.
MR. KAMLET: May Z ask Mr. Mitchell one question:
You indicated that the dioxin levels would be reduced to wha:
you felt were acceptable levels. Could you indicate for us
more specifically what those, levels would be?
MR. MITCHELL: I believe the impact statement
refers to a safe level of 1/10 part per million. We are qui-:
confident that we can totally eliminate that. I only want to
leave myself a little margin for human error. It is possible
by our process — as a matter of fact, there are references
in the impact study, which would support our findings. I am
not going to give you those particular references, because I
might have a competitor in the audience, but it is possible
to completely destroy the dioxin content in the material. I:
would leave no residue.
CHAIRMAN BIGLANE: We have one question from the
floor. Stephany Harris from the Health Research Group.
MS. HARRIS: I would like to know from Mr. Mitchell
is it economically feasible to completely destroy the dioxin
content?
And secondly, what will happen to it? Will it be
Reporting C^o/npany
(7.02) S28JS33
-------
I
1
'2
3
4
5
6
7
8
9
10
n
12
.13
14
15
IS
'17
18
19
20
21
22
23
24
25
42
converted, and will it be a waste product? If it is a waste
product, what will be done to it?
I would like to ask Mr. Johnson, he said the dioxin
could be removed and dealt with. Could he explain that? To
what levels and what does he mean by "dealt with."
CHAIRMAN BIGLANE: The young lady had three ques-
tions. Did you get the first two?
MR. MITCHELL: I will try to answer it with one
t
answer. It is economically feasible to elaborate without the
restrictions and red tape, just from a manufacturing point o::
view, it is quite feasible.
Secondly, the dioxin is totally decomposed. There
is no residual using our process. And here again, there are
references in the impact statement which would verify what I
am telling you.
CHAIRMAN BIGLANE: Are there further questions for
Mr. Mitchell before he leaves the lectern? We will get to
Kr. Johnson later.
VOICE: You mentioned who the leading companies
were —
CHAIRMAN BIGLANE: Would you give your name?
MS. HINGLE: Maureen Hingle from the Environment
Defense Fund. You mentioned the capacities of Dow, and you
have the capacity to be No. 2. Could you tell me what your
current capacity is in production of the 2,4,-D?
A
t.201) 820-a33tJ I
-------
1
2
3
4
5
8
7
S
9
10
11
12
13
14
15
IS
17
18
19
20
21
22
23
24
25
f
43
MR. MITCHELL: The capacity of the plant is 12 mil-j-
lion pounds. We have not reached our full output capacity.
We have a capability to expand to 20 million pounds which is
being studied at this time.
MS. HINGLE: How long would it take you to repro-
cess the amount that is now stored?
MR. MITCHELL: I think I mentioned a time element
of two years. Now, we have such warehouse space in Newark,
that if it would assist in the program, we could store or
transfer the storage at Gulfport to our location. We would
have to — we also are on the Snake River. I have half a
million gallons of bulk storage. We could accommodate some
of the bulk material from Johnston Island, but only to the
extent of half a million gallons at one time.
This is something that we only touched on with Dr.
Welsh. We could program this and that was our least consid-
eration. The time element would be about two years.
MS. HINGLE: Does the economic feasibility also
take into account the fact that Agent Orange has to be de-
barreled and transported from Johnston Island to your facilit
MR. MITCHELL: As I mentioned, we have bulk handliil
<
capabilities, up to half a million gallons. I think in the
final impact report it seemed feasible due to deterioration
of the drums on Johnston Island to dedrum at that point and
ship it in bulk, or even take it to sea by the ship in bulk.
(202) 326-4B8Q
-------
1
J.
2
3
4
5
S
7
S
9
10
n
12
13
14
15
16
17
18
19
20
21
22
23
24
25
44
i
Nov, the end products which we would produce from J
the active ingredients would namely be sold in bulk/ so we j
would not have the redrumming problem. But that is really
tactical and one of the lesser problems. We felt that we
had — that is by "we," I have a staff of three Ph.D.'s who
have done the work. 1 am in marketing myself. Z can take
no credit for this development. But in being able to total
eliminate the TCDD we think is a significant accomplishment.
MS. HINGLEs I am not clear about how much of the
material is there on Johnston Island and Gulf port, Mississip]
you would be able to handle immediately. I understand one
of the problems in the disposal of all of this is the immedi
acy of action.
MR. MITCHELL: This is something that would requir
further discussion with Dr. Welsh and his staff on my part.
We have not reached that point in our discussions.
CHAIRMAN BIGLANE: Now we still have a question ou
standing for Mr. Johnson. Could you repeat the question?
Thank you, Mr. Mitchell, thank you very much.
MR. JOHNSON: The question as I understand it, I
used the terminology regarding dioxin removed or otherwise
dealt with.
We currently register pesticide products which con
tain less than 0.1 parts per million TCDD in the technical
material. And by reducing, or removed, I would mean down to]
<202) a?a-J!sa3
-------
1
2
3
4
5
8
7
8
9
10
11
12
13
14
eh
15
16
17
18
19
20
21
22
23
24
25
1
45
that level or below by the process. By "dealt with/ this
actually means a couple of things. One is if you end tip at
the end of the process with a pot full of TCDD, what kind of
nethod is available for handling this in an environmentally-
satisfactory manner. "Dealt with" means actually changing
the molecular structures. So the TCDD no longer exists but
is converted into other materials.
CHAIRMAN BIGLANE: I think we ought to take a break
at about this point. Could I see the hands of those who
would want to ask questions after the break?
There are half a dozen. So, why don't we take a
break at this point and reassemble at 11:00.
(Short recess)
CHAIRMAN BIGLANE: Ladies and gentlemen, if we cou]
reassemble, please? 11:00 o'clock.
Continuing now with our clarifying question sessior
Mr. Kamlet has raised his hand. Ken, would you come to the
lectern, please?
MR. KAMLET: I have a couple of questions for Mr.
Johnson, whom I can no longer see.
The first is, can you clarify for the record what,
if any, restrictions presently exist on the domestic use of
2,4,-D?
And secondly, you indicated in your introductory
remarks that EPA is familiar in a general way with processes
sQcme j^eporting Company
<202) 628-4886
-------
1
2.
3
4
5
6
7
8
9
10
n
12
13
14
15
13
17
18
19
20
21.
22
23
24
25
i
I
46
for the reformulation and reprocessing of Agent Orange.
Could you Indicate for the record in somewhat greater detail
what types of processes you are thinking about?
MR. JOHNSON: with respect to special restrictions
on the 2,4,-D, I am not aware of any. It is registered for
fairly general herbicide use. It is registered for weed
control on ditch banks. The one use which has been sought
and so far there is not a registration on that use, but ther<
has been Section 18 emergency use control, is control of the
water hyacinth in navigable waters. I don't know of any
restrictions put on 2,4,-D because of environmental reasons.
I am not a chemist and X would be hard pressed to
try to describe these processes, but they are basically
processes that would change the molecular structure and woul
either separate out various components or transform them into
products as much as the ones I mentioned, such as chlorine
or phosgene or carbontetrachloride.
There are three processes that end up with differ-
ent byproducts. One ends up with 2,4,-D, and a dioxin con-
taining waste residue which would have to be disposed of. Wi
would be concerned with that. The other two processes do no
end up with TCDD as an end product in any of the streams.
MR. KAMLET: I wonder if it might not be helpful
if Paul DesRosiers could describe a. process he. ran
through for me that sounded very interesting for the benefi
(202) 623-£S8a
-------
1
2
3
4
5
8
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
47
of people in the audience who might have helpful comments to
make on it.
CHAIRMAN BIGLANE: Mr. DesRosiera, would you care
to step to the lectern?
MR. DES HOSIERS: Yes, I have been nominated. I
am; not prepared for this statement, but I will see if I can
do a good job so that everybody can understand what I am
about to say.
To recap a little history, the Air Force through
an interagency agreement with EPA, the Office of Research
and Development, transferred $45,000 in 1972, to allow us to
mutually investigate the possibilities of converting Orange
to useful products. This technology at that time was bench
scale and entailed the use of high temperature-high pressure
chlorination to chemically convert via an oxidated means
Orange to useful and marketable productsi Namely, carbon-
tetrachloride, carbonyl chloride, or phosgene, and hydrogen
chloride.
The studies were performed by Diamond Shamrock
Corporation in Painesville, Ohio. A final report was issued
and submitted to the Air Force, the title being "Study of
Feasibility of Herbicide Orange Chlorinalysis."
Now, bear in mind that the date is July of *74.
The work was done in late '72 and early '73. A marketing
study was also done at this time based on a 1972 value of
^tcme Company
(202) 626-4866
-------
I
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
48
those products. And at that time the conclusion was reached
that it would be a high risk for the Air Force in conjunction
with a company, a selected company, to go about and convert
this into useful products, mainly because of the prices for
these commodities.
However, since then, the marketing possibilities
have changed substantially. For example, carbontetrachloride
in 1972 had a value of $90 a ton. It now is worth $320 a
ton. Carbonylchloride had a market value in those days of
zero to $200 a ton, zero being if there was no market and it
had to be neutralized, $200 a ton if it was favorable. It is
now in short supply and is worth $400 a ton. Hydrogen chlor-
ide had an even more unusual valuation in the 1972 period,
being worth minus $30 a ton through zero, to plus $30 a ton.
The minus $30 a ton would be a cost of neutralizing HC1. The
zero would be the cost of giving it to somebody free, and th«
$30 a ton would be the value if it were marketable.
Now, the two options presented in the report were:
(1) Total chlorinalysis, the term used by Diamonc
Shamrock for this technique. This was the most expensive
option which would have converted all of the 2,4,-D, 2,4,5,
and dioxin into useful products with total destruction below
the detectable limit in the products of dioxin.
Detectable limit for this material at that time wait
10 parts per trillion. The analyses were performed by
kcporiiny (Company
<20?.) 623-4336
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
49
Dr. Kearny and Associates in Beltsville, Maryland. The toxi-
cological studies on carbontetrachloride were conducted by
the EPA at our Georgia lab.
The carbontet in this case was found to contain no
detectable dioxin from a toxicological point of. view.
Now, that was one of the options. The. second optic
was even a more preferred option because it entailed the
distillation, simple distillation, with off-the-shelf tech-
nology of 2,4,-D ester. Let me see if I can give an indica-
tion. We have a distillation column and 2r4,-D weighs less
than 2,4,5,-T or dioxin. Therefore, it will come off as an
overhead and be condensed out. It contained no dioxin down
to the detectable limit of one part per billion. This is
substantially less than the 0.1 parts per million that the
EPA has set as the limit for dioxin.
Now, the bottoms contained 2,4,-D ester that was
not totally sent to the top of the still, all of the 2,4,5,-p
and all of the dioxin. Now, the idea behind this was to
market the 2,4,-D ester, which has a market value of $950 to
$1000 a ton. The remaining mix, the bottoms, would then be
chlorylized into useful products.
Again, I have to emphasize the 1972 figures for
these products made it a high risk situation for a company toe
go this route. However, again, as I mentioned, the prices
have gone up. Let me just state a few numbers for you to
s$cme Reporting (Company
(202) 028-4889
-------
1
2
3
4
5
8
7
8
3
10
11
12
13
14
15
15
17
'13
19
20
21
22
23
24
25
i
i
50
masticate in your mind.
If we take 2.26 million gallons of Orange* the
entire stockpile, distill it, we will essentially get 40
percent of the 2,4,-D off as an overhead. This is approxi-
mately 9-1/2 million pounds of 2,4,-D ester. That $950 a
ton, we are talking of roughly $4.5 million of material that
is ready for the market place. It won't be deposited in one
day, obviously.
Now, we will then have 60 percent of the material
or 14.3 million pounds of a mixture of all of the 2,4,5,-T,
some of the 2,4,-D, and all of the dioxin. This 14.3 millio
pounds is equivalent to 7,200 tons. To this 7,200 tons of
mixture containing the dioxin we then must add 46,000 tons
of chlorine at a cost of $120 per ton, or a cost of $5.5 mil
lion.
Now, we produce through this chlorinalysis 34,000
tons of carbontetrachloride at $300 a ton, is $10.2 million.
We produce 12,000 tons of HCl, at $60 a ton, or $724,000.
We produce carbonylchloride at 7250 tons times $400 per ton,
or $2.9 million.
Now, summing up the plusses, including the 2,4,-D
ester, we have approximately $18.3 million worth of material
that is available into the market place. Subtract from that
the cost of chlorine, and again I am talking about only |
j
materials here, chemicals. We have a net available credit o
(20£) ¦323-4338
-------
1
2
3
4
5
S
7
S
9
10
11
12
13
14
15
13
1?
18
19
20
21
22
23
24
25
51 S
I
I
$12.8 million. 1
i
I
Now, what size plant are we talking about? For
purposes of discussion, I have come up with a 12-1/2 ton per
day plant based on feed stock Orange. This will take approxi
mately two years to chloralyze the material.
That is my presentation. Any questions, please?
MISS HARRIS: As far as you know, is there enough
ohlorine available today for total chlorinalysis, and is
there enough chlorine available for the partial chlorinalysis
MR. OES HOSIERS: As far as I am concerned, we
should put aside the total chlorinalysis. This is my persona
opinion only.
There are 10 chlorine plants coming into production
between last November and say this time next year. Right now
I would say the market is very close to being fulfilled with
chlorine and it will be a glut on the market by some five or
six percent this time next year.
Therefore, that $120 per ton figure I quoted you
will go down. Therefore, we will have more credit. Again,
remember this plant isn*t going to be put on the spot in a
week. It is going to take maybe a year or two to build,
probably two years knowing the way things are going in the
construction field today.
I have to emphasize the prelimination investigation
were done by — I think personally the top dioxin expert in
the world, Dr. Kearny and Dr. Wilson and Associates at USDA.
pure tuny
(202) G2S-4Q33
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
18
17
18
19
20
21
22-
23
24
2Sl
52
They were done by a third party* not EPA.
MISS HARRIS: I would like to know about the market
ability of the 2,4,-D ester. As far as you know, is the
market fulfilled in the United States right now? Would there»
be a market for 2,4,-D in the United States, or would it havi;
to be exported?
MR. DES HOSIERS: I leave that to the expert. I
think he stated there was a market for 2,4,-D in this country
The market will change slightly next year with another plant
coming on stream, but this is again not going to appear
instantaneously on the market.
CHAIRMAN BIGLANE: Any further questions?
If not, thank you very much, Paul.
Are there additional questions?
DR. WELSH: I am Dr. Welsh, I feel that by way of
clarification regarding Mr. DesRosiers' comments on chlori-
nalysis, I should state this: As he indicated, the Air
Force did fund the studies carried out by Diamond Shamrock
and we indeed were very much interested in the potential
that this would hold. And we would agree with the EPA in a
recent press release they put out that speaks of this as an
"emerging technology." We think it is an emerging technology
but it is easy to say we will build a plant for 12-1/2 tons
or 25 tons or 50 tons or what have you and we get all these
grand, glorious sums of money coming back out of it. We had
Slavic f^epot-tinej (Company
(Z02) 828-4398
-------
1
2
3
4
o
7
8
9
10
n
12
13
14
15
16
17
18
IS
20
21
22
23
24
25
53 !
I
I
Dr. Porter, a consulting engineer with us, who visited the j
Diamond Shamrock facility, went over the cost figures, and j
j
granted that the price of raw materials has gone up and the |
I
price of the output has gone up, the cost of construction .
has also gone up. At that particular point in time, which
i
was some year and a half or so ago, you get uncertainties j
i
that say that if you do this, you might make a couple of j
million bucks, or it might cost you $10 million.
It seems to me that is sort of a rather broad swiror
of uncertainty to utilize when you are trying to solve a
problem. My experience has been with that type of uncertain^
you create a problem quicker than you solve it.
So that is where we currently think we are relative
to the chlorinalysis question.
CHAIRMAN BIGLANE: Dr. Welsh, would you entertain
a question?
i
MR. JOHNSON: I got the impression, Dr. Welsh, j
j
there was still some interest last November perhaps in com- 1
II
I
mercial chemical reprocessing of the Herbicide Orange, based!
s
on some of the correspondence between EPA and the Air Force.!
We responded in January to that particular request with an j
indication that we would consider chemical reprocessing to b|
disposed under Section 19, providing certain conditions were
met and so forth. It was indicated that you might go out to;
|
companies other than the manufacturers. You indicated earlie
J U U (, jj
S20?.) 320-£\O6i£
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
1?
18
19
20
21
22
23
24
2,5
54
you had gone to the original manufacturers and they expressed
no interest in taking the material back. But there was,
several months ago at least, some interest in going out and
asking other companies if they would be interested in under-
taking this on a commercial basis.
I understand perhaps there are some companies that
have equipment in place which could be used for this. That
is an understanding I have which is not founded in first-hand
information.
Would you care to comment on your intentions to go
forward with asking for expressions of interest from commer-
cial companies and any evidence you might have about the
presence or absence of existing facilities vis-a-vis a new
plant type operation?
cine Reporting C^o
\eporltnfy l^ompantj
(202) 628*4889
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
'14
15
16
17
18
19
20
21
22
23
24
25
55
DR. WELSH: I would be pleased to comment, before
I start, I would like to get something cleared in my mind
regarding your last point' vis-a-vis facilities in place.
MR, JOHNSON: I have heard and I adinit it is
hearsay evidence that there are facilities currently being
opened by some chemical companies who might be interested
in chemichally reprocessing this material, whereas your
earlier comments were directed to the need for constructing
an absolutely new facility. I was wondering if there were
facilities to your knowledge that were available, or if
it would require the construction of a new facility/
DR« WELSH: I think it depends on how you define
chemical reformulation. If you define it in terms of the
complete chlorinization of the molecule, I don't know of
any facilities in this country that exist. If, as documented
in the statement, we provided material to EPA to evaluate
and determine plant. It is my understanding from the
informal conversations of the results back to us that due
to the presence of the oxygen in the Herbicide Orange
molecule, they got end production containing carbon dioxide
as well as the carbon tetrochloride, and they also had
problems with potentially increased corrosion inside the
facility. We have not seen the final results on that.
As fair as concerns of having equipment in place
or under construction right now, to my knowledge no one doe
¦corns
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
56
If you speak of reformulation in terms of perhaps converting
the material from its ester form to acid form, perhaps
separating the °D" and the BTn from each other, I would say
probably there are facilities in being to do that.
Our intent, as we have indicated for some time,
is to dispose of the Herbicide Orange either by destruction
or by use. We went to the EPA sometime back, arfd "time gets
away from one, but some time longer than a year ago, about
the potential of registration. At that point in time it
seemed that was not a logical thing to pursue, due to the
concern that was being expressed over 2,4,5-T.
Following the cancellation of the public hearings
last summer, we came back to you people to discuss this
matter further and arrived at a position that it seemed
that reformulation offered the best opportunity of a use
option, reformulation or reprocessing.
So, we currently are still in that particular
mode, that reformulation is, in our minds, a potentially
viable option. But I must say that we do not feel that
we have the luxury nor should we have the requirement to
study the problem for another two years. We think we have
studied it to the extent that a reasonable man would study
the problem, and that we have, we feel, reasonable solutions
that are available to us now.
MR. ROGERS: I have one question. Do your
^Acme (Company
(2o2» san-aeee
-------
1
2
3
4
5
6
7
¦8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
57
general remarks apply equally well to the comments of Mr,
Mitchell this morning, or do you have any specific com-
ments you would like to make as to his presentation^
DR. WELSHs We have had comments with Mr. Mitchel]
as well as other members of the chemical industry about
their potential interest and capabilities in handling this
problem. Our general approach to this is that, number 1,
it is a free country and anybody that has a v/ay that he
thinks he can solve the problem and make a buck in the
process of doing it is welcome to talk with us, is welcome
to take whatever action they choose to take on a unilateral
basis. One of the great things about our particular
country is this. We have not, I stress, seen Mr. Mitchell's
detailed proposals, nor anyone else's detailed proporsals.
We have not seen sufficient data from anyone at this point
in time that we would say tit at what they can do, they
indeed can prove that they can do. I am not casting doubts
on the integrity of Mr. Mitchell at all. I don't mean it
that way.
It is just that I think before one can reach a
conclusion that that mystic process is a good one or John
Doe Chemical Company's process is a good one, you have to
look at the numbers in black and white, what came in, where
it went, how you act for it. We have not felt it appropri-
ate to ask Mr. Mitchell to tell us that yet.
Reporting C^omp&ny
(202) 028-4306
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
58
MR. ROGERS: Why?
DR. WELSHt Very siraply, we have not from a pro-
curement point of view gone out to the industry and said,
''Hey, the EPA has taken a position thus and so. Now we
would like you to tell us what you, if anything, could do
with the particular product." We have not qone through
the tortuous path yet of implementing results of your
January 21 response to our November 18, or whatever it was,
letter.
MR. JOHNSON: Do you have any plans to implement
that response?
DR. WELSH: Well, yes, very definitely. It is
our desire to find out if there is interest, if it is tech-
nically and scientifically valid interest, and that if we
can arrive at this being one of the potential solutions to
the problem.
MR. ROGERS: That being the case, do you foresee
or would you anticipate that EPA would actively further
process your ocean disposal application, or would you
suggest that we defer that for a moment while you review
possible alternatives?
DR. WELSH: Let rae just say that based upon past
experience and history, I would sincerely hope you would
actively pursue the ocean dumping permit incineration
question simultaneously with pursuing the question of
^4cm
-------
1
2
3
4
5
6
7
8
9
'10
.11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
59
potential use.
CHAIRMAN: BIGLANEx Are there further inquiries
of Dr. Welsh?
DR. ENOSt You have indicated that you would like
the Environmental Protection Agency to pursue the possibility
of issuance of a license for at sea incineration. I wonder
since you heard earlier today some concern expressed about
the monitoring for various effluents from the stackgases
on the Vulcanis, if you would tell us something about your
evaluation of the incineration process albeit at the
laboratory level, for the determination of residues of 2,4-D
and 2,4,5-T, with specific reference to the efficiency of
such monitoring systems?
DR. WELSH: Well, number one, I don't think I
ought to try to answer that myself. Dr. Enos. We have some
people in the audience that might want to take it on. They
have been working on the problem. I am looking for one of
them to volunteer by raising their hand. They sire all
sitting on them at the present time.
Let me start and when I get it sort of bollixed
up, they will be emabarassed and come to my rescue.
As you recall from reading the Impact Statement,
we developed a monitoring train to apply in the studies we
carried out in conjunction with the Marguardt Company.
This particular monitoring train used benzine as I recall
9£eporfint} (Company
(2025 02&-488S
-------
1
2
3
4
5
6
7
8-
9
lo-
ll
12
13
M
15
16
1?
18
19
20
21
22
23
24
25
60
and it consisted of maybe three sequential traps, four —
I found a guy to help. John Kogelman.
MR. KOGELMANs We developed a sampling train
based on the standard EPA train because you go into a j
stack using four sequential impingers containing 250
milimeters of benzine. We tested this in the laboratory
for 2,4-D and 2,4,5-T and found we had essentially 100
percent collection efficiencies. In fact, we collected
most of it in the first two impingers. we modified the
impingers to be bubblers, because we found out with the
standard impingers our efficiencies dropped. We did not
evaluate our train for the CDD because our chemists felt
the similarity of the CDD to the other two constituents,
because the similarities to antizene, which was soluble in
benzine, would insure that the CDD was trapped in the train
along with the two major constituents of Orange.
In the lab, like I said, we found essentially
100 percent collection efficiency with the train. fJhen
used in the field we found no problems with it at all. This
is the monitoring train we developed based on the work done
at the Kelly Lab using benzine as the collection media.
DR. ENOSs What would be the difficulty to
adapting that particular train to a monitoring problem
on board the Vulcanis?
MR. KOGELMAN: Problems on the ship, we think we
aa®-4903
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
61
could use the benzine train as a train. The obvious
problem on the ship is getting from the train to the stacks.
The excessive heat, the hot stacks, the acid environment
existing inside the stack itelf, has an effect on the
problems we woulC have to use. We would have to go to a
water-cooled process.
Talking to the Shell people, and looking at the
ship itself, we have a 50 foot run of line. You have to
go from the stack to the first suitable environment before
you could set up the train, so that you could actively
watch the train and keep your instruments from coming apart.
We would have a 40 foot line to be heated because of the
possibilities of losing condensation in the line. We have
an acid environment that would have to be scrubbed out.
The biggest problem would be the measurement of the flow
coming out of the stack because of the unusual angle of the
porthole, plus the cruel and vicious environment that exists
inside the stack. The problems are getting from the train
to the stack itself more than environmental.
CHAIRMAN BIGLANEt Thank you very much.
Are there other questions?
Yes, would you please come to the lectern?
MR. BROWN: My name is Manfred Brown, owner
of the Vulcax\us* I would like to try to answer some of the
questions that Mr. Kamlet asked about the technical details
-Jlcme i^&ftoriing. Company
(2023 320-4038
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
i)
62
on the vessel.
For instance, about the injection system that is
being used on the ship, what we have on the ship is a
rotating large diameter cup system which is highly suitable,
as you mentioned in your paper, which disperses the waste
in a large area in the combustion chamber.
As far as the temperature, I think Dr. Welsh
said that the dioxin is destroyed at 1000 degrees; Centi-
grade. And the way we work it on the ship is the* incin-
erators are preheated with regular gas oil that we use for
the engine to a level of 1100 before any waste is injected.
That can even be higher.
The dwell time you mentioned should be in excess
of 14 seconds, and if I recall correctly, the dwell tim
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
63
it will be necessary because there should not be any prob-
lem with combustion efficiency. The ship has so far, in
about two and a half years, burned, I would say, close to
100,000 of clorinated hydrocarbons, both in -Europe and
here, which is similar to the Orange, except the chlorine
content is much higher, about double, and the BTU is
accordingly less. So, in other words, it is twice as
difficult to burn, We do not expect there would be any
problem- with this material in that respect, or that any
preheating is necessary.
Thank you.
DR. ENOS: X/have a question. As I recall from
our previous work with the Vulcanus, you discussed dwell
times that averaged around 1.7 seconds. But you quoted
or cited a figure much, much larger than that. Could you
explain why?
MR. SHIPMANs I am not an engineer myself, but
I remember this thing was brought up before, and this is
the figure that, as I recall, I was given by them when we
asked it.
DR. ENOS: I don't believe that figure is
correct.
MR. GALLAYj My name is Gallay. I would suggest
to take from the record the number Mr. Brown gave, because,
certainly, it is an error that is about 20 times what
t^cporting Company
(202) 636-4880
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
64
could be possible. There is no such thing in an industrial
furnace as 20 seconds dwell time. It is an understandable
mistake. I think for the record it looks more eloquent
to put something which is absolutely impossible in.
CHAIRMAN BIGLANEs Thank you for that clari-
fication, sir.
Are there further questions?
MR. WILLIAMS s I would like to get a clarification
on which waste was 66 percent chlorine, the Shell or the
Orange, and which was 10,000 BTS's?
My name is Carlton Williams, and there were some
comments relevant to the BTU and the chlorine content.
I am not sure of the exact figures, but the Orange Herbicide
has a BTU content about twice as much as the Shell, waste
and a chlorine content of about half as much, which* Caused
Mr. Brown to indicate there should be no problems in
combusting it. I was only going to make sure there was no
confusion on that point.
CHAIRMAN BIGLANEs Thank you for that clarifica-
tion.
DR. ENOS: I think you originally asked a question
I believe the Shell waste iz'an between 66 and 72 percent
chlorine content, and I believe that the BTU rating was
somewhere around 6,000, as I recall.
MR. WILLIAMS: Five to six was what I was told
~Acme i^eportinQ (Company
(202) <120-4800
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
65
informally. Ours is 10,000. Thank you;
CHAIRMAN BIGLANE: Thank you.
MR. DERORNY (phonetic)s I just want to put the
numbers correctly into the record for everybody's purpose.
The Shell waste contained 63 to 66 percent by
weight chlorine. It had a BTU value per pound of 5900 to
6100. The chlorine content of Orange is 29.7 percent and
has a BTU content of slightly over 10,000 BTU*s per pound.
So it will incinerate itself and sustain combustion. The
5800 to 6100 per pound of the Shell waste just about
contained combustion. At 5700 it would have been a
little difficult to burn.
CHAIRMAN BIGLANE: Are there further questions,
now?
MS. SIIOWER: I would like to address the point
that was laade in the environment impact draft that there
is a problem with leaving the Orange on Johnston Island
with respect to typhoons and hurricanes. I am concerned
as to when the final disposition of this material is
going to occur.
DR. WELSH: I don't believe we can say. Let
me just say we are interested in proceeding ahead with all
reasonable haste.
CHAIRMAN BIGLANE: Thank you. Doctor.
Are there further questions?
$«poriing C^nmpanij
120Z\ 626*4939
-------
1
2
1
I &
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
66
Hearing noner seeing none — hearing one more.
MR. HUGHESs I would like to ask Dr. Johnson
if you would just sort of give us an explanation as to the
situation of 2,4,5-T butal and octal esters as far as
there future use in our environment and why is 'it or has
there been a decision made in the event that the hearinqs
last year were called off on 2,4,5-T, has there been or
is there an impending decision on excluding the use of
2.4.5-T, for instance, and why should the butal ester in
Organge be any different than other commercial formulations?
MR, JOHNSON: I can answer the first part of
your question. The seond part I will defer to someone * else.]
The Agency withdrew its action on the basis of
insufficiant analytical methodology to find dioxin in the
environment. Therefore, since the hazard requires a
toxicological agent, plus an exposure, we felt we could
not aprove hazard sufficiently to go forward with the
hearing. We have instituted some special monitoring pro-
grams which are taking advantage of some new dioxin
methodology which is sensitive. We are down to the 10
parts per trillion level. We are shooting for a lower
level, A sequential decision basis has been set up whereby
we will review the evidence at six month intervals and de-
termine whether we should renew the hearings or not.
I honestly, as I said, am not enough of a
cme f^cportinfy (Company
(202) 026-4088
-------
1
-L
2
3
4
5
6
7
8
9
io
ii
12
13
14
15
16
17
18
19
20
21
22
23
24
25
|i
67 |
cheiaist — I am not a chemist at all to answer your i
i
question about the difference in the various types of
esters in the products. If anyone would care to take a
crack at it, that is fine. |
MR. HUGHES: The esters are in formulations
that are registered. And there seems to be a tendency to
exclude the possible reformulation of the Orange as removing
the dioxin and still use the Orange 50-50 2,4,5-T and
2^4rB as possible reformulation. That has been excluded.
\
t
I am concerned, why should it be excluded?
MR. JOHIISOH: I am not sure the option has been
excluded. We do in fact, as you correctly point out, have I
products registered now that are mixtures of 2,4,5-T and
2,4-D. They are different mistures. The basic problem
has been with who the registrant might happen to be, and,
more particularly, the dioxin content of the materials and
how that problem would be taken care of.
CHAIRMAN BIGLANE: Any further questions from
the audience? j
Questions from the panels, or statements? >
Hearing none, let me say we certainly appreciate
your coming here today. ;
I declare this public meeting in adjournment.
(Whereby at 11:40 a.m., the hearing was
adjourned.) i
------- |