Ocean Incineration: Its Role in Managing Hazardous Waste (Part 13 Of

Chapter 11 History of U.S. Ocean Incineration Contents

Page Past Burns ...... 179 Shell Chemical Organochlorine Wastes in the Gulf of Mexico: First Series ...... 179 Shell Chemical Organochlorine Wastes in the Gulf of Mexico: Second Series...... 179 Agent Orange Wastes in the South Pacific ...... 181

PCB Wastes in the Gulf of Mexico ...... ,. ....! 181 Organochlorine Wastes in the North Sea Using the Vulcan us ~~ : : : : : : : : : : : : : : : : : : ; : : 182 Canceled Burns...... 182

Adequacy of Past Burns in Demonstrating the Safety of Ocean Incineration...... 183 Past Incidents ......

Site Designation ...... Gulf Site ...... North Atlantic Site. . . . . Other Possible Sites . . . .

Recent EPA Efforts ...... Science Advisory Board (SAB) Study ...... Incineration Study ...... Ocean Incineration Research Strategy ...... Proposed Research Burn ...... The Usefulness of Research Burns:

Chapter 11 References. . . . .

Table Table No. Page 26. Summary of Past Ocean Incineration Burns ...... 180

Figure Figure No. 12. Location of the Designated (Gulf of Mexico) and Proposed (North Atlantic) Incineration Sites . Chapter 11 History of U.S. Ocean Incineration

This chapter discusses several facets of the his- tion, and recent Environmental Protection Agency tory of ocean incineration in the United States. Past (EPA) activities, including the recently denied pro- burns, the designation of sites for ocean incinera- posal for a PCB research burn, are discussed.

PAST BURNS

Four sets of research or interim burns occurred burned in late December 1974 and early January under EPA’s authority between 1974 and 1982. All 1975. four used the Vulcanus I and included varying EPA reported that destruction efficiencies for this degrees of monitoring and analysis of stack emis- set of burns averaged 99.95 percent, measured on sions and the marine environment. In addition, the basis of total organic carbon. No separate meas- EPA monitored a test of the Vulcanus II in the urement of individual principal organic hazardous North Sea in 1983. This section describes each of constituents (POHCs) or products of incomplete these burns and discusses the reported results. Ta- combustion (PICs) was undertaken. Seawater sam- ble 26 presents a summary of these five sets of ples taken from the area of contact between the in- burns, indicating locations, types of waste inciner- cinerator plume and the ocean surface were ana- ated, destruction efficiencies, and other reported lyzed for organochlorines, pH, chlorine content, results. In each case, a primary reference is indi- and trace metals. EPA was unable to detect any cated for additional information. changes over background levels.

Shell Chemical Organochlorine Wastes Shell Chemical Organochlorine Wastes in in the Gulf of Mexico: First Series the Gulf of Mexico: Second Series Use of ocean incineration was first proposed in In 1977, Shell obtained a special permit to con- the United States in 1974, when Shell Chemical duct another set of burns in the Gulf of Mexico, Co. sought permission to use the Dutch-owned ves- and again used the Vulcanus I to incinerate four sel Vulcanus I to incinerate liquid organochlorine shiploads, or about 16,000 mt, of organochlorine wastes. This type of waste had previously been wastes. EPA conducted extensive testing of the first dumped in the Gulf of Mexico, until EPA halted of these burns. Trace amounts of known waste con- the practice in 1973. The waste proposed for in- stituents (POHCs) were detected in the stack gas cineration was a mixture of chlorinated hydrocar- samples; these measurements were used to calcu- bons derived from production of vinyl chloride and late the POHC-specific destruction efficiencies re- other chemicals. The chlorine content of the waste ported in table 26. The analysis of emissions found was 63 percent. very low amounts of other compounds, which had In October 1974, EPA granted Shell a research not been identified in the waste, and which may permit to incinerate one shipload (4,200 metric have been PICs. tons, or mt) of the waste at a site 190 miles from EPA reported that the DE for total hydrocarbons land in the Gulf of Mexico. Because several prob- ranged from 99.991 to 99.997 percent. The DE for lems arose during the monitoring of this burn, a the major waste constituent, trichloropropane, second research permit for another shipload was ranged from 99.92 to 99.98 percent. granted, and a second burn took place in December 1974. The generally favorable results led EPA to The environmental monitoring of these burns re- grant a special interim permit for the incineration vealed the first evidence of an environmental ef- of two remaining shiploads of waste, which were fect from ocean incineration. Fish in towed cages

179 180 ● Ocean Incineration: Its Role in Managing Hazardous Waste Ch. 11—History of U.S. Ocean Incineration ● 181 were exposed to surface water in the area of con- cause the detection limits of the sampling and ana- tact between the incineration plume and the ocean lytical instruments employed did not allow meas- surface. Assays were then conducted on three en- urement of a higher DE. Destruction efficiencies zyme systems that increase in activity in response for total hydrocarbons ranged from 99.982 percent to physiological stress induced by the presence of to 99.992 percent. pollutants. One enzyme system (Cytochrome P- Emissions were also analyzed for the presence 450) showed a significant increase in activity. of TCDD (dioxin), which was found only in sam- When the exposed fish were placed in clean water ples from the second trial; its detection in these samp- for several days in the laboratory, the activities of les may have been caused, however, by interfer- all three systems were found to be normal. Although ence from other substances. Because TCDD was EPA interpreted the temporary nature of the ef- below the limit of detection in burns 1 and 3, the fect optimistically, detection of such an effect illus- reported DEs again represent minimum values: trates the need for caution and further monitoring 99,99 percent for burn 1 and 99.96 percent for burn and research of ocean incineration activities. This 3. A DE of 99.88 percent was calculated for the would be particularly important if incineration at second burn. particular sites became frequent or routine, because Only limited environmental monitoring was con- longer term exposures to marine organisms might ducted during the Agent Orange burn. Plankton result. samples at the site collected before and after the first burn showed no consistent differences in num- Agent Orange Wastes in the bers or species composition, No other tests were South Pacific performed on marine organisms.

Another set of burns employing the Vulcanus I PCB Wastes in the Gulf of Mexico occurred later in 1977, in the South Pacific about 120 miles west of Johnston Atoll. The waste inciner- An additional set of burns occurred in the Gulf ated was the herbicide Agent Orange, which came of Mexico, beginning in late 1981/early 1982 and from an Air Force stockpile of many separate drums completed later in 1982. Both sets of burns were remaining from production that occurred during carried out under research permits. In the first the Vietnam War. The waste consisted of roughly burn, about 3,500 mt of PCB-containing waste was equal amounts of 2,4-D and 2,4,5-T (see table 26 incinerated aboard the Vulcanus I (which by then for full chemical names), contaminated with the had been acquired by Chemical Waste Manage- highly toxic dioxin TCDD at a level that ranged ment, Inc., of Oakbrook, Illinois). EPA monitored from O to 47 milligrams per kilogram (mg/kg) and the burn, but later indicated that the data collected averaged 1.9 mg/kg. Total chlorine content was were ‘ ‘inconclusive because of major problems about 30 percent. with sampling and analysis. This test in particular A total of about 10,400 mt of Agent Orange was is cited by critics of ocean incineration as evidence incinerated in three separate burns. An initial burn of the unreliability, if not total unacceptability, of incineration at sea. of 3,520 mt took place under an EPA research permit. Favorable monitoring results led EPA to au- The Vulcan us I was also used for a second burn thorize incineration of the remaining stock, about of about 3,500 mt of PCB wastes conducted in Au- 6,880 mt in two shiploads, under a special permit. gust 1982. The waste composition included 27.5 Destruction efficiencies were reported in several percent PCBs, 7 percent chlorobenzenes, and trace amounts (estimated at 0.0000048 percent) of highly forms by EPA. For all three burns, the DE for the toxic tetrachlorodibenzofurans (TCDF). None of two main components of Agent Orange, 2,4-D and the emissions samples analyzed showed any trace 2,4,5-T, and for total chlorinated hydrocarbons, exceeded 99.999 percent. In fact, none of these sub- of these components, which means that the reported DEs again represent minimum values. These DEs stances was detected at all in the emissions. The are as follows: minimum DE of 99.999 percent was reported, even though the actual DE might have been higher, be- ● PCBs ...... , . . . >99.99989 percent 182 ● Ocean Incineration: Its Role in Managing Hazardous Waste

● Chlorobenzenes . . . . >99.99993 percent Major public opposition mounted, culminating ● TCDF ...... >99.96 percent. in a public hearing in Brownsville, Texas, on No- vember 21, 1983, attended by more than 6,400 peo- Both waste and emissions were analyzed for the ple, the largest public hearing in EPA history. In presence of TCDD, none of which was detected in May 1984, EPA denied the permits and announced any samples. The plume itself was also sampled for that no further operating permits would be issued PCBs and other organochlorine compounds, and until the Agency had promulgated specific ocean none was detected. However, some nonchlorinated incineration regulations and completed several on- compounds were detected in the plume, and EPA going studies. suggested that they either were PICs or arose from the vessel’s propulsion engines. In December 1985, EPA published its tentative determination to issue a research permit to Chem- Marine sampling and monitoring was conducted ical Waste Management, Inc., for incineration at during the second burn, and no detectable increase sea using the Vulcanus II (50 FR 51360, Dec. 16, in PCBs was found in water samples or organisms. 1985). EPA initially solicited the research permit Nor did any physiological indicators of exposure- as part of its Ocean Incineration Research Strat- related stress exceed normal levels. 1 egy (26). The permit would have authorized the incineration of one shipload (about 700,000 gallons) Organochlorine Wastes in the North Sea of a waste consisting of 10 to 30 percent PCBs in Using the Vulcanus II fuel oil. The waste was to have been loaded at the Port of Philadelphia, transported through Delaware With EPA in attendance, the newly built Vul- Bay, and incinerated at the North Atlantic Inciner- canus II was tested in February 1983, burning ation Site. In its application, Chemical Waste Man- waste from vinyl chloride production at the desig- agement indicated that the waste it planned to burn nated incineration site in the North Sea. The waste would actually contain 12 percent PCBs, and would consisted almost entirely of four compounds: tri- be transported by rail from its storage facility in chloroethane (39 percent), chloroform (26 percent), Emelle, Alabama (8). carbon tetrachloride (20 percent), and dichloro- ethanes (15 percent). The waste’s total chlorine con- The Coastal Zone Management Act, which is ad- tent was 84 percent; in addition, two of the waste’s ministered at the Federal level by the National components (chloroform and carbon tetrachloride) Oceanic and Atmospheric Administration (NOAA), are ranked by EPA as among the most difficult grants States the right to review Federal activities compounds to destroy thermally, because of their affecting their coastal zones for consistency with high chlorine content. Thus, this waste provided State management plans. As part of its application an unusually difficult test of the incinerator. procedure, Chemical Waste Management, Inc. sought coastal zone management (CZM) consist- The reported DEs were high, ranging from ency determinations from three coastal States: Dela- 99.998 percent for carbon tetrachloride to more ware, New Jersey, and Pennsylvania. These States than 99.999995 percent for trichloroethane. were consulted because the Vulcan us II would pass through their coastal waters en route to the inciner- Canceled Burns ation site. Pennsylvania granted approval without In October 1983, EPA proposed issuing two 3- conditions for the single research burn. Delaware year special permits and one 6-month research per- 1 EPA received a separate application from At-Sea Incineration, Inc. mit to Chemical Waste Management, Inc., to in- (ASI), for the Apolfo 1. However, ASI’S parent company, Tacoma cinerate 300,000 mt of PCB-containing waste and Boat, filed Chapter 11 bankruptcy proceedings in the fall of 1985. 900 mt of DDT-containing waste in the Gulf of This move, brought on partly by delays in the finalization of EPA’s regulations, forced ASI to default on $68 million in guaranteed loans Mexico. EPA based its tentative approval on the granted earlier by the U.S. Maritime Administration for construc- successful 1982 PCB burn (using Vulcanus I) and tion of its two incineration vessels ( 14). The loan was paid in full by the 1983 European organochlorine burn (using the Maritime Administration. The uncertain financial status of ASI led EPA to hold its permit application in abeyance pending resolu- Vulcanus II). tion of the situation (50 FR 51361, Dec. 16, 1985). Ch. 11-History of U.S. Ocean Incineration • 183 also reached a determination of CZM consistency Prior to any decision in the suit, the State of but limited transit to daylight hours and required Maryland and Chemical Waste Management reached prior notification of the ship’s movement (13). In a settlement in which Maryland withdrew its re- addition, Delaware was considering suing EPA to quest to conduct a CZM consistency review of this require the agency to prepare a separate Environ- research permit but retained its right to pursue such mental Impact Statement on the transit route (13). a review in the future (16). New Jersey originally placed several conditions Following the announcement of its tentative de- on its finding of CZM consistency. These included termination to grant a research permit to Chemi- prohibiting transit during the summer, extending cal Waste Management, EPA held a series of public the moving safety zone, modifying Coast Guard hearings in Philadelphia; Red Bank, New Jersey; contingency plans for managing a spill, allowing Wilmington, Delaware; and Ocean City, Mary- 60 days for the State to verify waste composition, land. Through the course of these hearings, strong and requiring State approval of the level of liabil- public opposition again surfaced, focusing particu- ity coverage. In the course of litigation, however, larly on the land and nearshore marine transpor- New Jersey withdrew its conditions regarding the tation risks. These concerns led to the issuance of moving safety zone and contingency plans, and a Hearing Officer’s report (31) that called for the modified its waste analysis requirement. resolution of several major issues of public concern before proceeding with the burn. In early 1986, the State of Maryland appealed to NOAA for the right to make a CZM consistency In May 1986, EPA announced its decision to determination, claiming that the proposed test burn deny the research permit, and to grant no permits, could adversely affect the States coastal zone. research or otherwise, until finalization of its Ocean Maryland argued that, although the vessel would Incineration Regulation (51 FR 20344, June 4, not pass through Maryland waters, those waters 1986). In its decision, EPA argued that the nature could nevertheless be adversely affected by the ac- of the issues raised in considering the research per- tivity. In February, NOAA ruled in favor of Mary- mit could be more appropriately addressed through land, despite strong opposition from EPA. Mary- the regulatory development process.2 land was granted 6 months to conduct its review As a result of EPA’s decision, the suit brought and reach a consistency determination (letter cited by Chemical Waste Management was dismissed in ref. 1 1). without a ruling on the circumstances under which In response to the NOAA decision and the strict permit applicants are required to demonstrate conditions imposed by New Jersey, Chemical CZM consistency or the rights of States to place Waste Management filed suit in March against conditions on their finding of CZM consistency NOAA and EPA (15). The suit contended that (11). Maryland was not entitled to conduct a consistency review for an activity that would occur outside of its coastal zone. In addition, Chemical Waste Man- agement contended that the Marine Protection, Re- 2 search, and Sanctuaries Act preempts New Jersey The PCB wastes that were to have been incinerated under the research permit are now expected to be transported to Chicago for in- from imposing conditions. cineration in Chemical Waste Management land-based incinerator,

ADEQUACY OF PAST BURNS IN DEMONSTRATING THE SAFETY OF OCEAN INCINERATION

All of the burns discussed above took place under only 99.9 percent. Therefore, all but one of the re- EPA regulations that incorporated the technical reported DEs met the required standard. (The ex- quirement of the London Dumping Convention ception was the reported DE for TCDD in the sec- mandating a minimum destruction efficiency of ond burn of Agent Orange, which appears to have 184 • Ocean Incineration: Its Role in Managing Hazardous Waste been anomalous and may have resulted from in- caused by accidental breakage of a sampling bot- terference by chemically related compounds. ) tle; sloshing of liquid through a tank hatch, as a result of rough seas; and overfilling of a tank during In 1981, EPA adopted rules requiring land-based rinsing. One or more of these spills was apparently hazardous waste incinerators to achieve a 99.99 per- tracked by personnel, leading to the contamination cent DE. In addition, the Toxic Substances Con- of other areas of the vessel. This contamination was trol Act requires a minimum 99.9999 percent DE detected during routine monitoring of the vessel for PCBs. EPA has proposed that the same values performed as a precautionary measure. be adopted in the regulations governing ocean incineration. The ability of ocean incineration to There have also been reports of a more serious achieve this DE has not yet been demonstrated. release of waste from this burn, caused by the in- Past test burn data for PCBs was derived from anal- tentional discharge of bilge water, which was appar- ysis of samples that were not large enough to defini- ently contaminated with Agent Orange, into a la- tively establish that the Vulcanus I is capable of goon at Johnston Atoll (12,22). Sampling of lagoon meeting a 99.9999 percent DE. However, EPA be- water in the immediate vicinity of the bilge water lieves that this DE was achieved in the burn and discharges revealed concentrations of herbicide that is achievable using ocean incineration (28). significantly exceeded water quality criteria. Re- ported concentrations were as high as 3 to 5 parts No consensus exists with regard to the adequacy per million, and the total release of herbicide was and accuracy of EPA’s past efforts to monitor ocean estimated to have been about 270 pounds (12). In incineration. Based on its monitoring of incinera- addition, a visible orange cloud in the water was tor performance and the environment during past noted, although the captain of the Vulcanus I main- ocean incineration activities, EPA reported that it tained that the color was caused, not by herbicide, had been unable to detect any increase in back- but by rust (22). ground levels of waste constituents in ambient air, water, or marine organisms. Many members of the Several small spills on deck were reported dur- public and EPA’s own Science Advisory Board ing the first of the PCB burns that took place in (SAB), however, have expressed concerns about the Gulf of Mexico in 1981-82 (2,25), Some con- these conclusions and the methods and adequacy tamination of other parts of the vessel (the burner of EPA’s monitoring efforts. (For further critical room, pumproom, and a gangway) was also re- discussion of these past efforts, see refs. 6,7,18, ported, identified during routine monitoring of the 19,29). vessel. In response to these concerns, EPA has called During the Agent Orange burns (1) and the 1977 for additional test burns before operating permits organochlorine burns in the Gulf of Mexico (9), are issued. The test burns would be intended to pro- several ‘ ‘impingements’ of the incinerator plume vide more accurate assessments of the performance, onto the deck of the vessel were reported. These levels of emissions, and environmental conse- were attributable to momentary flameouts caused quences of ocean incineration. In addition, the pro- by water in the waste being incinerated or to high posed regulations governing ocean incineration con- wind velocities and erratic wind direction, and in tain provisions for comprehensive environmental some cases resulted in brief exposure of crew mem- monitoring, which would be conducted by EPA bers to emissions. Based on consideration of the cir- with the participation of permitters. cumstances surrounding these incidents, steps were taken to avoid or reduce their subsequent occurrence. Past Incidents Several other incidents have been reported or al- Several small spills and contamination of the ves- leged to have occurred during ocean burns that sel occurred during three of the sets of burns de- occurred in Europe. These are discussed in refer- scribed in this chapter. ence 20. During the incineration of Agent Orange in the Certain provisions of EPA’s proposed Ocean In- Pacific (l), several small spills of herbicide occurred, cineration Regulation directly address these types Ch. 11-History of U.S. Ocean Incineration . 185 of incidents. In particular, bilge and ballast waters required to maintain a course and speed which, in and tank washings would have to be tested for the combination with the prevailing wind speed, would presence of waste constituents and, if contaminated, yield a combined effective wind speed over the ves- either incinerated at sea or disposed of in an ap- sel of 3 knots or more, to ensure that the plume proved land-based facility (50 FR 8236, Feb. 28, remained aft of the vessel and would not come into 1985). In addition, the vessel would at all times be contact with the crew (50 FR 8251, Feb. 28, 1985).

SITE DESIGNATION

Under the Marine Protection, Research, and North Atlantic Site Sanctuaries Act, incineration sites must be designated by EPA, and operational permits for ocean In 1981, a final EIS for the North Atlantic In- incineration may only be granted for designated cineration Site was released (24). This site, which sites. The site designation process falls under for- has not been formally designated, lies about 140 mal rulemaking procedural requirements mandat- miles east of the coasts of Delaware and Maryland ing public hearings. In addition, an Environmental and covers 4,250 square kilometers (see figure 12). Impact Statement (EIS) must be prepared for each The site lies beyond the continental shelf on the con- site. tinental rise, in waters ranging in depth from 2,400 to 2,900 meters. Due north and adjacent to the pro- The following discussion highlights the status of posed incineration site is the 106-mile Ocean Waste designation activities for ocean incineration sites. Disposal Site, which is expected to be used for dumping industrial acid and alkaline wastes as well Gulf Site as municipal sludge for the foreseeable future. Currently, only one site has been designated for Since the development of the 1981 EIS, the Na- ocean incineration. The final EIS for the Gulf of tional Marine Fisheries Service (NMFS) has found Mexico Incineration Site was issued in 1976 (23). that the proposed North Atlantic Incineration Site This site lies in the middle of the Gulf, about 190 lies in a “high use” area for several species of en- miles from land, and occupies an area of 4,900 dangered or threatened marine mammals (see ch. square kilometers (see figure 12). The site is be- 9). In response to this finding, EPA reevaluated yond the edge of the continental shelf, in waters the site and concluded that endangered species ranging in depth from 1,000 to 2,000 meters (5). would not be affected by incineration there (30). NMFS has concurred with this conclusion with re- The Gulf Site was initially designated in 1976 spect to limited use of the site for research burns. (41 FR 39319, Sep. 15, 1976) and redesignated in However, NMFS must develop a formal biologi- 1982 (47 FR 17817, Apr. 26, 1982). The 1982 rule cal opinion for consideration prior to EPA’s final designated the Gulf Site for ‘‘continued use. The designation of the site. proposed Ocean Incineration Regulation would limit designation of the Gulf Site to a period of 10 Other Possible Sites years, assuming that the additional proposed requirements for site designation were met (see ch. EPA-sponsored studies have tentatively exam- 10). Some members of the public and elected offi- ined areas off the coasts of California and Florida cials have called for the designation process for the as possible future sites for ocean incineration. How- Gulf Site to be reopened, based on new informa- ever, no steps in the actual site designation proc- tion and developments since 1976 (see ch. 2). ess have taken place to date. 186 ● Ocean Incineration: Its Role in Managing Hazardous Waste

Figure 12.-Location of the Designated (Gulf of Mexico) and Proposed (North Atlantic) incineration Sites

Designated incineration site

SOURCE: Office of Technology Assessment.

RECENT EPA EFFORTS

In conjunction with the development and issu- human and environmental health and compared ance of its proposed Ocean Incineration Regula- and contrasted the current level of understanding tion, EPA sponsored several studies. of land-based and ocean incineration technologies. Although stating that ‘‘incineration is a valuable Science Advisory Board (SAB) Study and potentially safe means for disposing of hazardous chemicals, and that the report’s intent was In April 1985, EPA’s SAB released its “Report to ‘‘strengthen already existing incineration pro- on the Incineration of Liquid Hazardous Wastes grams rather than to discontinue what is already by the Environmental Effects, Transport, and Fate in place, the SAB identified several major areas Committee” (29). The report examined various sci- where existing data are insufficient. In particular, entific issues bearing on incineration’s impacts on the SAB found that no reliable characterization of Ch. 11-History of U.S. Ocean Incineration ● 187 incinerator emissions or their toxicities was avail- ments received from the public. The strategy calls able, which meant that the potential for environ- for several research burns, both on land and at sea. mental or human exposure and impact could not Initial dockside burns with diesel fuel would allow be assessed. The study challenged EPA’s measure- development and testing of methodology; subse- ment of destruction efficiency, which addresses only quent burns of hazardous waste would be designed a few selected compounds, as a basis for evaluat- to gather data on incinerator performance, the ing the total performance of incinerators. It rec- quantity and composition of emissions, and envi- ommended that EPA undertake a complete charac- ronmental effects. terization of emissions, including products of incomplete combustion (PICs). Proposed Research Burn

The report stressed that the uncertainties the As described earlier in this chapter, EPA pro- SAB had identified applied equally to land-based posed to issue a research permit for incineration and ocean incineration and, in many cases, to other at sea as part of its research strategy (50 FR 51360, common combustion processes, such as the burn- Dec. 16, 1985). The burn was planned to be con- ing of fossil fuels. The report also argued that, be- tinuous for 19 days, during which EPA would con- cause it destroys waste, incineration is preferable duct extensive sampling and monitoring of all to current methods of disposal, such as landfilling aspects of operation. The following specific tests and deep-well injection. were planned:

● Incineration Study determination of flow characteristics and combustion efficiency at all points in the stack; EPA’s Office of Policy, Planning and Evalua- ● sampling and analysis of emissions to allow tion (OPPE) (27) published an “Assessment of In- measurement of: 1) semi-volatile trace organic cineration as a Treatment Method for Liquid Or- compounds, including PCBs, for calculation ganic Hazardous Wastes” in March 1985. The of destruction efficiency; 2) volatile organic study compared and evaluated land-based and compounds; 3) particulate; and 4) total chlo- ocean incineration with respect to technology, reg- rinated organic compounds; ulation, commercial market potential, relative envi- ● collection of samples for toxicity testing; ronmental and health risks, and public concerns. ● actual toxicity bioassays on five marine plant The major conclusions are the following: and animal species, testing for acute toxic ef- . incineration, whether at sea or on land, is a fects and chronic effects on growth and repro- duction; valuable and environmentally sound treatment ● plume sampling and modeling; and option for destroying liquid hazardous wastes, ● collection and analysis of samples of air, water, particularly when compared to land disposal and indigenous organisms for determining the options now available; presence of, or effects from, incineration- ● there is no clear preference for land-based or derived substances. ocean incineration in terms of risks to human health and the environment; and The Usefulness of Research Burns: ● future demand for hazardous waste incinera- Opportunities and Limitations tion will significantly exceed capacity as other disposal alternatives are increasingly restricted. Recent EPA developments are likely to consider- ably delay issuance of the final Ocean Incineration Ocean Incineration Research Strategy Regulation and any subsequent research burns. Clearly, ocean research burns are necessary to re- EPA’s Office of Water published an Ocean In- solve some of the technical questions about ocean cineration Research Strategy (26) detailing the incineration. In addition, if a decision were made means by which EPA intends to address the areas to proceed with ocean incineration, information of uncertainty identified in the SAB and OPPE from research burns could aid in modifying the reg- reports, in previous research burns, and in com- ulatory program, if necessary. 188 . Ocean Incineration: Its Role in Managing Hazardous Waste

Nonetheless, there are limits to the usefulness of be more likely to contain complex mixtures of many the data that could be obtained from ocean research chemicals, which limits the applicability of results burns. Foremost among these is the fact that the from this test burn to “real” situations. Conversely, data would not resolve the basic issue of whether choosing a heterogeneous wastestream for the re- to proceed with the ocean incineration program. search burn would have introduced a different but Technical analysis is only one of many factors in- comparable set of constraints. fluencing such a decision. Finally, to be most useful, ocean incineration Moreover, one or even a series of research burns research must be coupled to research on other al- would still leave many technical questions un- ternatives. A proper comparative analysis would resolved. For example, the recently denied EPA re- require research on both land-based and ocean tech- search burn would have used a waste composed of nologies. EPA does have an ongoing research pro- relatively homogeneous PCBs in fuel oil (8). This gram on land-based incineration, and EPA’s ocean waste was chosen because toxicity characteristics incineration research strategy contains a land-based and detection methods for PCBs are well studied, incinerator component—primarily to allow testing and because EPA wanted to have as little interfer- of the protocols for sampling, analysis, and toxic- ence from other chemicals as possible. Typical ity tests to be used during an ocean research burn. ocean incineration wastestreams, however, would

CHAPTER 11 REFERENCES

1. Ackerman, D. G., Fisher, H.J., Johnson, R.J., et Wastes,” Environ. Sci. Technol. 18(5) :148A-152A, al., At-Sea Incineration of Herbicide Orange On- 1984. board the M\T Vulcanus, EPA Technology Series 7. Bond, D. H., “Ocean Incineration of Hazardous No. EPA-600/2-78-186, prepared for the U.S. Envi- Wastes: An Update, ” Environ. Sci. Technol. ronmental Protection Agency, Industrial Environ- 19(6):486-487, 1985. mental Research Laboratory, Office of Research 8. Chemical Waste Management, Inc., “Application and Development (Washington, DC: April 1978). for a Research Permit To Incinerate Hazardous 2. Ackerman, D. G., ‘‘Observations During the First Waste At Sea: Exhibit B“ (Oak Brook, IL: May PCB Research Burn, ” and Attachments, Commu- 24, 1985). nication to U.S. Environmental Protection Agency, 9. Clausen, J. F., Fisher, H.J., Johnson, R.J., et al., Incineration Research Branch, Cincinnati, OH, At-Sea Incineration of Organochlorine Wastes On- Feb. 18, 1982. board the M\T Vulcanus, EPA Technology Series 3. Ackerman, D. G., McGaughey, J. F., and Wagoner, No. EPA-600/2-77-196, prepared for the U.S. Envi- D. E., At-Sea Incineration of PCB-Containing ronmental Protection Agency, Industrial Environ- Wastes Onboard the M\T Vulcanus, EPA-600/ mental Research Laboratory, Office of Research 7-83-024, prepared for the U.S. Environmental and Development (Washington, DC: 1977). Protection Agency (Research Triangle Park, NC: 10. Environment Reporter, “NOAA Decision Allow- 1983). ing Maryland Review May Delay Ocean Test Burn 4. Ackerman, D. G., Beimer, R. G., and McGaughey, Until Mid-1987, ” Environment Reporter 16(42): J. F., Incineration of Volatile Organic Compounds 1878, Feb. 14, 1986. by the M\T Vulcanus 11, prepared for Chemical 11. Environment Reporter, “Federal Court Defers to Waste Management, Inc., Oak Brook, IL (Redon- EPA Review in Waste Incineration Permit Dis- do Beach, CA: TRW Energy and Environmental pute, ” Environment Reporter 17(9):264, June 27, Division, 1983). 1986. 5. Ackerman, D. G., and Venezia, R. A., “Research 12. Graffeo, A. P., and Thomas, T., “Ocean Disposal on At-Sea Incineration in the United States, in of Agent Orange—Land-Based Environmental Wastes in the Ocean, vol. 5, D.R. Kester, et al. Monitoring at Johnston Island, ” paper presented (eds.) (New York: John Wiley& Sons, 1985), pp. at the Third International Ocean Disposal Sympo- 53-72. sium, Woods Hole, MA, Oct. 12-16, 1981. 6. Bond, D. H., ‘ ‘At-Sea Incineration of Hazardous 13. Inside EPA, “Delaware Eyes Suing EPA To Force Ch. 11-History of U.S. Ocean Incineration ● 189

Ocean Incineration Transit Route, EIS, ” Inside 24. U.S. Environmental Protection Agency, Office of EPA 6(41):2, Oct. 11, 1985. Water Regulations, Criteria and Standards Divi- 14. Inside EPA, “EPA Okays At-Sea Research Burns, sion, Environmental Protection Agency Find Envi- But Pool of Applicants Dwindles, ” Inside EPA ronmental Impact Statement (EIS) for North At- 6(48):5, Nov. 29, 1985. Jantic Incineration Site Designation (Washington, 15. Inside EPA, “EPA, NOAA Sued for Allowing DC: Nov. 25, 1981). Maryland Incineration-At-Sea Review Rights, ’ in- 25. U.S. Environmental Protection Agency, ‘ ‘Prelimi- side EPA 7(12):8, Mar. 21, 1986. nary Report, Research Permit for Incineration At 16, Inside EPA, “Justice Asks Court To Dismiss In- Sea of PCB Wastes, HQ 81-002, Results of Test dustry Incineration-At-Sea Suit, ’ Inside EPA Burn on M/T Vulcanus, ” May 20, 1982, p. 57. 7(18):3-4, May 2, 1986. 26. U.S. Environmental Protection Agency, Office of 17, Kamlet, K. S., ‘‘Ocean Disposal of Organochlorine Water, Incineration-At-Sea Research Strategy Wastes by At-Sea Incineration, ” Ocean Dumping (Washington, DC: Feb. 19, 1985). of Industrial Wastes, B.H. Ketchum, et al. (eds. ) 27. U.S. Environmental Protection Agency, Office of (New York: Plenum Publishing Corp., 1981), pp. Policy, Planning and Evaluation, “Summary and 295-314. Conclusions, Assessment of Incineration as a 18. Kleppinger, E. W., and Bond, D. H., Ocean In- Treatment Method for Liquid Organic Hazardous cineration of Hazardous Waste: A Critique (Wash- Wastes (Washington, DC: March 1985). ington, DC: EWK Consultants, Inc. , 1983). 28. U.S. Environmental Protection Agency, Office of 19. Kleppinger, E. W., and Bond, D. H., Ocean in- Policy, Planning and Evaluation, “Background Re- cineration of Hazardous Waste: A Revisit to the port I: Description of Incineration Technology, ” Controversy (Washington, DC: EWK Consultants, Assessment of Incineration as a Treatment Method Inc., 1985). for Liquid Organic Hazardous Wastes (Washing- 20 Lentz, S. A., Testimony Before the Subcommittee ton, DC: March 1985). on Oceanography, House Committee on Merchant 29. U.S. Environmental Protection Agency, Science Marine and Fisheries, U.S. Congress, Hearing on Advisory Board, Report on the Incineration of Liq- ‘ ‘Incineration of Hazardous Waste At Sea, ” Nov. uid Hazardous Wastes by the Environmental Ef- 11 and Dec. 3, 1985, Serial No. 99-25 (Washing- fects, Transport and Fate Committee (Washington, ton, DC: 1986). DC: April 1985). 21 Metzger, J. F., and Ackerman, D. G., “A Summary 30. U.S. Environmental Protection Agency, Marine of Events, Communications, and Technical Data Operations Division of the Ofilce of Marine and Es- Related to the At-Sea Incineration of PCB- tuarine Protection, Assessment of the Impact of In- Containing Wastes Onboard the M/T Vulcanus, cineration of Chemical Wastes in the Proposed 20 December, 1981-4 January, 1982, ” prepared North Atlantic Incineration Site on Endangered and for the U.S. Environmental Protection Agency, Threatened Species (Washington, DC: July 9, March 1983. 1985). 22. Smith, G., ‘‘The Burning Question, San Fran- 31 U.S. Environmental Protection Agency, “Hearing cisco Chronicle, This World, May 12, 1985, pp. Officer’s Report on the Tentative Determination To 7-9. Issue the Incineration-At-Sea Research Permit HQ- 23 U.S. Environmental Protection Agency, Office of 85-001” (Washington, DC: May 1, 1986). Water and Hazardous Materials, Division of Oil 32 Wastler, T. A., Offutt, C. K., Fitzsimmons, C. K., and Special Materials Control, Final Environmental et al., Disposal of Organ ochlorine Wastes, EPA- Impact Statement of Designation of a Site in the 430/9-75-014, contract report prepared for the U.S. Gulf of Mexico for Incineration of Chemical Wastes Environmental Protection Agency (Washington, (Washington, DC: 1976). DC: July 1975).