U.S. ENVIRONMENTAL PROTECTION AGENCY
Background Document
on
The Tentative Determination
To Issue
Incinerat1on-At-Sea Permits
HQ 83-001 (Special)
HQ 83-002 (Special)
HQ 83-003 (Research)
Criteria and Standards Division
Office of Water Regulations and Standards
Office of Water
October, 1983
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27651
TABLE OF CONTENTS
I. INTRODUCTION
1. Foreword 1
2. Background J 5
3. Summary of the Permits I ! ! 11
II. FINDINGS
1. Introduction 19
2. Compliance with the Ocean Dumping
Regulations 21
3. Compliance with the London Dumping
Convention 92
4. Compliance with TSCA Regulations
When Incinerating Liquid PCBs 115
5. Consistency With Land-Based Incinerators
Permitted Under RCRA 125
6. U.S. Coast Guard's Findings on the
Contingency Plan 136
7. Conclusion ' 133
III. SECTION-BY-SECTION ANALYSIS OF THE PERMITS 139
APPENDIX I - POHC Case Examples
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I. INTRODUCTION
1. Foreword
The U.S. Environmental Protection Agency (EPA) has made a
tentative determination to issue special and research permits to
Chemical Waste Management, Inc., Oak Brook, Illinois, and Ocean
Combustion Service, B.V., Rotterdam, the Netherlands, for the M/T
VULCAMUS I and M/T VULCANUS II to transport and dispose of material as
authorized by the Marine Protection, Research, and Sanctuaries Act of
1972 (the Act), as amended.
Chemical Waste Management, Inc., and Ocean Combustion Service (the
Applicants) submitted an application for a Special Permit on July 10,
1981, and an application for a Research Permit on November 2, 1981.
Public meetings were held in Brownsville, Texas, May 25, 1982, and in
Mobile, Alabama, May 27, 1982, to consider the Applicants' permit
requests and to discuss the preliminary results of the first research
burn on PCBs (HO 81-002). On August 31, 1982, a public hearing was
held in Brownsville, Texas to receive formal comments on the
Applicants' request for permits and to outline the quality assurance
and quality control procedures used in monitoring the second PCB
research burn. Subsequent to the public hearing and after considering
the hearing record, the Agency decided to revise its approach in
developing the conditions for the proposed permits.' The Assistant
Administrator for Water made a> new tentative determination to issue
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permits based on the finding that the activities under the proposed
permits would not unreasonably degrade or endanger human healthl,
welfare or amenities, or the marine environment, ecological systems or
economic potentialities of the oceatflbecause the proposed permits are
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consistent with the Ocean Dumping Regulations in 40 CFR Parts 220-228
and^the CONVENTION ON THE PREVENTION OF MARINE POLLUTION BY DUMPING OF
WASTES AMD OTHER MATTER (the London Dumping Convention} to which the
United States is a Contracting Party. With respect to the incineration
of PCRs, the proposed permits meet the requirements of the regulations
in 40 CFR 761.70(a) implementing provisions of the Toxic Substances
Control Act on the incineration of liquid PCBs. In addition, as a
matter of Agency policy, the proposed permits are consistent with the
Resource Conservation and Recovery Act regulations on land-based
incinerator facilities in 40 CFR Part 264, Subpart 0.
The purpose of this background document is to provide all
interested parties with an opportunity to comment on the factors
considered in reaching the tentative determination to issue the permits
and to invite public comment on the principles used in developing the
permits for the incineration at-sea program. These principles will be
used as a basis for developing specific criteria regulating
incineration at-sea activities.
Public hearings will be held to receive comments on the proposed
permits and the findings used as a basis for the tentative
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determination to issue the permits, in the following locations on the
dates and at the times specified below:
1. November 21, 1983, from 9:00 a.m to 10:00 p.m.
Jacob Brown Auditorium
Brownsville Civic Center
600 International Boulevard
Brownsville, Texas
2. November 22, 1983 from 7:00 p.m. to 10:00 p.m.
November 23, 1983 from 9:00 a.m. to 1:00 p.m.
Mobile Gas Service Corporation Auditorium
2828 Dauphin Street
Mobile, Alabama
Registration will begin at 8 a.m. for day sessions and at 6:00
p.m. for the Mobile evening session. A 30 minute staff presentation
will open all sessions and if necessary, a summary of the staff
presentation will be repeated at 7 p.m. for the Brownsville session.
All speakers must register and will be heard in the order in which they
have registered. Remarks should be summarized in five minutes or less.
Speakers are encouraged to submit written statements for the record.
Comments on the tentative determination to issue the permits and the
principles on which the permits are based should be sent by December 8,
1983, to:
Patrick M. Tobin
Criteria and Standards Division (WH-585)
Office of Water Regulations and Standards
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
(202) 755-0100
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Information on Incineration at-sea and all reports and studies
cited in this background document may be examined at the following
locations during normal business hours:
United States Environmental Protection Agency
Library, Room 2904 Mall (Rear)
401 M Street, S.W.
Washington, D.C. 20460
Attn: Ms. Gloris J. Butler
(202) 382-5926
U.S. Army Corps of Engineers, Brownsville,
Room 508, Boca Chica Towers
2100 Boca Chica Blvd.
Brownsville, Texas 78520
Attn: Mr. Arthur Barrera
(512) 546-2456
State of Texas Law Library
Texas Supreme Court Building
13th and Colorado Streets
Austin, Texas 78711
Attn: Ms. Kay Schlueter
(512) 475-3807
U. S. Army Corps of Engineers, Mobile
Room 5031 New Federal Building
109 St. Josephs
Mobile, Alabama 36601
Attn: Ms. Cissy Scott
(205) 690-3182
For further information on the contents of this Background
Document and on the incineration at-sea program in general, contact:
Dr. Alan B. Rubin
Chief, Criteria Section
Criteria and Standards Division (WH-585)
U.S.. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
(202) 245-3030
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2. Background
Incineration is a method of thermally destroying liquid organic
compounds at high temperatures. The liquid wastes incinerated at-sea
are generated by a variety of industrial processes and for the most
part are defined as hazardous by EPA in Appendix VIII of 40 CFR 261.
Incineration at-sea is regulated under the Marine Protection,
Research and Sanctuaries Act of 1972, as amended, the regulations
promulgated thereunder in 40 CFR Parts 220-228 and the Annexes that are
binding on the United States as a Contracting Party to the CONVENTION
ON THE PREVENTION OF MARINE POLLUTION BY DUMPING OF WASTES AND OTHER
MATTER (London Dumping Convention). If incinerating polychlorinated
biphenyls (PCBs), the requirements of Section 6(e) of the Toxic
Substances Control Act (15 U.S.C. §2605(e)), and the regulations issued
thereunder in 40 CFR Part 761.70(a), apply.
The vessels used to transport hazardous wastes are certified by
the International Maritime Organization (IMO) and the U.S. Coast Guard.
The M/T VULCANUS I is a double-hull, double bottom cargo vessel that
was converted, in 1
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ship. The M/T VIILCANUS II has a similar design and is also classified
as a "Type II" chemical ship. It was launched in 1982 and has a length
of 93.55 meters, a beam of 16 meters and maximum draft of 6.2 meters.
Waste is carried in cargo tanks ranging in size from 112 cubic meters
to 574 cubic meters. The waste cargo capacity on M/T VULCANUS I is
3,503 metric tons (approximately 800,000 gallons) and on M/T VULCANUS
II the capacity is 3,170 metric tons (approximately 724,000 gallons).
The incinerator system on both vessels is located in the stern.
The M/T VULCANUS I has two incinerators; the M/T VULCANUS II has three
incinerators. The initial certification and biennial recertification
of the incinerators is performed by a Contracting Party to the London
Dumping Convention, which in the case of the VULCANUS vessels is the
Government of the Netherlands. In addition, the U.S. Coast Guard
inspects and certifies the safety of the incinerators as required by
P.L. 97-389, December 29, 1982.
The incinerator systems used in these vessels are refractory lined
furnaces consisting of two chambers - a combustion chamber for internal
mixing and a stack to ensure that adequte retention time for complete
combustion is available. Combustion gases pass through these two
chambers sequentially. The wastes are fed from storage tanks in the
vessels and pass through a gorator which reduces any solid particles
into a pumpable slurry. The liquid pumpable wastes are fed to the
combustion system by means of electrically driven pumps.
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be between 1166°C and 1350°C. The average waste residence time in the
incinerator will be on the order of one second or longer. Incinerator
systems such as those on the M/T VULCANUS I and II can process 20 - 25
metric tons of wastes per hour (as opposed to land-based incinerators
which process 2-4 metric tons per hour).
The emissions resulting from the incineration of mixed liquid
organic compounds consist primarily of hydrochloric acid, carbon
dioxide, carbon monoxide, and water vapor with minute amounts of
metallic oxides, silicate ash, partially combusted organic compounds
and possibly trace amounts of surviving organics. The hydrochloric
acid is rapidly diluted and neutralized by the ocean's buffering
capacity and any remaining metallic oxides, silicate ash, or surviving
organics are in such trace amounts that they do not exceed marine water
quality criteria. None of the emissions from incineration at-sea
activities has been demonstrated to have an adverse impact on the
marine environment.
EPA issues research and special permits for incineration at-sea.
Research permits are issued for no more than 6 months and are used to
demonstrate the destruction efficiency of an incinerator on a
particular chemical compound. Incineration at-sea special permits are
issued for no more than three years, if it has been demonstrated that
the incinerator can achieve a destruction efficiency of at least 99.99
percent on the most difficult to burn compound in the waste mixture.
Incineration takes place only in specially designated areas. The
incineration sites must be outside areas of commercial and recreational
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There are three rotary cup type burners located on the periphery
of each incinerator near the base. Waste and if necessary, fuel oil
pass through a central tube to atomization nozzels near the periphery
of the rotary cup.^ High velocity combustion air supplied by large
fixed-speed blowers with a rated capacity of 90,000 cubic meters per
hour per incinerator, shape the flame. The burners with their rotating
cups are directed tangentially to the vertical axes of the incinerators
so that along with the combustion air they are able to swirl and mix
the combustion gases.
A three-way valve is employed on each burner. One valve position
allows wastes to feed into the incinerator; another valve position
allows fuel oil to feed into the incinerators alone or in combination
with the wastes; and a third valve position shuts off the wastes to the
incinerator. Wastes may only be fed though the incinerator, and then
only when the incinerator reaches steady state operating conditions.
The automatic shutoff valve position prevents the wastes from entering
the incinerators until the operating conditions specified for
temperature, oxygen, and carbon monoxide have been reached, or if any
of these operating conditions are not attained during the course of a
burn. Until the incinerator is in compliance with the operating
conditions, auxiliary fuel oil is burned.
Wastes are fed into the incinerator when the incinertors have
reached the operating conditions specified in the permit. The
temperature of combustion is -neasured at the incinerator wall and will
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traffic and away from areas of biological significance. The Gulf
Incineration Site is approximately 315 kilometers south, southeast of
Halveston, Texas and encompasses approximately 4,900 square kilometers.
It was originally designated as an incineration site on September 15,
1976, (41 FR 39319) and was redesignated on April 26, 1982, (47 FR
17817).
Since 1974, the M/T VULCANUS I has conducted four series of burns
under EPA permits. Between October 1974, and January 1975, 8400 metric
tons of organochlorine wastes from the Shell Chemical Company Deer Park
manufacturing complex were incinerated in the Gulf of Mexico under a
Research permit. Under an interim permit,* a second series of burns,
totaling 29,100 metric tons of mixed wastes were conducted at the Gulf
Incineration Site in 1974-1975 and in 1977. A third series of burns
followed during July 1977 under a research permit and during September
1977 under an interim permit, when Herbicide Orange was incinerated at
a site 322 kilometers west of Johnston Atoll in the Pacific Ocean. The
last series of burns were performed in 1981 and 1982 when liquid PCB
wastes were incinerated under a research permit at the Gulf
Incineration Site.
* Interim permits were used only until April 1978.
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Since 1974, EPA has acquired substantial experience in regulating
the incineration of mixed chemical wastes in incinerator vessels and in
land-based incinerator facilities. During this same period, there have
been significant improvements in analytical techniques, methodology,
and instrumentation. These improvements allow the detection of minute
quantities of any compound in a waste mixture, in the combustion
emission, and in the environment. Based on EPA's accumulated
experience in monitoring the incineration of hazardous wastes and on
the improvements in incinerator technology and analytical methodology,
EPA is confident that the proposed permits will provide the same or a
greater degree of protection to public health and the environment as
other hazardous waste disposal alternatives.
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3. Summary of the Permits
The Special Permits (HQ 83-001 and HQ 83-002) would authorize the
Applicants, over a three year period, to use both vessels to transport
to the designated Gulf Incineration Site (in the Gulf of Mexico) and
incinerate at the site a combined total of 300,000 metric tons
(approximately 79.7 million U.S. gallons) of mixed liquid organic
compounds. The M/T VULCANUS I would be authorized to incinerate mixed
liquid organic compounds having heats of combustion of 1.79 kcal/gram
or greater and the M/T VULCANUS II would be authorized to incinerate
mixed liquid organic compounds having heats of combustion of 0.24
kcal/gram or greater. Both vessels are authorized to incinerate TCDD
at a maximum concentration of 2 ppm and PCBs at a maximum concentration
of 35 percent by weight.
The Research Permit (HQ 83-003) would be issued for six months and
would authorize the Applicants to demonstrate that the M/T VULCANUS
II's incinerators could attain a destruction efficiency of 99.99
percent or greater on 10 percent dichlorodiphenyl trichloroethane
(DDT), 90 percent solvent wastes.
Part III of this Background Document includes a section-by-section
analysis of the permits. The major provisions of the proposed permits
are summarized below:
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EPA Signature:
Assistant Administrator for Water
Permittees:
Chemical Waste Management, Inc., Oak Brook, Illnois and its
subsidiary Ocean Combustion Service, B.V., Rotterdam, the
Netherlands.
Vessels:
0 HO 83-001: M/T VULCANUS I
0 HO R3-002: M/T VULCANUS II
0 HO 83-003: M/T VULCANUS II
Required Vessel and Incinerator Certifications
0 Certificate of Fitness issued by the International Maritime
Organization.
0 Letter of Compliance issued by the U.S. Coast Guard
0 Survey Report and Form of Approval for the incinerators issued
by a Contracting Party to the London Dumping convention.
Compliance with the Requirements of Other Laws and Conventions:
0 THE CONVENTION ON THE PREVENTION OF MARINE POLLUTION BY DUMPING
OF WASTES AND OTHER MATTER (London Dumping Convention).
0 Section 6(e) of the Toxic Substances Control Act, 15 ll.S.C
§2605(e). The Assistant Administrator for Pesticides and Toxic
Substances must grant written approval of the Permits before the
incineration of any wastes containing PCBs may occur.
0 Solid Waste Disposal Act, as amended by the Resource
Conservation and Recovery Act, 42 U.S.C. §6901, et seq.
Permit Program Manager:
0 Director, Criteria and Standards Division, Office of Water
Regulations and Standards
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Permit Term:
0 HQ 83-001: 3 years (Special Permit)
0 HO 83-002: 3 years (Special Permit)
0 HO 83-003: 6 months (Research Permit)
Eligible Materials in Wastes to be Incinerated:
0 HO 83-001: liquid organic compounds with heats of combustion
equal to or greater than 1.79 kcals/gram
0 HO 83-002: liquid organic compounds with heats of combustion
equal to or greater than 0.24 kcal/gram
0 HO 83-003: liquid DDT wastes consisting of 10 percent DDT in
90 percent organic solvents having heats of
combustion equal to or greater than 0.24 kcal/gram.
Prohibitions and Limitations on Materials Incinerated
o
o
HO 83-001 and HQ 83-002:
- Ouantifiable concentrations of compounds with heats of
combustion less than 1.79 kcal/gram (HO 83-001) or 0.24
kcal/gram (HO 83-002)
- Quantifiable concentrations of
— DDT and associated compounds DDO, DDE
-- PCT (polychlorinated triphenyls)
— BHC (lindane)
- TCDD (dioxin) in concentrations exceeding 2 ppm
- PCBs in concentrations exceeding 35 percent
- Chlorine in concentrations exceeding 70 percent
- Over 100 ppm of arsenic, cadmium, chromium, copper, lead,
nickel, selenium, thallium, zinc
- Over 9 ppm mercury
- Over 20 ppm silver
- Materials which are produced for radiological, chemical, or
biological warfare, high-level radioactive wastes, materials
which cannot be identified or which are persistent and may
float or remain in suspension.
HQ 83-003:
- identical to above, except TCDD and PCBs are excluded from
the trial burn under the Research permit.
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Waste Analysis
0 Before each incineration cruise an analysis of the wastes is
conducted in accordance with EPA-approved protocols (in Appendix
A of the Permit) in an EPA-approved laboratory
0 Duplicate samples may be taken by EPA or an EPA-authprized EPA
representative and may be coded and analyzed in an EPA-approved
laboratory to verify the Permittees' samples and analyses.
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Authorization for Loading and Incineration;
Provided in writing by the Permit Program Manager if:
0 it is determined that the Permittees successfully demonstrated
compliance with the performance standard, operating conditions
and other provisions of the permit on the previous incineration
cruise; and
0 it is determined that the wastes to be incinerated meet the
specifications in the permits.
Port of Departure;
Port of Mobile, Alabama
Incineration Site:
fiulf Incineration Site
Amount of Material Authorized to be Incinerated:
0 HO 83-001 and HO 83-002: a combined total of 300,000 metric tons
0 HO 83-003: 900 metric tons
Performance Standard:
0 HO 83-001: 99.99 percent destruction efficiency; 99.9 percent
combustion efficiency
0 HQ 83-002: 99.99 percent destruction efficiency; 99.9 percent
combustion efficiency
0 HQ 83-003: 99.99 percent destruction efficiency and 99.9 percent
combustion efficiency
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Operating Parameters:
0 HQ 83-001:
- temperature: minimum-1280°C: average-1303°C: prior to waste
feed 1n1tiation-1353°C
- oxygen: minimum-5%; average-10.1%
- carbon monoxide: maximum-!00 ppm; average-8 ppm
0 HQ 83-002:
- temperature: nrinimum-1166°C; average-1200°C: prior to waste
feed initiation-1250°C
- oxygen: minimum-5%; average-10.6%
- carbon monoxide: maximum-!00 ppm; average-22 ppm
- if incinerating TCDD or PCBs, same as HO 83-001
0 HQ 83-003:
- minimum and maximum parameters only are specified for
temperature, oxygen and carbon monoxide and are the same as
HO 83-002.
Automatic Waste Feed Shut-off;
Automatic devices shut-off the waste feed to the incinerator
whenever:
0 flameout occurs
0 minimum temperature or oxygen, or maximum carbon monoxide,
are reached; or
0 monitoring devices fail for temperature, air flow, draft
(negative pressure) in the combustion chambers, oxygen,
carbon monoxide, carbon dioxide, waste feed and/or auxiliary
fuel (if used).
Monitoring Requirements;
0 Automatic, tamper proof devices are to continuously monitor and
record temperature, air flow, oxygen, carbon monoxide, carbon
dioxide, draft (negative pressure) in the combustion chambers,
and waste feed and/or auxiliary fuel (if used).
0 At least hourly recordings of time, date, wind speed and
direction and vessel position, course and speed are to be made.
0 All monitoring data are to be submitted to the Permit Program
Manager for evaluation of compliance with the performance
standard, operating conditions and monitoring requirements of
the permit.
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Instrument Calibration:
0 Calibration of the instrument measuring temperature, air flow,
draft (negative pressure) in the combustion chambers, oxygen,
carbon monoxide, carbon dioxide, waste feed flow and auxiliary
fuel flow (if used) is to be done before each cruise, and in
accordance with manufacturer's recommendations or, more
frequently if conditions warrant. A permanent record is to be
made of each calibration.
Other Requirements:
0 No black smoke or extension of the flame above the plane of the
stack is allowed.
0 Ammonia is to be added to the plume, if necessary, to make it
visible.
0 A draft (negative pressure) of at least one (1) inch of water
column is to be maintained in all combustion chambers.
0 If tanks are washed, they must be washed with a combustible
solvent and such washings and any residues or ash remaining
after incineration are to be incinerated at-sea or, upon return
to port, incinerated in EPA-approved facilities or otherwise
properly disposed of in accordance with applicable EPA
regulations.
0 Any wash waters, ballast waters, or pump room bilge water found
to be contaminated are to be incinerated at sea or, on return to
port either incinerated in EPA-approved land-based facilities or
alternatively, treated in accordance with applicable EPA
regulations. In no case are these contaminanted waters to be
discharged directly to the ocean or into the harbor.
Verification of Permit Conditions:
Verification is by:
0 automatic tamper proof monitoring devices; and
0 24 hour per day independent observation of the incineration
activities by shipriders employed by and/or approved by and
responsible to EPA.
Contingency Plan:
The Contingency Plan, approved by the U.S. Coast Guard and EPA, is
to be followed during any accident or emergency.
Modifications to or Revocation of the Permit:
May result from:
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0 Factors stated at 40 CFR Section 223.3(a)(l-4)
0 The violation of any provision of the Permit including any
misrepresentation, inaccuracy or failure to disclose all
relevant facts in the permit application.
0 A change in any condition or fact upon which the Permit is based
that adversely affects human health or welfare or the
environment.
0 Failure to meet the performance standard or operating
conditions.
Penalties
0 Civil penalty of up to $50,000 per violation, per day.
0 Criminal penalty of up to $50,000 per violation, per day and/or
1 year in prison for each violation.
Liability Insurance
0 The Permittees shall inform the Permit Program Manager of any
decrease in their liability insurance.
The two sections that follow include: the FINDINGS and the
SECTION-BY-SECTION ANALYSIS of the Permits. The FINDINGS demonstrate
that the proposed permits are consistent with the requirements of: the
Ocean Dumping Regulations, and the London Dumping Convention and for
the purposes of incinerating PCBs, the TSCA regulations on the
incineration of liquid PCBs. In addition, as a matter of Agency
policy, the proposed permits are consistent with the RCRA regulations
on land-based incineration of hazardous wastes. The FINDINGS section
also give the U.S. Coast Guard's views on the Contingency Plan as a
guide for responding to potential emergencies and accidents while at
sea or in the harbor. The SECTION-BY-SECTION ANALYSIS of the proposed
Permits discusses the permit conditions and the rationales for their
selection.
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II. FINDINGS
1. INTRODUCTION
The Environmental Protection Agency (EPA) is authorized by the
Marine Protection, Research and Sanctuaries Act of 1972 (the Act), as
amended (33 DSC $1412), to issue permits for the dumping of material
into the ocean "where the Administrator determines that such dumping
will not unreasonably degrade or endanger human health, welfare, or
amenities, or the marine environment, ecological systems, or economic
potentialities." In establishing criteria for the review and
evaluation of permit applications, Section 102 of the Act requires that
consideration be given to the following:
"(A) The need for the proposed dumping.
"(B) The effect of such dumping on human health and welfare,
including economic, esthetic, and recreational values.
"(C) The effect of such dumping on fisheries resources, plankton,
fish, shellfish, wildlife, shorelines and beaches.
"(D) The effect of such dumping on marine ecosystems, particularly
with respect to- .
(i) the transfer, concentration, and dispersion of such material
and its byproducts through biological, physical, and chemical
processes,
(ii) potential changes in marine ecosystem diversity,
productivity, and stability, and
(iii) species and community population dynamics.
"(E) The persistence and permanence of the effects of the dumping.
"(F) The effect of dumping particular volumes and concentrations of
such materials.
"(G) Appropriate locations and methods of disposal or recycling,
including land-based alternatives and the probable impact of
requiring use of such alternate locations or methods upon
considerations affecting the public interest.
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"(H) The effect on alternate uses of oceans, such as scientific
study, fishing, and other living resource exploitation, and
nonliving resource exploitation.
"(I) In designating recommended sites, the Administrator shall
utilize wherever feasible locations beyond the edge of the
Continental Shelf."
In addition, the Act provides that the standards and criteria
binding on the United States as a Contracting Party to the London
Dumping Convention, shall be applied to the extent that application of
such criteria do not relax the requirements of the Act.
EPA made the tentative determination to issue the proposed
permits because the proposed dumping would "not unreasonably degrade or
endanger human health, welfare, or amenities, or the marine
environment, ecological systems or economic potentialities." The basis
for that determination included a comparison of the proposed permits
with:
0 the criteria for the review and evaluation of ocean dumping
permits in 40 CFR Parts 220-228, which implement Section 102 of
the Act;
0 the regulations and technical guidelines of the London Dumping
Convention;
0 the regulations in 40 CFR 7fil.70(a) implementing the Toxic
Substances Control Act (15 USC §2fi01, P.L. 94-466, Oct. 11,
1976), because the applications proposed to incinerate
polychlorinated biphenyls (PCBs) in the mixed organic chemical
wastes ;
0 the regulations in 40 CFR 264.340-.351 implementing the
requirements for land-based incinerators under the Solid Waste
Disposal Act, as amended by the Resource Conservation and
Recovery Act (42 USC 6905, 6912(a), 6924, 6925, and 6927), if
applicable, as a matter of Agency policy that incineration
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at-sea permits be at least equivalent to land-based incinerator
permits.
The FINDINGS compares the requirements in each of the above to the
proposed permits and gives EPA's rationale for concluding that the
proposed permits are consistent with each of them.
In addition, EPA requested the assistance of the U.S. Coast Guard
in evaluating the adequacy of the Contingency Plan in implementing
procedures to protect the environment, if accidents or life threatening
incidents should occur in the harbor or at-sea.
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2. COMPLIANCE WITH THE OCEAN DUMPING REGULATIONS
The Ocean Dumping Regulations require in 40 f.FR 220.3(f) that
"permits for incineration at-sea are to be issued only as research
permits... until specific criteria to regulate this type of disposal
are promulgated, except in those cases where studies on the waste, the
incineration method and vessel, and the site have been conducted and
the site has been designated for incineration at-sea in accordance with
the procedures of Section 228.4(b). In all other respects the
requirements of Parts 220-228 apply".
If the studies have been performed and an incineration site has
been designated in accordance with Part 228, the criteria that the
Administrator is to use in reviewing and evaluating ocean dumping
permits, as required by Section 102 of the Act, are in Part 227.
Subpart A of Part 227 states that:
"(a) If the applicant satisfactorily demonstrates that the
material proposed for ocean dumping satisfies the environmental
impact criteria set forth in Subpart B, a permit for ocean dumping
will he issued unless:
(1) There is no need for the dumping, and alternative means of
disposal are available, as determined in accordance with the
criteria set forth in Subpart C; or
(2) There are unacceptable adverse effects on esthetic,
recreational or economic values as determined in accordance with
the criteria set forth in Subpart D; or
(3) There are unacceptable adverse effects on other uses of the
ocean as determined in accordance with the criteria set forth in
Subpart E" (emphasis added).
The following discussion explains, in detail, the studies of the
waste, the incineration method and vessel, and the site necessary for
issuing a special permit under Section 220.3(f). Then, the
requirements of Part 227, Subparts B, C, D and E, and the criteria that
were taken into consideration in establishing the Gulf Incineration
Site, are discussed. In applying the criteria in Parts 227 and 228 for
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Incineration at-sea permits, EPA evaluated the emissions resulting from
the incineration of mixed liquid organic compounds as the materials to
he disposed of by ocean dumping. The emissions may include:
hydrochloric acid; carbon dioxide; carbon monoxide; water vapor and
trace amounts of metallic oxides, silicate ash and partially combusted
and surviving organic compounds.
(a) Permits for Incineration at-Sea (40 CFR 220.3(f)
"Permits for incineration of wastes at sea will be issued only as
research permits... until specific criteria to regulate this type
of disposal are promulgated, except in those cases where studies
on the waste, the incineration method and vessel, and the site
have been conducted and the site has been designated for
incineration at-sea in accordance with the procedures of
S228.4(b). In all other respects the requirements of Parts
220-228 apply."
EPA has not promulgated any specific criteria for incineration
at-sea permits. However, EPA has concluded that adequate studies have
been conducted on the waste, incineration method and vessel, and the
site. This part describes the system that will be used to satisfy the
requirement that studies on the waste and incineration method, and
vessel be conducted without requiring that a study on the incineration
method and vessel be conducted for each compound in a waste mixture.
In addition, this part discusses the tests that were conducted to
qualify the vessels for the wastes that they are authorized to
incinerate. Descriptions are also given on the environmental
monitoring studies conducted at the Gulf Incineration Site.
(1) The heat of combustion of principal organic hazardous constituents
(POHCs) is used as a surrogate for determining the incinerability of
the entire waste mixture.
The liquid organic wastes to be incinerated are complex mixtures
of many different compounds. A surrogate system was developed so that
22
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a trial burn would not have to he conducted on each compound in a waste
mixture prior to authorizing that waste mixture to be incinerated.
This surrogate system was first described in the rulemaking for
"Incinerator Standards for Owners and Operators of Hazardous Waste
Management Facilities" - Interim Final Rule Parts 264 and 122, 46 FR
7666, January 23, 1981, and has been used in recent permits for
land-based incineration of complex wastes mixtures under the Resource
Conservation and Recovery Act (RCRA).
Under the system, principal organic hazardous constituents (POHCs)
are selected to measure the performance of the incinerator during test
burns under a research permit. A POHC is an organic chemical in the
waste mixture that has been identified as hazardous by EPA in Appendix
VIII of 40 CFR 261. Generally, those organic constituents which are
most difficult to destroy, as measured by their heat of combustion, and
most abundant in a waste mixture, are selected as POHCs.* During the
trial burn, the incinerator is operated to demonstrate a destruction
efficiency** of at least 99.99 percent on each POHC designated for the
trial burn.
* For examples of how the POHCs are selected see Appendix I to this
document.
** The formula for determining Destruction Efficiency is:
Destruction Efficiency =
Total POHC fed - POHC in combustion gases x 100
—" total POHC fed
23
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A destruction efficiency of at least 99.99 percent was estahlished
as a performance standard based on extensive data indicating that such
a destruction efficiency is attainable and can be routinely measured in
incinerators burning a wide range of organic hazardous wastes in
concentrations over 100 ppm. A 99.99 percent destruction efficiency
ensures that there will be no products of incomplete combustion from
the incineration process, except as trace contaminants as required in
40 CFR 227.6 and as discussed elsewhere in the FINDINGS.
Waste mixtures that are eligible for incineration under special
permits are those mixtures that contain only those compounds or classes
of compounds with heats of combustion equal to, or greater than, the
POHC with the lowest heat of combustion on which the incinerator
demonstrated a destruction efficiency of 99.99 percent. By
demonstrating that an incinerator can achieve a destruction efficiency
of 99.99 percent on a particular POHC, EPA can generally be assured
that any less thermally stable hazardous constituents burned in that
incinerator under comparable conditions will be destroyed also.
Compounds with a lower heat of combustion have greater thermal
stability and are therefore more difficult to burn than compounds with
a higher heat of combustion. The Agency has ranked 293 hazardous
constituents by their heats of combustion* (expressed in kilo calories
* Heat of combustion is determined empirically in the laboratory
through bomb calorimetry or may be calculated through chemical bond
strengths.
24
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per gram (kcal/ gram)) in an index, "Ranking of Organic Hazardous
Constituents by Incinerability" (Index of Incinerability). The ranking
on the Index of Incinerability is in ascending order by ease of
incineration. For example, the compound most difficult to destroy has
the lowest heat of combustion and is listed first and the compound
least difficult to destroy has the highest heat of combustion and is
listed last.
Prior to loading the vessel, the permits require that an analysis
of the waste mixture to be incinerated be performed using EPA-approved
sampling and analytical protocols (listed in Appendix A of the
permits), and be conducted in an EPA-approved laboratory. The
compounds identified in the analysis of the waste mixture can be
r
compared to the Index of Incinerability to determine whether there are
any quantifiable concentrations* of chemicals in the mixture that have
a heat of combustion less than that of the POHC tested.
For a waste mixture containing compounds not listed on the Index
of Incinerability, the Permittees would have to demonstrate by one of
three methods that the incinerator could destroy such compounds to at
Quantifiable concentration is defined as a minimum concentration of a
discrete chemical constituent (element or compound) in a chemical
waste that can be detected, identified, and quantified without
confirmatory analyses. The amount of this concentration will vary
' depending on the chemical constituent, possible interferences of
other constituents in the chemical waste, the method of sample
preparation, and method of analytical detection, identification, and
quantification (as defined in Appendix A of the permits).
-------
least 99.99 percent efficiency. First, the Permittee could determine
the heat of combustion of the compound and then compare the heat of
combustion of the compound in question to that of any of the POHCs for
which the incinerator was tested. If the compound in question's heat
of combustion was equal to or greater than any of the POHCs tested, it
could be burned. However, if the heat of combustion was lower,
then the compound could not be incinerated until a test burn was
conducted to prove that the incinerator could destroy the compound to
at least 99.99 percent efficiency.
Second, the Permittees could determine the chemical class to which
the compound belongs and compare the lowest heat of combustion of any
member of that class to any of the POHCs on which the incinerator was
tested. Only if the heat of combustion of any member of that class was
greater than or equal to the POHCs tested could the compound be
incinerated.
Third, the Permittees could demonstrate the capability of the
incinerator to destroy the compound to at least 99.99 percent
efficiency by conducting a trial burn under a research permit. This
approach is resource intensive and, therefore, expensive.
There are five compounds identified in Annex 5 to the London
Dumping Convention on which doubts as to incinerability exist. These
compounds are:
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0 Polychlorinated biphenyls (PCPs)
0 Polychlorinated triphenyls (PCTs)
0 Tetrachlorodibenzo-p-dioxin (TCDD, dioxin)
0 Dichlorodiphenyl trichloroethane (DDT)
0 Benzene hexachloride (BHC, lindane)
in order for these compounds to be eligible for incineration under
a special permit, the applicant must demonstrate the ability of the
incinerator to achieve at least a 99.99 percent destruction efficiency
on the compound. At such time when substantial scientific data from
trial burns on these five compounds show a strong correlation between
destruction efficiency and incinerator operating conditions and/or
other data becomes available on the similarity of the performance of
incinerators on different vessels, EPA may make a determination that
there is no longer doubt as to the incinerability of these compounds.
If and when doubt no longer exists regarding the incinerability of
these five compounds, then incineration of these compounds will be
permitted in a manner similar to other organic hazardous compounds
using the Index of Incinerability.
In EPA's judgment, use of the POHC/Index of Incinerability
surrogate system as described above and the trial burns conducted on
the vessels, as described below, meet the requirements that studies of
the waste and incineration method and vessel he conducted prior to
issuing special permits for incineration at-sea.
27
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(2) Studies of the Incineration Method and Vessel
In accordance with Article VI1(1) of the London Dumping
Convention, the incineration system for every vessel must be initially
surveyed under the direction of a Contracting Party to the London
Dumping Convention. An initial survey is carried out to ensure that
during incineration of waste and other matter, combustion efficiency
(on the entire waste mixture) and destruction efficiency (on the POHCs
tested) are in excess of 99.9 percent.
The proposed permits require a destruction efficiency of 99.99
percent on the POHCs tested and a combustion efficiency of 99.9 percent
on the entire waste mixture. Extensive Agency data indicate a high
correlation between a 99.9 percent combustion efficiency and a 99.99
percent destruction efficiency. The lower combustion efficiency of
99.9 percent is due to the fact that a waste mixture is not pure; it
includes such elements as metals, sand and moisture which cannot be
destroyed completely. Combustion efficiencies are continuously
calculated on each incineration cruise. Destruction efficiencies are
calculated on each research permit cruise, but not necessarily on each
cruise under the special permits.
Annex 5, Regulation 3 of the London Dumping Convention specifies
that the Contracting Party under whose direction the survey is being
carried out shall:
"(i) approve the siting, type and manner of use of temperature
measuring devices;
(ii) approve the gas sampling system including probe locations,
analytical devices, and the manner of recording;
(iii)ensure that approved devices have been installed to
automatically shut off the feed of waste to the incinerator
if the temperature drops below approved minimum temperatures;
(iv) ensure that there are no means of disposing of wastes or
other matter from the marine incineration facility except by
means of the incinerator during normal operations;
28
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(v) approve the devices by which feed rates of waste and fuel are
controlled and recorded;
(vi) confirm the performance of the incineration system by testing
under intensive stack monitoring, including the measurements
of Oo, CO, C02, halogenated organic content, and total
hydrocarbon content using wastes typical of those expected to
be incinerated."
The incineration system is to be surveyed at least every two years
to assure that the incinerator continues to comply with the
regulations. In addition and in accordance with PL 97-389,
December 29, 1982, the U.S. Coast Guard inspects and certifies the
safety of the incineration system.
Initial inspection and certification of the M/T VULCANUS I's and
M/T VULCANUS II's incineration system was performed by the
Rijkswaterstaat, Government of Netherlands. Certificate of Approvals
were issued in June 1983, for the M/T VULCANUS I and in July 1983, for
the M/T VULCANUS II and therefore are current and valid.
Prior to issuing special permits allowing regular incineration of
mixed chemical wastes, EPA issues research permits or uses the initial
incinerator survey by a Contracting Party to the London Dumping
Convention to determine the destruction efficiency of an incinerator on
a particular compound, or to establish the incinerability of the five
compounds identified in Annex 5 of the London Dumping Convention.
The M/T VULCANUS I's incinerators are certified to incinerate
tetrachlorodibenzo-p-dioxin (TCDD, dioxin) in concentrations of less
than 2 ppm based on a 1977 trial burn of Herbicide Orange which
contained concentrations of dioxin averaging 1.9 ppm. The most recent
study of the M/T VULCANUS I's incineration system was the second trial
burn under Research Permit HQ 81-002, August 15-31, 1982 which
29
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qualified the M/T VULCANUS I to burn PCBs in concentrations of 35
percent and mixed liquid organic compounds with a heats of combustion
equal to or greater than 1.79 kcal/gram (hexachlorobenzene). A
discussion of these two trial burns follows.
(i) M/T VULCANUS I's Trial Burns
Incineration of U.S. Air Force stocks of Herbicide Orange was
performed onboard the M/T VULCANUS I operating in the Pacific Ocean
west of Johnston Atoll. Approximately 10,400 metric tons were
incinerated under permits granted to the U.S. Air Force and ocean
Combustion Service, BV. The first shipload was incinerated under
Research Permit No. 770DH001R and the second and third shiploads under
Special Permit No. 770DH001S.
EPA contracted with TRW, Inc., to perform combustion gas
monitoring during the incineration of the herbicide. The U.S. Air
Force issued a contract (No. F41608-77-C-0169) to the Brehm Laboratory
of Wright State University to analyze the stack gas samples for
2,3,7,8-tetrachlorodibenzo-p-dioxin.
Stack sampling operations utilized a USAF-OEHL benzene impinger
train and a modified U.S. EPA Method 5 train (Lear-Siegler) which
incorporated an organic vapor sorbent trap. The USAF-OEHL train was
the primary train for acquiring samples for the dioxin analysis,
whereas the Lear-Siegler train was used to acquire samples to be
analyzed for other organic species potentially present in the stack
gases. The Lear-Siegler train also served as a backup to the USAF-OEHL
train. Stack gas samples were acquired by a remotely activated, water-
cooled, stainless, steel probe capable of traversing the starboard
stack diameter of 3.4 meters.
30
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Usually a concentration of at least 100 ppm of a compound is
needed in a waste mixture to analytically measure and demonstrate an
incinerator's destruction efficiency on a compound to at least 99.99
percent. In the Herbicide Orange mixture, TCDD averaged only 1.9 ppm.
While an overall destruction efficiency of greater than 99.93
percent was obtained for dioxin in the three burns, EPA believes that
in actuality the incinerators probably achieved at least a 99.99
percent destruction efficiency on TCDD based on the fact that during
the same trial burn, the destruction efficiencies for 2,4-D and 2,4,5-T
were calculated to be greater than 99.999 percent. However, to be able
to demonstrate an unqualified destruction efficiency, there has to be a
detectable and quantifiable amount of a compound in the stack gas
samples. Failure to detect a compound does not mean that the compound
is not there, if the level of detection of the methodology is not
adequate to measure low levels of a particular compound. At that time,
the sampling methodologies employed did not have the analytical
sensitivity to measure such low levels of potentially surviving dioxin
in stack gas samples, particularly for mixtures that contained
compounds with a similar chemical structure as dioxin.
Dioxin is easier to incinerate than other compounds that the
vessels are authorized to include in a waste mixture. Dioxin has a
31
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heat of combustion of 3.43 kcal/gram, while hexachlorobenzene has a
heat, of combustion of 1.79 kcal/gram and tetrachlormethane has a heat
of combustion of 0.24 kcal/gram on which the M/T VULCANUS I and M/T
VULCAMUS II, respectively, demonstrated greater than 99.99 percent
destruction efficiencies.
In addition, incinerator plume modelling and subsequent ocean
dispersion modelling have demonstrated that emissions resulting from
the incineration of chemical wastes containing 2 ppm of dioxin at a
destruction efficiency of 99.93 percent will cause no adverse
environmental impact. This is based on a determination that any
potential uncombusted dioxin in the emissions would result in an
ambient marine water concentration of dioxin below the marine aquatic
life no-effect level for dioxin and below the limiting permissible
concentration as required by 40 CFR 227.27.
32
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The test results are shown in Figure I below.
FIGURE I
0 Incinerator wall temperature 1273°C (average)
0 Concentration of Oxygen (02) 8.9 percent (mean)
0 Concentration of Carbon Dioxide (COo) 10.3 percent (mean)
0 Concentration of Carbon Monoxide (CO) 10 pm (mean)
0 Residence time 1.0 second
0 Combustion Efficiency ,(CE) > 99.9
0 Destruction Efficiency*:
Dioxin (TCDD) > 99.93 (average)
2,4-D > 99.999
2,4,5-T > 99.999
More detailed information may be found in:
U.S. EPA, Office of Research and Development, At-Sea Incineration
Onboard the M/T VULCANUS. ~19l5
-_-_-
(EPA-600/2-78-08fi
For the August 1982, trial burns, EPA contracted with the Energy
and Environmental Division of TRW Inc., Redondo Beach, California, to
sample and monitor the incineration process and to analyze both raw
waste and combustion gas samples in order to determine whether the
vessel met the performance and operating requirements in the permit. A
representative from EPA was onboard during the testing, and a
technician-employee of EPA assisted the TRW test team.
*DE = 100 x Co-Cf
Where Co = emission concentration at 0*, destruction efficiency
Cf = emission concentration determined from analyses
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A standard EPA-specified sampling train* mandated for use in
testing land-hased incinerators for emissions of PCBs was modified for
at-sea analysis and was used to acqui-e sanples of the effluent
combustion gases. A fixed-position, water-cooled probe was mounted in
the starboard incinerator and directed stack gas to the train. Samples
from the emissions were analyzed for PCBs and chlorobenzenes by TRW.
The test results, in Figure II indicated below, show that the
operating conditions on the M/T VULCANUS I meet the requirements for
Incineration at-sea permits. The operating conditions established in
this trial burn are the average operating conditions required in the
permit.
More detailed information on the study of the M/T VULCANUS I's
incineration system and the wastes incinerated, including the
analytical procedures and quality assurance/quality control procedures
used in the study, iiay be found in:
U.S. EPA, Industrial Environmental Research Laboratory, At-Sea
Incineration of PCB-Containing Wastes on the M/T VULCAMUS (I).
1983. (EPA-6no/7-83-024).
* A sampling train is laboratory equipment used in collecting samples
of the emissions from incinerator stacks at high efficiency.
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FIGURF II. M/T VULCANUS I TRIAL BURN DATA
Incinerator wall temperature
Concentration of Oxygen (03)
Concentration of Carbon dioxide (CO?)
Concentration of Carbon Monoxide (CO)
Residence time
Combustion Efficiency (CE)
Destruction Efficiency (DE)*
-PCB, Octachloro
-Hexachlorobenzene
1303°C (average)
10.1 percent
9.1 percent
8 ppm
1.3 seconds
99.99 percent
>99.99
>99.99
(ii) M/T VULCANUS IPs Trial Burns
A study of the M/T VULCANUS IPs incineration system and its
initial survey and certification is based on a trial burn conducted by
the Government of the Netherlands during January and February 1983, at
the North Sea Incineration Site. As part of the initial survey,
Chemical; Waste Management, Inc., contracted with the Energy and
Environmental Division of TRW Inc., to measure the emissions of several
POHCs selected from the waste mixture incinerated. This study
established the eligibility of the M/T VULCANUS II to incinerate mixed
liquid organic compounds with a heats of combustion equal to or greater
* DE = 100 x Wi - Wo
Where:
Wi
Wi = mass feed rate into the incinerator
Wo = mass emission rate in the stack gas before release to the
atmosphere
Wo = FoCo
Where:
Fo = flow rate (dry) of combustion effluent in m^/hr.
Co = concentration in combustion effluent
Thus
DE = 100 x Wi-FoCo
Wi
35
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than 0.24 kcal/gram (tetrachloromethane on the Index of
Incinerabillty).
Sampling and chemical analyses were conducted according to a test
plan reviewed by EPA. fSee Plan for Sampling and Analysis of Volatile
Organics During a Certification-Voyage of the M/T VULCANUS II. Report
to Chemical Waste Management January, 1983). A standard volatile
organic sampling train (VOST)*, incorporating approved minor
improvements in design, was used to acquire samples of the effluent
gas. A stainless steel-jacketed, water-cooled probe with a quartz
liner was designed and fabricated for use with the VOST train. Four
complete tests were performed, and each test generated six pairs of
adsorbent tubes containing organic vapors from the combustion gases.
Pertinent process-related data were acquired from computer
printouts maintained by the Chief Engineer of the MA VULCANUS II.
These data included: temperatures in the incinerators, feed rates of
waste and air, and concentrations of carbon dioxide, carbon monoxide,
and oxygen in the stack gases.
The test results, as indicated below show that the operating
conditions on the M/T VULCANUS II meet the Agency's requirements for
* The VOST is used for testing land-based incinerators on
tetrachloromethane, one of the POHC's tested in the trial burn.
36
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incineration at-sea. The operating conditions established in this
trial burn are the average operating conditions required in the permit,
except when incinerating TCDD and PCBs, as explained later in this
section.
FIGURE III. M/T VULCANUS II TRIAL BURN DATA
0 Incinerator wall temperature 1166°C (average)
0 Concentration of Oxygen (02) 10.6 percent
0 Concentration of Carbon dioxide (CO?) 9.fi percent
0 Concentration of Carbon Monoxide (CO) 22 ppm
0 Residence time 1.1 seconds
0 Combustion Efficiency (CE) 99.9
0 Destruction Efficiency (DE)
Tetrachloromethane* >99.99 percent
Chloroform* >99.99 percent
1,1,2 Trichloroethane* >99.99 percent
1,2 Dichloroethane* >99.99 percent
1,1 Dichloroethane* >99.99 percent
More detailed information on the study of the M/T VULCANUS II1s
incinerator system and the wastes incinerated may be found in:
TRW, Incineration of Volatile Organic Compounds on the M/T
VULCANUS ll.Prepared for Chemical Waste Management, inc. Apri1
Memorandum from Merrill Jackson, to Steven Schatzow, Review of
Reports of At-Sea Incineration Onboard the M/T VULCANUS II.
June 24, 1983.~~
The requirement for test burns for the M/T VULCANUS II to
incinerate mixed liquid organic wastes containing TCDD and PCBs have
been waived. These waivers are based on a determination by EPA's
* These numbers are conservatively expressed based on a minimum 50%
VOST recovery.
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Industrial Environmental Research Laboratory (IERL-CI) that both
the M/T VULCANUS,I and M/T VULCANUS II are using the same equipment and
on EPA's accumulated experience with the monitoring of incinerators for
TCDD and PCBs emissions. These findings are contained in:
Memorandum from David 6. Stephan, Director, IERL-CI, to Patrick M.
Tobin, Acting Director, Criteria and Standards Division.
Recommended Operating Parameters, Past Performance Reliability
Considerations, and Similarity Considerations for VULCANUS I and
_IJ_. August 10, 1983.
Memorandum from Marcia E. Williams, Acting Director, Office of
Toxic Substances to Patrick M. Tobin, Acting Director, Criteria
and Standards Division. Waiver of a PCB Trial Burn for the
VULCANUS II. July 9, 1983:
Because of the determination that the equipment on both vessels is
the same, the operating conditions specified in the permit for the M/T
VULCANUS II (HQ 83-002) when it is incinerating TCDD and PCBs are the
same as those used in the permit for the M/T VULCANUS I (HQ 83-001).
(3) Environmental Studies at the Gulf Incinerator Site
In addition to the studies of the efficiency of the incinerator
systems, EPA has conducted environmental monitoring studies in
conjunction with the research permits. These studies include both air
and water quality monitoring and are summarized below.
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(1) Water quality studies
During the 1974-1975 incineration in the Gulf of Mexico of the
Shell Chemical Company's organochlorine wastes on the M/T VULCANUS I,
monitoring was conducted from airplanes and onboard two research
vessels (ORCA and OREGON II owned by NOAA and the Scripps Institute of
Oceanography, respectively). The incineration plume near the M/T
VULCANUS I was monitored by aerial photography and the air was sampled
from an Environmental Monitoring Systems Laboratory (EMSL), Las Vegas
aircraft which followed and periodically contacted the vessels'
incinerator plume. Dye tests were run to determine water current
patterns and diffusion rates, and samples of marine organisms
(plankton) were collected for identification and analysis. Surface
water was collected under the plume and analyzed for organochlorine
content, pH, chlorinity, trace metals, chlorophyll and adenosine
tri-phosphate (ATP) levels. No PCBs or other organochlorines were
detected and there were no noticeable effects on marine life due to the
incineration operations. Additional information on these studies may
be found in:
U.S. EPA, Disposal of Organochlorine Wastes by Incineration
at-Sea, 1975. (EPA-430/9-75-014).
During the August 1982, incineration of PCBs on the M/T VULCANUS I
under Research Permit HO 81-002, TerEco personnel, under contract to
EPA, conducted a 4-day baseline or pre-burn cruise to the Gulf Ocean
Incineration Site to check on the environmental conditions at the site
prior to the incineration of PCB wastes and to launch two pelagic
biotical ocean monitors (P-BOM's). In August, they participated in the
39
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monitoring cruise during which time they launched five P-BOM's, three
of which were impacted by the fallout of the plume from the M/T
VULCANUS I, and two of which served as controls. Three species of
marine organisms were exposed in each P-BOM and were processed for
laboratory analyses while still aboard the OSV ANTELOPE (an EPA owned
and operated research vessel).
Laboratory analyses involved determining the concentrations of
PCBs in the surface waters, in collectors placed on each P-BOM, in
neuston, and in the tissues of Menidia beryllina and Fundulus grandis
(both finfish). No increase in ambient water background levels of
organochlorines was detected from the incineration. Results show that
Fundulus and Menidia did not accumulate additional PCBs above their
background levels. The core of the monitoring effort centered in
determining the adenylate energy charge (AEC) of test (exposed to
fallout plume) and control individuals of the above species and the
grass shrimp Palaemonetes/pugio. Although the results of AEC
calculations revealed that all three species suffered some stress
during their stay on the ship and their exposure in the P-BOM's, it was
concluded that plume contact from the incineration of PCB wastes could
not have caused this physiological reaction. The more likely cause was
the stress caused by the long delay in deciding upon the vessel's
departure and the related long period that the test organisms had to
stay in crowded conditions.
40
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Metabolic enzyme analyses carried out on Fundulus tissues compare
favorably with results obtained by TerEco in other environmental
studies. No evidence was generated that related any metabolic change
in test animals directly to the incineration process. This study is
reported in.greater detail in:
U.S. EPA, Monitoring Results and Environmental Impact on the Gulf
of Mexico Incineration Site from Incineration of RGB's Under
Research Permit HQ 81-02. April 1983. Appendix v.
(ii) Air Monitoring Studies
In a 1978 report to EPA, monitoring data obtained from the Shell
at-sea incinerations in 1974-1975 and in 1977 and mathematical modeling
were used to describe the plume formed during incineration. Simulation
plume models estimating the maximum hydrochloric acid, organohalogens
and metal oxides released from the pluine to the air and to'the water
were compared to actual observations. The report indicated a strong
correlation between the simulation models and actual observations.
There was no increase in ambient air concentrations of organochlorines
in the vicinity of the vessel or wherever the plume contacted the water
surface. These findings are described in:
U.S. EPA, Environmental Assessment: At-Sea Incineration and_Land_
Based Incineration of Organochlorine waste?:Prepared by TRW,
Inc., under Contract No. 68-02-2660 (EPA-fcUO/2-78-087).
Similar results were also documented in:
U.S. Department of State and EPA, Fin^l_E^vj£onm^ntaJ_lmpact
Statement for Incineration of Wastes At Sea. Under the 1972 Ocean
Dumping Convention, 1979.
41
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Michael fiuttman, et al., Ambient Air Monitoring of the August
1982. M/T VULCANUS PCB Incineration at the Gulf of Mexico
Designated Site, La Jolla. California. ORB Associates, January
T98TT
In this latter report, JRB Associates using EPA's survey vessel
OSV ANTELOPE as a sampling platform, tracked the incineration plume and
collected ambient air samples for PCB measurement. The primary
objective was to determine if any detectable amounts of fugitive PCBs
or organochlorine residues from the incineration process could be found
in the atmosphere. Using a dispersion model to predict plume location
and guide the sampling, a secondary objective was to check the model's
validity using hydrogen chloride (HC1) from the incineration process as
a tracer.
Results from the baseline survey indicated only trace amounts of
air-borne organic materials, and no organochlorines were present. By
comparison, during the incineration monitoring significantly higher
amounts of air-borne organics were measured, but again no PCBs or other
organochlorines were detected. Presumably, the elevated airborne
organics were generated by combustion on the M/T VULCANUS I, either
from the waste incineration or from the vessel's engines. Real-time
HC1 monitoring assured that the incineration emission plume generated
by the M/T VULCANUS I was being sampled. Although there were
discrepancies between measured airborne HC1 levels and distributions
predicted by the model, agreement between the two was relatively good
considering the uncertainties involved in modeling atmospheric
stability.
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A report prepared by the Texas Air Control Board furnished
monitoring data for incineration plume remnants at several shore
locations taken during the test burn of PCBs in August 1982. The Texas
Air Control Board used special high vojume air samplers with glass
fiber pre-filters and polyurethane foam plugs to collect particulate
and gaseous PCBs, chlorinated dibenzodioxins, and chlorinated
dibenzofurans. Based on trajectory forecasts, it was estimated that
the plume from the M/T VULCANUS I would impact only one of the samplers
over one 48 hour period during the 339 hours of sampling conducted
during the burn period from August 16-28, 1982. Gas chromatographic
(GC) and gas chromatographic/mass spectrometric (GC/MS) analysis of the
foam plugs and pre-filters collected during the burn and post-burn
sampling did not indicate the presence of PCBs, other organochlorine
compounds, or hydrochloric acid. Further discussion of these tests may
be found in:
Texas Air Control Board, Report on Air Sampling for PCB's Along
the Texas Gulf Coast During Incineration Operations Cond'ucted by
the M/T VULCANUS I. April 1983.
In summary, based on the studies of the wastes, the incineration
systems on the M/T VULCANUS I and M/T VULCANUS II and the effects of
incineration on the incineration site, EPA has concluded that:
adequate studies have been conducted in accordance with 40 CFR
220.3(f);
the incinerators onboard the M/T VULCANUS I and M/T VULCANUS II
have demonstrated a destruction efficiency of at least 99.99
percent on the compounds proposed for incineration;
43
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no short term increases have been found in background
concentrations of organochlon'nes in the water, and no short
term effects have been found on water chemistry or biota exposed
to the plume in the vicinity of the vessels: and
air monitoring studies indicate no air borne emissions of
PCBs or other organochlorine residues from the incineration
process.
44
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(b) Subpart P - Environmental Impact
Subpart B, Sections 227.5 - 227.13 of the Ocean Dumping
Regulations sets forth specific environmental impact prohibitions,
limits and conditions for the dumping of materials in the ocean.
Section 227.4 states that "if the applicable prohibitions, limits and
conditions are satisfied, it is a determination of EPA that the
proposed disposal will not unduly degrade or endanger the marine
environment and that the disposal will present:
110 No unacceptable adverse effects on human health and no
significant damage to the resources of the marine environment;
110 No unacceptable adverse effect on the marine ecosystem;
110 Mo unacceptable adverse persistent or permanent effects due to
the dumping of the particular volumes or concentrations of
these materials; and
110 No unacceptable adverse effect on the ocean for other uses as a
result of direct environmental impact."
The analyses used in making that determination follow.
(1) Section 227.5 Prohibited Materials
"The ocean dumping of the following materials will not be approved
by EPA... under any circumstances:"
no
High-level radioactive wastes as defined in §227.30;"
110 Materials in whatever form (including without limitation,
solids, liquids, semi-liquids, gases or organisms) produced or
used for radiological, chemical or biological warfare;"
45
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110 Materials insufficiently described by the applicant in terms of
their compositions and properties to permit application of the
environmental impact criteria of this Subpart B;"
110 Persistent inert synthetic or natural materials which may float
or remain in suspension in the ocean in such a manner that they
may interfere materially with fishing, navigation, or other
legitimate uses of the ocean."
The incineration at-sea permits specifically prohibit these
materials from the wastes to be incinerated. There are a number of
provisions in the permits which will ensure that these prohibited
materials are not included in the wastes. As discussed earlier, prior
to loading the wastes onto the vessel, the Permittees must analyze the
wastes in accordance with EPA-approved procedures in EPA-approved
laboratories. The Waste Sampling and Analyses Procedures included in
Appendix A of the permits are the analytical protocols that must be
followed by the Permittees in analyzing their wastes. These protocols
require identification of quantifiable concentrations of the chemical
classes of the constituents. This is sufficient analytical detail to
ensure that prohibited materials are not in the wastes. In addition,
through the Permit Program Manager, EPA may authorize a duplicate
sample be taken by EPA or an EPA-authorized representative from the
blending/holding tanks, from the vessels' or dockside storage tanks to
verify the original chemical analyses submitted by the Permittees.
Loading of the vessel and incineration of the wastes are authorized
only after EPA is certain that the wastes do not contain prohibited or
restricted materials.
(2) Section 227.6 - Constituents prohibited as other than trace
contaminants
4fi
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Subpart B, 40 CFR 227.6(a) also prohibits the dumping of
organohalogens, mercury and mercury compounds, cadmium and known
carcinogens, mutagens or teratogens, except as trace contaminants.
Section 227.6(h) states that the prohibitions and limitations of
Section 227.6(a) do not apply "for the granting of permits for the
transport of these substances for the purpose of incineration at-sea,
if the applicant can demonstrate that the stack emissions consist of
substances which are rapidly rendered harmless by physical, chemical or
biological processes in the sea." These requirements are to be
established on a case-by-case basis.
The regulations do not define the criteria for determining whether
stack emissions are rapidly rendered harmless. However, Annex 5,
Regulation 5.2.1 of the London Dumping Convention states, "based on
current scientific knowledge on the environmental effects of
incinerating liquid organochlorine compounds, substances are rapidly
rendered harmless if the Regulations and Technical Guidelines are
observed." These Regulations and Technical Guidelines contain specific
operating parameters for the incinerators. As discussed under
"Compliance with the London Dumping Convention," and shown in Table 3,
"Hazardous Waste Incineration: Comparison of At-Sea and Land-based
Requirements", page 88, the requirements of the incineration at-sea
permits are equivalent to or more stringent than the requirements of
London Dumping Convention.
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In addition, the permits prohibit the incineration of wastes
containing compounds with heats of combustion less than that of the
principle organic hazardous constituent (POHC) for which the
incinerator demonstrated at least a 99.99 percent destruction
efficiency. This prohibition means that all compounds in the wastes
should be destroyed to at least 99.99 percent efficiency and any
emissions from incineration will be rapidly rendered harmless, as
required in Section 227.6(h).
As discussed later in this part, modelling studies also indicate
that if the destruction efficiency on the organic compounds is at least
99.99 percent, the emissions from the incinerator meet all the
conditions necessary to establish that they are rapidly rendered
harmless.
Therefore, EPA concludes that the stack emissions will not contain
any prohibited constituents in Section 227.6(a) except as trace
contaminants which are "rapidly rendered harmless" as provided for
under Section 227.6(h) and in accordance with the Regulations and
Technical Guidelines of the London Dumping Convention.
(3) Section 227.7 - Limits established for specific wastes or waste
constituents
Section 227.7 establishes additional limitations on certain
materials for these materials to be acceptable for ocean dumping. The
permits comply with this section as follows:
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(i) Section 227.7(a). Incinerating the entire waste mixture to
the required 99.9 combustion efficiency is more than
sufficient to assure that the trace contaminants in the
emission when they reach the water are totally soluble.
(ii) Section 227.7(b). The permits do not allow the incineration
of containerized wastes. Therefore, the provision that low
level radioactive materials be containerized is not
applicable.
(iii)Section 227.7(c). The gaseous emissions are stenle and
therefore do not contain living organisms.
(iv) Section 227.7(d). The stack emissions contain hydrochloric
acid but in amounts which EPA has determined are rapidly
neutralized by the ocean after allowance for initial mixing
as defined in 40 CR 227.29.
(iv) Section 227.7(e). The gaseous emissions contain no
biodegradable constituents or constituents which consume
oxygen in any fashion.
(4) Section 227.8 - Limitations on disposal rates of toxic wastes.
Section 227.8 states that "no wastes will be deemed acceptable for
ocean dumping unless such wastes can be dumped so as not to exceed the
limiting permissible concentrations as defined in Section 227.27.
Limiting permissible concentration is defined as "that concentration of
a constituent which, after allowance for initial mixing as defined in
Section 227.29, does not exceed applicable marine water quality
criteria..." or where there are no marine water quality criteria, that
concentration of a waste which ... "will not exceed a toxicity
threshold defined as 0.01 of a concentration shown to be acutely toxic
to appropriate sensitive marine organisms in a bioassay carried out in
accordance with approved EPA procedures."
49
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To determine the maximum concentration of metals which could be
included in a waste mixture so that the resulting emissions reaching
the water would not exceed applicable marine water quality criteria or
the limiting permissible concentration, a model was developed for EPA
that was more stringent than necessary to comply with Section 227.0 for
initial mixing. The model used a combination of a mixing zone model
and a plume dispersion model. This model was then used to calculate
the maximum concentrations of metals in the stack gases to ensure that
the marine water quality criteria for the metals would not be exceeded.
It was then possible to determine the maximum concentration of metals
in the wastes so that the marine water quality criteria were not
exceeded as a result of incinerating the wastes. A full discussion of
the model may be found in:
JRB Associates. Permissible Metal, PCB, and Dioxin
Concentrations inTncineratlon Waste Material. Report submitted
under EPA Contract Mo. 68-01-6388, Work Assignment No. 37,
September 1983.
Other than silver, which the model indicated should not exceed 20
ppm in the waste mixture and mercury, which should not exceed 9 ppm,
metals could be in significantly higher concentrations than the 100 ppm
requirement included in the proposed permit and still would not exceed
the marine water quality criteria for each of the metals. However, EPA
has retained the 100 ppm concentration limit for each of the metals
other than for silver and mercury, in recognition of the modelling
uncertainties and until long term monitoring can verify that emissions
of trace amounts of metals indeed have no impact on the environment.
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Only after substantial long term monitoring, will EPA evaluate all the
data and seek public input to determine if these allowable metal
concentrations in waste can be relaxed.
A similar set of models was used to document that trace quantities
(if any) of TCDD and PCBs which might be released in.the stack gases
would not cause the marine aquatic life no effect level or the marine
water quality criterion to be exceeded. TCDD and PCB were chosen as
surrogates for all organic compounds because TCDD and PCBs are among
the most toxic, persistent and bioaccumulative of all the organic
compounds. The model showed that if TCDD and PCBs were in
concentrations of 2 ppm and 35 percent or less, respectively, and if
TCDD was destroyed to 99.93 percent efficiency and PCBs were destroyed
to at least 99.99 percent efficiency, any surviving TCDD or PCBs
emitted in the incinerator plume would result in ambient marine water
concentrations of TCDD and PCBs below the marine aquatic life no effect
level or the marine water quality criterion for TCDD and PCB,
respectively, which is below the limiting permissible concentrations as
required in 40 CFR 227.27. In fact, after incineration and mixing of
surviving PCBs in the water, PCBs were not detected in concentrations
beyond background levels. This determination was based on the
environmental monitoring conducted in conjunction with the August 1982,
trial burn. Based on these studies, TCDD and PCBs may be included in
the wastes in concentrations no greater than 2 ppm and 35 percent by
weight, respectively.
The special permits do not require that destruction efficiency be
determined for constituents on each load of wastes that are
incinerated. However, from time-to-time, the Permit Program Manager
51
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may request that the Permittees sample and analyze the wastes and
emissions to verify that the operating conditions established in the
special permits achieve the performance standard of 99.99 percent
destruction efficiency. The special permits do require that a
performance standard of at least 99.9 percent combustion efficiency be
attained on each load of wastes incinerated. Based on EPA's
accumulated experience and judgment, a combustion efficiency of at
least 99.9 percent on the entire load of mixed chemical wastes
corresponds to destruction efficiencies of at least 99.99 percent on
compounds with heats of combustion greater than the POHCs tested.
Combustion efficiencies are continuously calculated on each
incineration cruise. Therefore, EPA concludes that the permits will
result in emissions below the limiting permissible levels as required
in Section 227.8.
(5) Section 227.9 - Limitations on quantities of waste materials
The permits are consistent with Section 227.9 because the quantity
of material in the emissions will not damage the ocean environment or
reduce its amenities. Monitoring conducted thus far shows no
detectable adverse environmental impact, as shown in the foregoing
discussion of environmental monitoring conducted at the site. As a
precaution, EPA is restricting, at this time, the use of the Gulf
Incineration Site and any other site which is designated to one vessel
at a time. This is being done for navigational safety and until the
Agency evaluates the monitoring data from the site. This does not
mean that only one Permittee may use a site. Rather, EPA will assure
that there is an equitable distribution of the use of a site among all
Permittees.
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EPA, in cooperation with the National Oceanic and Atmospheric
Administration (NOAA), U.S. Department of Commerce, has developed a
monitoring strategy to measure the long-term impacts on human health
and the marine environment associated with the incineration at-sea of
mixed liquid organic wastes. Measurements for the strategy include
both atmospheric and ambient physical, chemical and biological analyses
of the marine environment. The monitoring strategy is designed to
produce generic and site-specific long-term monitoring plans that can
be used both as predictive tools for identifying potential areas of
environmental impact and, if necessary, for triggering permit
modifications. The computer models generated for the implementation of
the strategy will be sufficiently flexible to predict cumulative
effects of multiple vessel and long-term burns.
(6) Section 227.10 - Hazards to fishing, navigation, shorelines or
beaches
The permits meet the requirements of Section 227.10. The location
of the incineration site was specifically chosen because it is removed
from fishing areas and it is outside of the normal shipping fairways
for commercial and recreational vessels. As the monitoring data
discussed earlier indicate, the emissions pose no threat to fishing,
navigation, shorelines or beaches. The characteristics of the site are
discussed in detail later in the FINDINGS.
(7) Sections 227.11 - Containerized wastes; Section 227.12 - Insoluble
wastes; Section 227.13 - Dredged material
Sections 227.11, 227.12, and 227.13 are not applicable to the
incineration at-sea permits because the permits do not authorize the
incineration of containerized wastes or dredge material. The emissions
from incineration are below limiting permissible levels, which complies
with the criteria for soluble wastes established in Section 227.12.
53
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Based on the above analysis, EPA has determined that the
incinerator emissions will meet the criteria of Subpart B and that the
proposed release of the emissions to the marine environment will not
unduly degrade or endanger the marine environment.
Section 227.2(a) provides that if the applicants' wastes satisfy
the environmental impact criteria in Subpart B, a permit will be issued
unless:
(1) There is no need for the dumping, and alternative means of
disposal are available, as determined in accordance with the
criteria set forth in Subpart C; or
(2) There are unacceptable adverse effects on esthetic,
recreational or economic values as determined in accordance
with the criteria set forth in Subpart D; or
(3) There are unacceptable adverse effects on other uses of the
ocean as determined in accordance with the criteria set forth
in Subpart E.
The remaining sections of this part discusses EPA's determination
that there is a need for ocean dumping, that there are no unacceptable
impacts on esthetic, recreational or economic values of the ocean and
.that there are no unacceptable adverse effects on other uses of the
ocean.
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(c) Subpart C - Need for Ocean Dumping
Subpart C of Part 227 (40 CFR 227.14-.16) states the basis on
which an evaluation will be made of the need and the alternatives to
ocean dumping. Section 227.15 lists the factors to be considered in
determining the need for dumping, and section 227.16 lists the
determinations that musL be made, after thorough evaluation of those
factors. The determinations that must be made include:
"(1) There are no practicable improvements in process technology or
overall waste treatment to reduce the adverse impact of the waste in
the total environment;
"(2) There are no practicable alternative locations or methods of
disposal or recycling available, including without limitation storage
until treatment facilities are completed, which have Jes_s adverse
environmental impact or potential risk to other parts of the
environment than ocean dumping" (Emphasis added).
Section 227.16 (b) defines practicable as "...available at
reasonable incremental cost and energy expenditures, which need not be
competitive with the costs of ocean dumping..."
The determinations and the factors to be considered in making the
determinations are discussed below.
1. There are no practicable improvements in process technology or
overall waste treatment to reduce the adverse impact of the waste on
the total environment.
Section 227.15 lists two factors which are pertinent to this
determination. ERA'S analyses of each factor is presented below.
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(i) Degree of treatment useful and feasible for the waste to be
dumped, and whether or not the waste material will be treated
to this degree before dumping.
EPA has determined that incineration of the mixed liquid organic
wastes under the terms of this permit constitutes a very effective
means of treating those wastes. As is explained elsewhere in this
document, incineration at-sea will result, at a minimum, in the
destruction of 99.99 percent of each of the organic constituents
contained in the waste. Thus, the amount "dumped" in the sense of
actually being released to the environment will consist of only a very
small fraction of the wastes. The by-products of the incineration
process consist of hydrochloric acid, carbon dioxide, carbon monoxide,
water vapor and trace amounts of metal oxides, silicate ash, and may
additionally consist of trace quantities of surviving organic compounds
and partially combusted organic compounds. Surviving waste
constituents (metallic oxides or organic by-products of incomplete
combustion) comprise no more than 0.1 percent of the emissions.
Although not completely destroyed, the incineration process degrades
surviving organic compounds by lowering their molecular weight and
their chlorine content. As a result, these products of incomplete
combustion are less toxic than the original compounds. As discussed
earlier, all the emissions, including products of incomplete
combustion, will be below the limiting permissible level, which ensures
that the marine water quality criteria or, the marine aquatic life no
effect level are not exceeded and therefore are rapidly rendered
harmless as required in Section 227.6(h).
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The permit does not require treatment of the wastes before being
loaded onto the vessels for incineration because EPA is unaware of any
treatment method for the wastes which would be useful, in terms of
further reducing the potential impact of the emissions from ocean
incineration. Therefore, EPA concludes that the wastes will be treated
to an appropriate degree prior to their release to the environment.
(ii) "Raw materials and manufacturing or other processes resulting
in the waste, and whether or not these materials are
essential to the provision of the applicant's goods and
services, or if other less polluting materials or processes
could be used."
In evaluating this factor, EPA is asked to consider changes in raw
materials, manufacturing, or other processes which, if used, would
reduce the amount of wastes generated and the need for ocean dumping.
By its nature, this factor applies only to actions which could be taken
before the wastes are generated; it cannot apply to wastes which have
already been generated. Waste reduction is thus inapplicable to wastes
which are stored and awaiting incineration under these permits
(approximately one million gallons), but could be applied to the wastes
yet to be generated which, over the term of the permit, might be
incinerated (approximately, an additional 78 million gallons).
It is difficult to address waste reduction alternatives with much
specificity because of the large number of different processes used in
generating the wastes covered under this permit. As the Office of
57
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Technology Assessment* points out, there are several ways to reduce the
amount of waste generated:
0 source segregation or separation
0 process modification
0 end-product substitution
0 material recovery and recycling
Mo one method provides the ultimate means of reducing the volume
of wastes. Often these approaches are used simultaneously or
sequentially.
Source segregation is the simplest and probably the least costly
method of reducing waste volume. This approach avoids the
contamination of large volumes of nonhazardous waste by segregating
hazardous from non-hazardous constituents and forming a concentrated
hazardous waste. Implementation of this method can be accomplished
in a short-to-medium time period by individual generators.
Process modifications are, in general, made on a continuous basis
in existing plants to increase production efficiencies, to make product
improvements, and to reduce manufacturing costs. These modifications
include relatively small changes in operational methods, such as a
change in temperature, pressure, or raw material composition, as well
*0ffice of Technology Assessment. Technologies and Management
Strategies for Hazardous Waste ConfrcTrWashington, D.C., GPO, March
19R3
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as major changes such as the use of new processes or equipment.
Although a manufacturing process often may be used in several plants,
each facility has slightly different operating conditions and designs.
Thus, a modification resulting in hazardous waste reduction in one
plant may not be applicable industrywide. Proprietary concerns have
inhibited the transfer of information on process changes and the use of
process modifications to reduce hazardous wastes.
End-product substitution is the replacement of hazardous waste-
intensive products, that is, industrial products the manufacture of
which involves significant hazardous waste, by a new product the
manufacture of which would eliminate or reduce the generation of
hazardous waste. This is a long-term effort. As the Office of
Technology Assessment points out, the general problems with this method
are:
0 Not all of the available substitutes avoid the production of
hazardous waste.
0 Substitution may not be possible in all situations.
A change in consumer behavior may motivate product changes, but if
the only benefit is the reduction of potential adverse effects on human
health or the environment other incentives may be needed to accomplish
end-product substitution, such as tax incentives, regulations,
limitation of raw materials, etc.
Recovery and recycling are often used together but technically
they are different. Recovery involves the separation of a substance
from a mixture. Recycling is the use of such a material recovered from
the mixture. Recovery and recycling are usually considered a waste
reduction method; however, in the Ocean Dumping Regulations, recycling
also must be examined as an alternative to incineration at-sea.
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Therefore, except for the summary in Table 1 below comparing the four
reduction methods, recovery and recycling is discussed in the analysis
of the alternatives to ocean dumping.
EPA believes that there is a high potential for the use of new
processes and technologies to substantially reduce the amount of
hazardous waste generated in this country. At present, however, the
Agency is unaware of any technological modifications which would
substantially reduce the amount of wastes generated over the period of
the permits. While waste reduction technologies need to be encouraged,
the timing of their implementation is a factor to be considered in
evaluating the need for ocean dumping under this permit. Even if there
were changes which were known and could be made in all the processes
involved in generating the wastes covered by the proposed permit, these
process changes, product substitutions, recovery operations, etc., take
time to implement. General adoption of the changes discussed may take
years. EPA generally is supposed to take action on a permit within 180
days of a completed application. Unless public comments on the
proposed permits demonstrate that there are generally available waste
reduction technologies applicable to the wastes that are to be
incinerated under this permit, EPA will not deny these permits solely
on the premise that in the future these technologies may be available.
However, as changes in technology and process design occur, EPA will
evaluate these alternatives for each new permit, or renewal, according
to the availability of the process and raw material alternatives known
at that time.
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Table 1 - A Comparison of the Four Reduction Methods
Advantages
Disadvantages
SOURCE SEGREGATION OF SEPARATION
1) Easy to Implement; usually low
Investment
2) Short-term solution
PROCESS MODIFICATION
1) Potentially reduce both hazard
and volume
2) Moderate-term solution
3) Potential savings In production
costs
END PRODUCT SUBSTITUTION
1) Potentially industrywide impact-
large volume, hazard reduction
3)
RECOVERY/RECYCLING
0 In-pi ant
1) Moderate-term solution
Potential savings in manufacturing
costs
Reduced liability compared to
commercial recovery or waste
exchange
0 Commercial recovery (offsite)
1) No capital investment required for
generator
2) Economy of scale for small waste
generators
0 Waste Exchange
1) Transportation costs only
1) Still have some waste to
manage
1) Requires R&D effort; capital
1nvestment
2) Usually does not have
industrywide impact
1) Relatively long-term
soluti ons
2) Many sectors affected
3) Usually a side benefit of
product improvement
4) May require change in
consumer habits
5) Major investments required
need growing market
1) May require capital
1nvestment
2) May not have wide impact
1) Liability not transferred to
operator
2) If privately owned, must
make profit and return
investment
3) Requires permitting
4) Some history of poor
management
5) Must establish long-term
sources of waste and markets
6) Requires uniformity in
composition
1) Liability not transferred
2) Requires uniformity in
composition of waste
3) Requires long-term relation-
ships-two-party involvement
SOURCE: Office of Technology Assessment.
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The second determination to be made is:
(2) There are no practicable alternative locations and methods of
disposal or recycling available, including without limitation, storage
until treatment facilities are completed, which have less adverse
environmental impact or potential risk to other parts of the
environment than ocean dumping.
Section 227.15 lists two factors which must be examined in making
the above determination. The factors are:
(i) The relative environmental risks, impact and cost for ocean
dumping as opposed to other feasible alternatives including
but not limited to:
(A) Land-fill;
(B) Well injection:
(C) Incineration;
(D) Spread of material over open ground;
(E) Recycling of material for reuse;
(F) Additional biological, chemical, or physical treatment of
intermediate or final waste streams;
(G) Storage
(ii) Irreversible or irretrievable consequences of the use of
alternatives to ocean dumping.
Before discussing each of these factors, a relevant question to
ask is how much hazardous waste must be disposed of? Uncertainty
pervades as to how much hazardous waste is generated in the United
States each year. Estimates range from 41 to 275 million metric tons
depending on the definition of hazardous wastes used. Recently, EPA
has estimated that 150 million metric tons of wastes regulated by the
Agency were generated in 1981.
Many States define hazardous wastes more broadly than EPA. High
BTU wastes burned in commercial and industrial boilers and wastes from
small generators (less than 1 ton per month) are exempted from EPA's
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estimates. The Association of State and Territorial Solid Waste
Management Officials recently surveyed the States for the study by the
Office of Technology Assessment referenced earlier. That survey
indicated that, based upon the State's definitions, 255 to 275 million
tons of hazardous waste are generated annually.
There is, in fact, no "one" method of disposal which is effective
for all hazardous wastes generated in the United States. EPA's
analysis of each of the factors is in terms of liquid hazardous wastes
similar to those which would be destroyed under incineration at-sea
permits.
m The relative environmental risks, impact and cost for ocean
dumping as opposed to other feasible alternatives including,
but not limited to:
(A) Land fill
Nationwide, EPA has estimated that almost 95 percent of the
hazardous wastes generated are managed at the site where they are
produced. Of the wastes disposed of by industry, as much as 95 percent
of the hazardous wastes are disposed of on land. In the Gulf Coast
Region, which has approximately 21 percent of the nation's hazardous
waste generators, use of land disposal varies among the States as it
does nationwide. In Louisiana, 97 percent of the wastes are managed
onsite. Of the three percent disposed of offsite, 50 percent of these
wastes are disposed of on land. In Texas, 95 percent of all hazardous
wastes generated are disposed of on land.*
* ibid Office of Technology Assessment p. 8
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Virtually any waste can be physically buried in a landfill.
However, as the Office of Technology Assessment pointed out, landfills
are not effective in controlling the migration of liquid wastes. Land-
filled wastes that are toxic, persistent, soluble, and volatile present
significant risk to human exposure.*
The scientific community, the public, Congress and several States
are beginning to doubt the long-term safety and reliability of even the
most advanced landfills for the type of liquid hazardous waste that the
Applicants seek to incinerate. Congress is considering legislation to
ban the disposal of highly toxic wastes on land (see Senate bill, S.
757 and House bill, H.R. 2867). In addition, as Table 2 summarizes,
several States are active in banning or restricting land disposal of
hazardous wastes.
Table 2 - Summary of State Activities on Restricting Land
Disposal of Hazardous Wastes
Report Regulatory Regulatory Regulatory
Legislative Required Action Action Action
State Action by Legislature Draft Proposed Final
Arkansas
California
Illinois
Louisiana
Maryland
Massachusetts
Minnesota
Missouri
New York
Ohio
Pennsylvania
Rhode Island
Wisconsin
X X
X
X (proposed)
X
X X
X
X X
X
X
X
X
X X
X
X
X
Source: Office of Solid Waste, U.S. EPA
* ibid Office of Technology Assessment p. 175
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An extensive study is currently being undertaken hy EPA's Office
of Solid Waste to define the hazards of various types of wastes,
identify the wastes found to be inappropriate for land disposal,
identify alternative disposal technologies, and assess the respective
capacities and environmental acceptability of such technologies.
In EPA's judgment, the environmental risks associated with the
incineration at-sea of liquid organic compounds are significantly less
than those associated with landfill ing of liquid organic compounds.
(B) Well injection
Injection of liquid waste into subsurface formations is a
technology that uses porous sedimentary strata to hold liquid waste.
Essentially, underground injection entails drilling a well to the depth
required to intersect an appropriate geologic formation (known as the
injection zone) and pumping the liquid waste in with pressure
sufficient to displace the native fluids, but not so greater as to
cause fracturing of the strata and waste migration.
Wells are categorized into five classes (47 FR 4992). Federally
defined hazardous liquid waste can be disposed of in Class I or Class
IV wells. Class I wells are those wells used for the disposal of
municipal and industrial waste liquid which is injected below the
deepest underground source of drinking water. Class IV wells are those
wells used to inject hazardous liquids into or above a formation that
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is within one-quarter mile of a drinking water source. The exact
number of these wells is not known. Some Class IV wells are already
banned and the Agency has proposed a possible ban on the remainder.
The majority of Class I wells are comparatively deep, that is 60fl
to 1800 meters (2,000 to 6,000 ft). Disposal at these depths is
unlikely to contaminate surface or near-surface water. Technologies
for constructing and operating wells for disposal are well established.
In general, waste disposal through properly constructed and operated
injection wells into deep formations below the lowest drinking water
source is much less likely to contaminate surface or shallow aquifers
than is waste disposal through landfills. In EPA's judgment the risks
associated with incineration-at-sea are no greater than those
associated with deepwell injection.
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(C) Land-based Incineration
Land-based incineration is permitted under the Solid Waste
Disposal Act, as amended by the Resource Conservation and Recovery Act
(RCRA) and the regulations found in 40 CFR 264.340-264.351 or in the
case of polychlorinated biphenyls (PCBs), the Toxic Substances Control
Act (TSCA) and the regulations found in 40 CR 761.70. Table 3
"Hazardous Waste Incineration: Comparison of At-Sea And Land-Based
Requirements," on page 88, compares the major provisions of each of the
programs.
As shown in the Table and discussed elsewhere in the FINDINGS, the
environmental effects of incinerating at-sea will be no greater than
those of incinerating on land. This finding is based on the
determination that if at-sea and land-based incinerators each attain a
99.9 percent combustion efficiency and attain a 99.99 percent
destruction efficiency or destruction removal efficiency, and adhere to
the stipulated operating parameters, at-sea and land-based incinerators
are equally effective. In addition, both at-sea and land-based
incinerators meet applicable water quality and air pollution
standards.
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The differences in land-based and at-sea incineration are most
apparent in the type of risks involved. Both land-based and at-sea
incineration permits require that contingency plans and safety
procedures be implemented if there are spills, accidents or other
potentially hazardous incidents. In case of catastrophic or periodic
malfunctions at land-based facilities, the potential for acute adverse
human health and environmental effects is greater due to the close
proximity of population centers and areas of environmental concern.
However, the ability to fully clean up small spills is greater at
land-based facilities.
The risks involved with at-sea incineration vessels are collisions
in a harbor or potentially life threatening incidents at-sea which
might require jettisoning the cargo. All practicable precautions have
been taken, including the design and safety features of a Type II
chemical carrier, the "Broadcast to Mariners" warning other ships of
the vessel's progress to and incineration at the Gulf site, the
preparation and provision for execution of a detailed emergency
response (Contingency) Plan, and the location of the Gulf Incineration
Site on the continental slope, away from population centers, shipping
fairways, and ecologically productive areas.
Because land-based and at-sea incinerators are subject to the same
performance standards and the risks involved in each process are
comparable, EPA finds that the overall environmental, human health and
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safety risks associated with at-sea Incineration are no greater than
those associated with land-based incineration.
(D) Spread of material over open ground
Spreading liquid hazardous wastes on open land is not a viable
alternative. If disposed of in this manner, the wastes could easily
contaminate water supplies or, through air transport of volitile
components, could directly affect human health.
(E) (Recovery and) Recycling of Material for Reuse
Recovery and recycling are not new industrial practices. In
certain instances they are an excellent way of reducing the volume of
hazardous waste. If extensive recovery i.e., the separation of a
substance from an effluent is not required prior to recycling a waste
constituent, in-plant operations are relatively easy. But as is shown
on Table 1. on page 61, capital investment is normally required to
implement recycling processes. In many industrial processes, recovery
and recycling it is not yet a viable alternative.* Complex component
separation techniques such as reverse osmosis are being investigated
for application to organic liquids. These are generally expensive
operations and have not been applied commercially. However,
* ibid. Office of lechnology Assessment p. 148
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distillation and evaporation, though energy intensive, are used
commercially on organic liquids.
Chlorinolysis, which uses a chemical transformation process on
chlorocarbon waste, is an emerging technology. However, the process is
capital intensive, requires a pure waste stream and, as the Office of
Technology Assessment* points out, is a limited option because there is
an insufficient U.S. market for carbon tetrachloride, the major
end-product of Chlorinolysis.
While stricter disposal regulations, or prohibitions of certain
disposal practices (i.e. landfill ing) for particular wastes, might
increase the attractiveness of both in-plant and commercial recovery/
recycling facilities, storing hazardous wastes longer than 90 days
requires a permit. This permit requirement may discourage recycling if
large quantities of a waste must accumulate (for economic reasons) from
different generators prior to recycling or recovery. A further
disincentive to commercial recovery and recycling is that until
recovery and recycling is complete, the generator cannot transfer his
liability for the waste to the recycling operator.
EPA believes that recovery and recycling is an environmentally
preferable option to incineration at-sea and other hazardous waste
disposal options. Over the period of the permits, however, EPA is
unaware of any generally applicable technological modifications which
*ibid. Office of Technology Assessment p. 214
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would substantially increase the applicability of this option to the
type of wastes to be incinerated.
(F) Additional biological, chemical, or physical treatment of
intermediate or final waste streams
As indicated above, EPA is unaware of any commercially available,
practicable treatment that could supplement incineration to make the
emissions more environmentally acceptable.
(G) Storage
Storage postpones and delays for future generations the
inevitable need to dispose of the wastes. Were storage the only
option, huge areas would be required. While storage of hazardous
wastes for over 90 days requires a RCRA permit and implementation of
safety measures, these requirements do not alleviate the potential for
leakage and adverse effects on human health and the environment. As a
result, EPA does not believe that storage is a viable alternative to
incineration at-sea.
(ii) Irreversible or Irretrievable Consequences of the Use of
Alternatives to Ocean Dumping
Section 227.15(d) asks EPA to evaluate the irreversible or
irretrievable consequences of using the alternatives just described in
(i)(A)-(G). The irreversible consequence of land-based incineration is
71
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similar to that of ocean incineration. Only trace amounts of
uncombusted materials are discharged to the environment.
Landfills require, as a practical matter, the restriction of land
areas from other uses for an indefinite period, as many of these wastes
are likely to remain hazardous for a long time. Landfills also pose
the potential threat of contaminating surface or ground waters at some
future time. While cleanup of contaminated ground water is technically
possible, as a practical matter the cleanup is very difficult and in
some cases is prohibitively expensive. The advantage of incineration
is that the wastes for all practical purposes are destroyed
completely.
There are risks associated with the land-based and at-sea
incineration alternatives. EPA does not believe that at-sea
incineration has any greater irreversible or irretrievable consequences
than the other alternatives. Therefore, based on the forgoing analysis
of the factors to be considered in determining the need for ocean
dumping, EPA finds that:
(1) There are no practicable improvements which can be made in
process technology or in overall waste treatment to reduce
the adverse impacts of the waste released to the environment
from the incineration at-sea emissions.
(2) There are no practicable alternative locations and methods of
disposal or recycling available which have less adverse
environmental impact or potential risk to other parts of the
environment than incineration at-sea.
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(d) Subpart D - the Impact of the Emissions on Esthetic, Recreational
and Economic Values; Subpart E - the Impact of the Proposed Ocean
Dumping on Other Uses of the Ocean~
In order to evaluate the impact of incineration at-sea on
esthetic, recreational and economic values, and on other uses of the
ocean included in Subparts D and E of Part 227, EPA reviewed the basis
for designating the Gulf Incineration Site, the area where the
incineration activities will be carried out under these permits. By
their nature, Subparts D and E of Part 227 are dependent on the
characteristics of the site where the incineration is to take place as
well as on the effects of the incineration emissions on the site.
Therefore, this discussion begins by focusing on the criteria which
were considered in the designation of the Gulf Incineration Site.
(1) The Gulf Incineration Site
The Gulf Incineration Site was designated as an ocean disposal
site for high temperature incineration at-sea of mixed liquid organic
wastes on September 15, 1976 (41 R 39319). The Gulf Site was the
first site designated because the initial experimental incineration
at-sea permits were granted to waste generators from the Gulf Coast
region. The Site was redesignated on April 26, 1982 (47 FR 17817).
The Gulf Incineration Site lies 315 kilometers south, southeast of
Galveston, Texas, and 350 kilometers south, southwest of Cameron,
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Louisiana. It occupies approximately 4900 square kilometers in the
Gulf of Mexico.* The water depth at the site's center is approximately
1,375 meters (4,500 feet).
Sites for incineration at-sea are designated through a rulemaking
procedure. The criteria and procedures for designating sites are found
in 40 CFR Part 228. In evaluating potential sites, initial
consideration is given to those areas where:
0 there would be minimal interference with existing fisheries and
shell fisheries or regions with heavy commercial or recreational
navigation, and
0 temporary changes in water quality or other environmental
conditions during initial mixing are expected to be reduced to
normal ambient seawater levels or undetectable contaminant
concentration or effects before reaching beaches, shorelines, or
marine sanctuaries.
For those areas meeting the criteria in 40 CFR 228, a draft
Environmental Impact Statement (EIS) is prepared and made available for
public comment with the notice proposing the site. A final EIS is made
available at the time of final site designation.
Under research permits, air and water quality monitoring studies
were conducted to assess the impact on the marine environment of
incinerating organochlorine wastes at-sea. A designated Site is not
* The coordinates of the Gulf Incineration Site are:
Latitude. Longitude
26°20'00"N 93°20'00"W
26°20'00"N 94°00'00"W
27°00'00"N 93°20'00"W
27000'00"N 94°00'00"W
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required for a research permit (see 40 CFR 228(4)(b)). For a
discussion of these studies conducted at the Gulf Incineration Site,
see Environmental Studies at the Gulf Incineration Site at page 38.
The following summary briefly describes the reasons for EPA's
determination that the Gulf Incineration Site meets the criteria
outlined in 40 CFR 228.6. More detailed information may be found in;
U.S. EPA, Final Environmental Impact Statement. Designation of a
Site in the Gulf of Mexico for Incineration of Chemical Wastes.
Washington, D.C., July, 1976.
(i) Geographic position, depth of water, bottom topography, and
distance from the coast.
The site is positioned over the continental slope of the northern
Gulf of Mexico, some 300 kilometers from the nearest coast, where the
minimum depth of water is 1100 meters. This satisfies the requirement
of Section 228.5, that "EPA will, wherever feasible, designate ocean
dumping sites beyond the edge of the continental shelf." Furthermore,
the Site is located as near as possible to the industries that produce
substantial quantities of highly toxic organic wastes thereby reducing
transportation distance and the risks associated with long distance
transport of hazardous waste.
(ii) Location in relation to breeding, spawning, nursery, feeding,
or passage areas of living resources in adult or juvenile
phases.
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Available evidence indicates that the waters of the site contain
low levels of nutrients, few standing crops of phytoplankton, few
larvae of commercially important shnmp species, and few large nektonic
species.
(iii) Location in relation to beaches and other amenity areas.
Results of testing indicate no detectable concentrations of
pollutants reaching the beaches. The site is so far from shore that
only under the most unlikely of physical conditions would products of
the incineration process reach Gulf beaches and then only in such high
dilution as to be undetectable by even the most advanced chemical
analytical techniques.
(iv) Types and quantities of wastes proposed to be disposed of,
and proposed methods of release, including methods of
detecting the wastes after release.
The results of the research burns demonstrate that combustion
efficiencies of greater than 99.9 percent as required in these permits,
are achievable. This means that less than 0.1 percent of the waste
will be discharged to the environment. The principal products of
combustion are hydrochloric acid, carbon dioxide, water vapor, metallic
oxides, silicate ash and may, additionally contain trace quantities or
surviving or partially combusted organochlorines. It has been
demonstrated that no detectable deleterious effects on the marine
environment have occurred during the incineration of organochlorine
wastes.
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(v) Feasibility of surveillance and.monitoring.
The location of the site poses no special problems of monitoring
either from sea or from the air. The configuration of the site has
been established congruent with specific Loran* C lines in order to
facilitate navigation and surveillance.
The possibility of vessels being involved in an accidental
collision at the site is extremely remote. Poor visibility at the site
is rare. In addition, the permit allows only one vessel to operate at
the site at any one time. A U.S. Coast Guard "Broadcast to Mariners"
warns commercial and recreational vessels to not enter the site during
the incineration.
(vi) Dispersal, horizontal transport and vertical mixing
characteristics of the area, including prevailing current
direction and velocity.
Prevailing winds over the site are from the eastern quadrant and
are at a velocity such that total atmospheric dispersion of the plume
will take place before it reaches land, some 300 kilometers away. This
eliminates all but the remotest possibility of any remnants of the
incineration plume reaching land areas. Under all but the most unsual
wind conditions, the plume touches the sea surface within one to two
nautical miles downwind of the incinerator ship, distances well within
the site boundaries. In a 100 year period, it is estimated that 43
* The Loran System is a method of precisely determining a geographical
position on the ocean.
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tropical storms and 26 hurricanes are expected to occur within or very
near the incineration site. These storms are predictable far enough in
advance so that appropriate action may be taken to suspend or defer
ocean incineration operations and thus these metorological events will
have minimal effect on incineration at the site.
Current flow at the site prevails to the west or northwest. Water
movement in this direction assures additional mixing and travel time
before reaching shallow water since these waters enter a counter-
clockwise gyre west-northwest of the site.
The depth of the water at the site is more than sufficient to
provide adequate mixing for the minute concentrations of organic
chemicals possibly being added by the incineration process.
(vii) Existence and effects of current and previous discharges and
dumping in the area (including cumulative effects).
The flow and resultant short residence time of the waters at the
site precludes the possibility that previous incineration activities
could have produced measurable effects upon pelagic life while within
the site boundaries. In view of the great depth of water at the site
and the nature of the plume fallout, no effects on bottom life will
78
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occur within the site boundaries. Additionally, since no known dumping
has previously occurred at the site, the only effects would be from
incineration and these have been shown to be nonexistent or '
negligible.
Mii) Interference with shipping, fishing, recreation, mineral
extraction, desalination, fish and shellfish culture, areas
of special scientific importance and other legitimate uses
of the ocean.
The site is beyond shipping fairways (the site is at least 75
kilometers from the nearest shipping fairway) and the normal reach of
recreational vessels. It does not support viable shell fisheries or
finfisheries. It is also 90 kilometers or more from the 180 meter
bottom contour inshore of which numerous submarine banks of scientific
interest, such as the East and West Flow Garden banks, occur.
(ix) The existing water quality and ecology of the site as
determined by available data or by trend assessment or
baseline surveys, as described in the Guidelines for Ocean
Disposal Site Baseline and Trend Assessment Surveys.
Data obtained from earlier studies and from monitoring
observations which have been carried out reveal that the water quality
at the site is typical of normal ocean Gulf waters both chemically and
biologically.
(x) Potentiality for the development or recruitment of nuisance
species in the disposal site.
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It is unlikely that the growth of nuisance species of any type
would be encouraged by incineration at the site in view of the fact
that the plume products are sterile, non-nutntive and do not change
the water quality.
(xi) Existence at or near the site of any significant natural or
cultural features of historical importance.
There are no known natural or cultural features of historical
importance located within or near the boundaries of the site.
(2) Subpart D, Part 227 - Impact of the Proposed Dumping on Esthetic,
Recreational and Economic Values
This discussion considers, in accordance with the criteria listed
in Subpart D of Part 227, the impact of incineration at-sea activities
conducted at the Gulf Incineration Site on esthetic, recreational and
economic values according to the criteria listed in Subpart D of Part
227. The findings are based on: (1) EPA's knowledge of the
incineration site, acquired through the site designation process and by
conducting biological and chemical studies at the site during the
research permit burns; and (2) EPA's accumulated data and knowledge
from monitoring incineration at-sea activities and sampling the stack
emissions similar to those that will be discharged as a result of the
proposed permit activities.
The factors to be considered and EPA's findings follow.
H) Nature and extent of present and potential recreational and
commercial use of the site affected by the proposed dumping;
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The Gulf Site was selected in part because one, it is far from
normal commercial shipping fairways, two, it is beyond the reach of
most recreational vessels, three, it is low in marine resources of
recreational or commercial value, and four, it is sufficiently far from
shore to ensure that any trace contaminants from the emission plume
are in such minute amounts or are so diluted by the ocean that on-shore
or near shore activities would not be affected. Therefore, EPA finds
no adverse impact on commercial or recreational activities from
incineration at-sea activities.
(ii) Existing water quality, and nature and extent of disposal
1 activities, in the areas which might be affected by the
proposed dumping; and
(iii)Applicable water quality standards.
The monitoring data indicate that the water quality at the site is
typical of normal oceanic Gulf water. Since the site is more than
three miles from the shore, there are no applicable State water quality
standards for the site.
As discussed earlier, EPA has found no impact on the quality of
the water or on the biota from the emissions due to incineration at-sea
activities. However, until EPA can verify through a long term
monitoring program that there are no long term impacts from extended
incineration at-sea activities, EPA is limiting the use of the Site to
one vessel at a time. This will ensure adequate time for mixing and
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dilution of any emission products and will allow time for the Site to
recover from any potential impacts without overloading and hindering
its capability for recovery in future burns. Therefore, EPA does not
believe there will be any adverse water quality or biological impacts
from incineration at-sea activities.
(iv) Visible characteristics of the materials (e.g. color,
suspended particulates) which result in an unacceptable
esthetic nuisance in recreational areas.
The contents of the emission plume pose no problem for
recreational areas. The hydrochloric acid in the gaseous emissions is
neutralized and buffered by the ocean waters within a few miles of the
vessel.
The plume itself is not likely to be visible from any recreational
areas because the site is so distant from the shore. In fact, the
permits require the addition of ammonia to the plume, when needed, to
ensure its visibility in order that any ships which wander off course
or which have not heard the "Broadcast to Mariners" will be aware of
and avoid the incineration operations. EPA is convinced that the plume
and its contents will have no impact on recreational areas.
(v) Presence in the material of pathogenic organisms which may
cause a public health hazard either directly on through
contamination of fisheries or shellfisheries.
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This factor is not appropriate for incineration at-sea permits
because the emission by-products are sterile.
M) Presence in the material of toxic chemical constituents
released in volumes which may affect humans directly.
(vii) Presence in the material of chemical constituents which may
( be persistent or bioaccumulate and which may have an adverse
effect on humans directly or through food chain interactions;
(viii) Presence in the material of any constituents which might
significantly affect living marine organisms of recreational
or commercial value.
EPA has shown through modelling studies that if TCDD is destroyed
to 99.93 efficiency and if PCBs are destroyed to 99.99 percent
efficiency, any remaining TCDD or PCBs in the emissions would result in
ambient marine concentrations of .TCDD or PCBs below the marine aquatic
life no-effect level' for TCDD and the marine water quality criterion
for PCBs, respectively (the limiting permissible concentrations defined
in 40 CFR 227.27). In addition, the permits preclude the Incineration
of wastes with compounds that have a heat of combustion less than that
of compounds successfully incinerated in the trial burn. And finally,
the concentration of metals in the waste is limited so that the
metallic oxides released to the environment will not exceed marine
water quality criteria (the limiting permissible concentrations as
defined in 40 CFR 227.27). Therefore, EPA concludes that the emissions
will contain no products that could present a risk to human health
directly or through contamination of fisheries or shell fisheries.
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Based on the nature of the site an.d the contents of the emissions,
EPA finds that incineration at-sea, when,conducted in accordance with
the proposed permits, will not have an unacceptable impact on esthetic,
recreational or economic values of the ocean according to the factors
outlined in Subpart D.
(3) Subpart E, Part 227 - Impact of the Proposed Dumping on Other Uses
of the Ocean
EPA considered the impact of the proposed incineration at-sea
permits on the uses set forth in Section 227.21. Consistent with
Section 227.20, EPA considered the potential effects of the ocean
Incineration activities on the specific uses listed. Based on our
knowledge of the site and the by-products of the incineration process,
EPA's determination is that incineration-at sea will not have an
unacceptable impact, as shown by the following analysis:
(i) Commercial fishing in open ocean areas, coastal areas and in
estuarine areas.
The Gulf Incineration Site is located over the continental slope,
300 kilometers from the nearest coast. The minimum depth at the site
is 1100 meters. Available evidence indicates that, consistent with its
location, the water at the site has a low level of biological activity
and would not and could not support a viable commercial fishery. The
site is approximately 4900 square kilometers. It is large enough so
that the plume containing the emission products will touch down well
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within In the site, usually within a few miles of the Vessel. Upon
initial mixing after touch down, these incineration by-products are
rapidly rendered harmless or are below levels which would exceed marine
water quality criteria. Any by-products reaching the shore would be so
diluted as to be undetectable by the most sophisticated analytical
techniques.
(ii) Recreational fishing in open ocean areas, in coastal areas
and in estuarine areas:
The site is beyond the reach of most recreational vessels and, as
indicated above, it is highly unlikely that the emission products would
be detectable outside the site area.
(iii)Recreational Use of Shorelines and Beaches;
The environmental monitoring conducted as part of the 1982 trial
burn discussed earlier, indicated that there would not be any
detectable effect of incineration at-sea activities on recreational or
other uses of the shorelines and beaches.
(iv) Commercial and recreational navigation;
The site is 75 kilometers from the nearest commercial shipping
fairway and beyond the reach of most recreational vessels. During
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Incineration operations, the U.S. Coast Guard issues a "Broadcast to
Mariners", warning vessels to stay away from the incineration site.
i ••
(v) Actual or anticipated exploitation of living marine resources;
,>
The site is over the continental slope and has a low level of
living marine resources. Existing or future exploitation of living
marine resources would not be affected.
(vi) Actual or anticipated exploitation of non-living resources,
including without limitation, sand and gravel and other
mineral deposits, oil and gas exploration and development and
offshore marine terminal or other structure development;
The site is beyond the area where incineration activities would
interfere with any sand and gravel operations or offshore marine
terminal or other structural development. Available evidence indicates
that oil, gas and other mineral deposits, exploration and development
are unlikely in or near the site.
(vii) Scientific Research and Study
There are no known natural or cultural features within or near the
site that would draw scientific research or study other than the
monitoring of the effect of incineration activities.
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(e) Finding
EPA finds that the proposed permits meet all the requirements of
the Ocean Dumping Regulations applicable to incineration at-sea and
Section 102 of the Act.
As part of the tentative determination to issue the permits, EPA
compared the provisions of the proposed permits to the requirements of
the London Dumping Convention, TSCA regulations for the incineration of
PCBs and RCRA regulations for land-based incinerator facilities. These
analyses follow. Table 3 "Hazardous Waste Incineration: Comparison of
At-Sea, and Land-based Requirements", below, summarizes the major
provisions of the proposed special permits, the London Dumping
Convention and TSCA and RCRA requirements.
R7
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TABLE 3
HAZARDOUS WASTE INCINERATION
COMPARISON OF AT-SEA AND LAND-BASED REQUIREMENTS
A. Performance
Standards
1) DE/DRE
CWM SPECIAL PERMITS
LDC
RCRA
TSCA (PCBs)
DE: 99.991
DE 99.9%
ORE 99.991
ORE (non-liquid) 99.999«
(liquids). See note 1.
?) CE
99.91
99.91
99.91
3) Other
Standards
HC1 rapidly rendered harmless.
HC1 rapidly rendered
harmless.
HC1 emissions: If > 4 lbs/hr.,
control to no greater than
larger of 4 lbs/hr. or IS of
HC1 In stack gas pre-pollution
control equipment.
Water scrubbers to control
HC1 emissions to RA's
specifications
Metals limited to trace
amounts (100 ppm, except
silver, 20 ppm. and mercury, 9
ppm) so that they will not
exceed marine water quality
standards.
Metals limited to
trace amounts.
Par-titillate emissions. < .08
gralns/dscf when corrected
for amount of oxygen In stack
gas.
CO
CO
B. Incinerator
Certification/Test
Burn
An Initial trial burn is
performed to certify
attainment of performance
standards for POHCs and
compliance with operating and
monitoring requirements.
Additional trial burns may be
necessary for burning a new
POHC with a lower heat of
combustion. Trial burn needed
to Include in a waste mixture
DDT (and ODD. DDE) PCT. and
BHC. Incinerator must be
recertified every two years.
Incinerator "survey" Is
initially required to certify
attainment of performance
standards, compliance with
operating and monitoring
requirements. Trial burns
necessary for PCBs, DDT (and
Dim, DDE), PCT, BHC and TCDD.
Incinerator must be recertified
every two years. No significant
changes without approval.
An Initial trial bum or data
submitted In lieu thereof is
required to certify attainment
of performance standards for
POHCs of each specific waste
feed and compliance with
operating and monitoring
requirements. Additional trial
burns and permit modifications
may be necessary for burning new
waste feeds, or after facility
modifications.
RA determines necessity of
Initial trial burn to certify
attainment of performance
standards. An additional
trial burn may be required
after any pertinent facility
modifications.
C. Operating Conditions
1) Temperature
Wall.
2) Dwell time
Vulcanus
I
mnm. prior
to waste
feed 1353-C
mnm. 1280*C
avg. 1303°C
Vulcanus
II
Wastes w/
PCBs, TCDD
135J-C
1280°C
1303°C
Jastes w/o
>CBs, TCDD
1250°C
1166°C
1200°C
Flame- >_ 1250"C unless CE and Minimum specified on case by
DE achieved at low- temperature case-basis. See note 3.
Wall: > 1200-C unless as Measuring location should be
above.7 See Note 2. specified.
On the order of 1.0 seconds. "0" the order of" 1.0 seconds.*
Established Indirectly through
combust!oi' qas velocity,
temperati re requirements and
specification of allowable waste
feed locations. If variable.
Liquids > 1200°C or 16PO°C
(+ 100°C)7 depending on dwell
time.
Liquids- 2.seconds fl 1ZOO°C
or 1.5 seconds 0 16%°C.
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CUM SPECIAL PERHI1S
IDC
RCRA
TSCA (PCBs)
3) O fn stack gas
4) CO In stack gas
Vulcanus
I
avg.
51
10. IS
Vulcanus
I
max.
avg.
100 ppm
8 ppm
Vulcanus
II
Minimum 3JS*
tastes w/
'CBs.TCDO
5t
10. IX
tastes w/o
>CBs.TCDD
5X
10.6%
Vulcanus
II
lastes w/
'CBs.TCDD
100 ppm
8 ppm
lastes w/o
'CBs.TCDD
100 ppm
22 ppm
Liquids 3X 8 1200°C or 2 %
1600"C.
Maximum specified on case by case basis.
5) Waste feed rate
6) Combustion gas
Velocity
7) Flame/Plume
Conditions
No black smoke or flame
extension above stack plane;
no plume Impingement,
ammonia-adding device to
make plume visible.
No black smoke or flame
extension above stack plane.
Maximum specifted on a case by case
basts; effectively controlled by
' stipulation of maximum total thermal
Input rate. Turndown allowable if
other operating conditions complied
with. Mass or volume feed rates may
also be Imposed. Waste feed
locations are to be specified.
Maximum specified on case by case '
basis.
8) Other Operating
Conditions
Combustion chamber draft (nega-
tive pressure) maintained greater
than 1 inch of water below atmos-
pheric pressure.
Prompt reply to all radio
calls, broadcast regular radio
warnings, during incineration,
operating controls and
monitoring devices to be
supervised during Incineration.
Waste-contaminated water to be
ocean Incinerated or land
disposed, residues shall be
land disposed.
Reply to all radio calls.
broadcast regular radio
warnings*, during incin-
eration.
Waste-contaminated tank
washings, pump room bilges
incinerated P sea or land
disposed, incinerator residue
disposal shall conform to LDC
provisions.*
No hazardous waste to be fed during
start-up or shut-down unless Inciner-
ator within specified conditions.
Combustion zone fugitive emissions
controlled by 1) totally sealed
combustion zone 2} combustion zone
pressure < atmospheric pressure, or 3)
alternate means providing control equal
to 2), above.
Scrubber effluent shall comply
with applicable standards.
0.
Automatic waste
feed cut-off
linked to minimum wall
temperature, flame-out.
minimum Oi» maximum CO. and
failure of monitoring devices
for temperature-, air flow-,
draft (negative pressure),
02. CO. C02. and waste
and auxiliary fuel flow.
Linked to wall tempciature
and flame-out.*
Linked to operating parameters for: CO Triggered by 1) Insufficient temp-
in stack gas, waste feed rate. crature. ?) failure of monitoring
combustion temperature, combustion gas devices for, 0;. CO, C0?, PCB rate and
velocity. Should be interlocked_to all quantity, 3) Insufficient excess
required continuous'monitoring devices, oxygen.
For each operating parameter, permit
spei.ities a range for operation and,
•somewhat beyond that." a level at
which cut-off system must be
activated.
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CWH SPECIAL PERMITS
LDC
RCRA
TSCA (PCBs)
E. Monitoring
Requirements
1) Temperature
(wall or flame)
2) Air flow
3) Draft (negative
pressure)
4) CO
5) C02
6) 02
7) Haste feed and
auxiliary fuel rate
8) Combustion Gas
Velocity
9) Other Monitoring
Requirements
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Vessel position, course
and speed, wind speed
and direction; Incin-
eration date, time, thereof.
•Continuous* Continuous
Required; frequency un-
specified.
Required; frequency un- Continuous
specified.
Required; frequency un-
specified.
•Routine* (by use of an
automatic oxygen analyzer).*
Continuous for liquid waste
and fuel, except vessels
existing pre-1/1/79.
Continuous
Continuous
Vessel position, course,
speed; meteorological
conditions (wind direction.
speed)*; air feed rate. If
variable*; waste Incinerated.*
and date, time thereof.
Continuous
HC1; participates.
Continuous
At RA-speclfled Intervals.
Continuous
Feed rate and quantity
measured at regular Intervals,
maximum of 15 minutes.
Scrubber effluent.
f. Instrument Calibration/
testing
Before each cruise and
according to manufacturer's
specifications, for devices
measuring CO, CO , 0 , wall
temperature, waste flow and
fuel (If used), air flow, and
draft (negative pressure).
Cut-off system tested before
each Incineration cruise.
Inspection schedule required. At
least dally visual Inspection of
Incinerator and associated
equipment.
At least weekly testing of cut-
off system.
G. Outsider Observation/
Supervision
Mandatory 24 hour per day
"shiprlders", who can terminate
a burn for cause. EPA can
board vessel, enter
Incineration- related premises,
and inspect required records,
monitoring devices and
Incineration and navigation
equipment.
R.A. can enter and Inspect
facility premises and required
records, can sample any sub-
stances and monitor operations.
H. Waste Analysis
Chemical analysis to be
submitted to'EPA before each
hum. f PA may request that a
duplicate sample be taken and
analyzed.
Waste analysis plan must be
developed, and followed -
frequently enough to verify
waste feed is within permit-
specified physical and chemical
composition limits.
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CHN SPECIAL PERMITS
LOG
ftCRA
TbU
1. Haste Limitations
J. Safety/Contingency
Plan
Haste containing detectable
quantities of organic compounds
with a heat of combustion < 1.79
kcals'/gm (VULCANUS I) or <0.24
kcals/gm (VULCANUS 11). Trial
burn required for PCT.
8HC and POT.
Dioxln Is limited to 2 ppm.
The PCS and chlorine
concentration of the waste is
limited to 35X and 70X.
respectively.
The concentration of arsenic,
cadmium, chromium, copper.
lead, nickel, selenium,
thallium, zinc 1s limited to 100
ppm.
Mercury concentration is limited
to 9 ppm, silver concentration
Is limited to 20 ppm.
Material containing hIghHevel
radioactivity, material produced
for radiological, chemical, or
biological warfare, or that Is
persistent and may float or
remain suspended in the ocean.
Is prohibited.
Application requirement.
Shall be followed during
emergencies. Activities
requiring its Implementation
must be reported to EPA.
Trial burn required for
PCBs. PCTs. TCDD, BHC, and
DDT.
HC1 emissions- if > 4 lbs/hr..
control to no greater than
larger of 4 lbs/hr. or IS of
HC1 In stack gas pre-pollutlon
control equipment.
Partlculate emissions- <.08
grains/dscf when correcTed
for amount of oxygen in stack
gas.
Application requirement. Hust
be implemented during emergency.
Report to R.A. required when-
ever Implemented.
Notes
1. If applicable operating conditions are met, It Is believed that a ORE of
99.99991 will be attained.
2. LDC Technical Guidelines state that temperature controls and records are based
upon wall measurements.
3 As RCRA permits are performance-based, there are no generic operating
conditions. Each facility's operating conditions are determined by the
conditions necessary for achievement of the performance standard, as
demonstrated during the trial burn.
•Indicates provisions of the LDC Technical Guidelines. Contracting Parties
to the LDC are to "take full account of" the Technical Guidelines.
Abbreviations
avg Average
BHC Benzene hexachlonde
CE Combustion efficiency
CO Carbon monlxtde
CO* Carbon dioxide
ODD Dlchlorodiphenyl dichloroethane
DDE Dlchlorodlphenyl dichloroethane
DDT Oichlorodiphenyl trlchloroethane
OE Destruction efficiency
ORE Destruction and removal efficiency
dscf dry standard cubic feet
gm gram
HCI Hydrochloric acid
hr hour
max maximum
min minute
mnn
0« Oxygen
PCT Polychlorinated trlphenyls
POHC Principal organic hazardous
constituent
ppm parts per million
sec second
TCDD Telrachlorodibenzo-p-dloxln
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3. COMPLIANCE WITH THE LONDON DUMPING CONVENTION
As a Contracting Party to the CONVENTION ON THE PREVENTION OF
MARINE POLLUTION BY DUMPING OF WASTES AMD OTHER MATTER (the London
Dumping Convention), EPA is bound by the "Regulations for the Control
of Incineration of Wastes and Other Matter at Sea", and is required "to
take full account of" the "Technical Guidelines" implementing the
Regulations. The Regulations and Technical Guidelines are in Annex 5
of the London Dumping Convention.
The following discussion shows that the proposed permits are
equivalent to and in many cases more stringent than the Regulations and
Technical Guidelines of the London Dumping Convention. The Regulations
are discussed first, followed by the Technical Guidelines.
(a) Regulations of the London Dumping Convention
(1) Regulation 2.2:
Contracting Parties shall first consider the practical
availability of alternative land-based methods of treatment, disposal
or elimination, or of treatment to render the wastes or other matter
less harmful, before issuing a permit for incineration at sea in
accordance with these Regulations. Incineration at sea shall in no way
be interpreted as discouraging progress towards environmentally better
solutions including the development of new techniques.
This requirement is satisfied by EPA's consideration of the need
for ocean dumping discussed in "Compliance With the Ocean Dumping
Regulations."
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(2)Regulat1on 3:
(1) The incineration system shall be subject to the surveys specified
below.... The Contracting Party which proposes to issue an
incineration permit shall ensure that the surveys have been completed
and the incineration system complies with the provisions of these
Regulations. If the initial survey is carried out under the direction
of a Contracting Party a special permit, which specifies the testing
requirements, shall be issued by the Party. The results of each survey
shall be recorded in a survey report.
(a) An initial survey shall be carried out in order to ensure
that during the incineration of waste and other matter
combustion and destruction efficiencies are in excess of 99.9
per cent.
(b) As a part of the initial survey the State under whose
direction the survey is being carried out shall:
(i) approve the siting, type and manner of use of
temperature measuring devices;
(ii) approve the gas sampling system including probe
locations, analytical devices, and the manner of
recording;
(iii)ensure that approved devices have been installed to
automatically shut off the feed of waste to the
incinerator if the temperature drops below approved
minimum temperatures;
(iv) ensure that there are no means of disposing of wastes or
other matter from the marine incineration facility
except by means of the incinerator during normal
operations;
(v) approve the devices by which feed rates of waste and
fuel are controlled and recorded;
(vi) confirm the performance of the incineration system by
testing under intensive stack monitoring, including the
measurements of Ooi CO, C02» halogenated organic
content, and total hydrocarbon content using wastes
typical of those expected to be incinerated.
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(c) The incineration system shall be surveyed at least every two
years to ensure that the incinerator continues to comply with
these Regulations. The scope of the biennial survey shall be
based upon an evaluation of operating data and maintenance of
records for the previous two years.
(2) Following the satisfactory completion of a survey, a form of
approval shall be issued by a Contracting Party if the incineration
system is found to be in compliance with these Regulations. A copy of
the survey report shall be attached to the form of approval. A form of
approval issued by a Contracting Party shall be recognized by other
Contracting Parties unless there are clear grounds for believing that
the incineration system is not in compliance with these Regulations. A
copy of each form of approval and survey report shall be submitted to
the Organization.
(3) After any survey has been completed, no significant changes which
could affect the performance of the incineration system shall be made
without approval of the Contracting Party which has issued the form of
approval.
In addition to the Certificate of Approval required by the above
Regulation, the U.S. Coast Guard inspects the incineration system to
ensure its safety, as required by P.L. 97-389, December 29, 1982.
Prior to issuing a special permit, EPA requires vessels to
demonstrate a destruction efficiency of at least 99.99 percent on a
principle organic hazardous constituent (POHC). This is more stringent
than the London Dumping Convention regulation. The M/T VULCANUS I, in
a trial burn conducted in August 1982, demonstrated a destruction
efficiency of greater than 99.99 percent on hexachlorobenzene which had
the lowest heat of combustion (1.79 kcal/gram) of the POHCs tested.
The M/T VULCANUS II, during its survey by the Government of the
Netherlands and EPA during January and February 1983, demonstrated a
94
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destruction efficiency of greater than 99.99 percent on
tetrachloromethane, which had the lowest heat of combustion (0.24
kcal/gram) of the POHCs tested.
(3) Regulation 4:
(1) Where a Contracting Party has doubts as to the thermal
destructability of the wastes and other matter proposed for
incineration, pilot scale tests should be undertaken.
EPA has limited the compounds eligible for incineration in a waste
mixture to those compounds with a heat of combustion greater than the
POHC for which a trial burn demonstrated a destruction efficiency of
99.99 percent. Therefore, EPA does not doubt the thermal
destructability of wastes that are to be incinerated under the proposed
special permits.
(11) Where a Contracting Party proposes to permit incineration of
wastes over which doubts as to the efficiency of combustion exist, the
Incineration system shall be subject to the same intensive stack
monnorfng as required for the initial incineration system survey. The
specific compounds referred to, in Technical Guideline 4.1.2, are. (i)
pSlycnlorinated biphenyls (PCBs); (ii) Pol^!^;!?te<
-------
VULCANUS II to incinerate TCDD and PCBs because of the determination
that the incinerator equipment on the M/T VULCANUS II is the same as
the equipment on the M/T VULCANUS I and the Agency's accumulated
experience in monitoring the incineration of TCDD and PCBs emissions.
The proposed Research Permit, HQ 83-003, would fulfill the
requirements of the London Dumping Convention to conduct a trial burn
on DDT and its associated compounds ODD and DDE prior to including
these compounds in a waste mixture, under a special permit. The trial
burn is to be conducted and if successful the Special Permit for the
M/T VULCANUS II will be modified to authorize the incineration of DDT,
DDD and DDE.
(4) Regulation 5:
The operation of the incineration system shall be controlled so as
to ensure that the incineration of wastes or other matter does not take
place at a flame temperature less than 1250 degrees centigrade, unless
the results of tests demonstrate that the required combustion and
destruction efficiency can be achieved at a lower temperature.
A flame temperature of 1250°C is equivalent to a wall temperature
of 1200°C. Wall temperature is used in the proposed permits.
The proposed permits require a minimum wall temperature of 1280°C
for the M/T VULCANUS I and 1166°C for the M/T VULCANUS II. In
addition, prior to initiating the waste into the incinerators, the
proposed permits require a wall temperature 50°C higher than the
96
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average temperature,which must be maintained during incineration.
These temperatures are 1353°C for the M/T VULCANUS I and 1250°C for the
*' ' t
M/T VULCANUS II. tf the M/T VULCANUS II is incinerating PCBs, then the
minimum wall temperature must be the same as those for the
, | I r
M/T VULCANUS I.
The specified minimum temperatures are based upon data collected
from actual trial burns on both vessels and from evaluations of a large
number of other incinerators. These values are used as an operating
guide. Waste feed is automatically stopped to an incinerator unit if
it drops below the specified minimum temperature or a flame out occurs.
i ' /
Auxiliary fuel must be substituted for waste feed to raise the
temperature to the level specified for waste feed initiation before
s r
wastes may be fed again into the incinerator.
The proposed special permits also stipulate average wall
temperatures that must be maintained during waste incineration. The
average temperatures are based on the average temperatures, attained 1n
the trial burns that demonstrated destruction efficiencies of 99.99
percent on the POHCs tested. The average wall temperature required 1s
1303°C for the M/T VULCANUS I and 1200°C for the M/T VULCANUS II.
Although the average attained during the February 1983, trial burn was
1166°C for the M/T VULCANUS II, EPA used the usual 1?00°C London
97
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Dumping Convention requirement as the average for the M/T VULCANUS II
since a minimum and average cannot be the same.
The Research Permit does not stipulate an average wall temperature
because the trial burn will establish the average which is to be
maintained during incineration.
(5) Regulation B.2:
The combustion efficiency shall be at least 99.95^ 0.05% based on:
«« ^ ~"
2_
C,
on " rn
Combustion efficiency = ™2 x 100
"CQZ
where Cro = concentration of carbon dioxide in the combustion gases
rn
LA/
ro =
Crn2= concentration of carbon monoxide in the combustion gases,
The proposed special and research permits have this identical
requirement expressed in a slightly different formula:
i
Combustion Efficiency = rCQp] x 100
[C02J + [COJ
Where:
C02 = concentration of carbon dioxide in the combustion gases
CO = concentration of carbon monoxide in the combustion gases
(6) Regulation 5.3:
There shall be no black smoke nor flame extension above the plane
of the stack.
The proposed permits include the same provision.
(7) Regulation 5.4:
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The vessel shall reply promptly to radio calls at all times during
the incineration. ,
A similar requirement is included in the proposed permits.
(8) Regulation 6:
(11) At a'minimum, the following data shall be recorded during each •
incineration operation and retained for inspection by the Contracting
Party who has issued the permit:
(a) continuous temperature measurements by approved temperature
measuring devices:
(h) date and time during incineration and record of waste being
.incinerated;
(c) vessel position by appropriate navigational means;
(d) feed rates of waste and fuel - for liquid wastes and fuel the
flow rate shall be continuously recorded; the latter
requirement does not apply to vessels operating on or before
January 1979;
(e) CO and COp concentration in combustion gases;
(f) vessel's course and speed.
The proposed permits also stipulate that monitoring devices record
these parameters. In addition to monitoring and recording wall
temperature, and the waste and fuel feed rates, the proposed permits
require continuous monitoring and recording of air flow to the
incinerators, the level of oxygen, carbon monoxide, and carbon dioxide
in the stack gases and draft (negative pressure) in the combustion
chamber. The permits require the continuous monitoring and recording
of the feed rates of waste and/or fuel (if used) on the M/T VULCANUS I,
even though the vessel was operating prior to January 1, 1979. This
requirement together with the requirement to continuously monitor and
record air flow were added not only to be consistent with EPA's
land-based permit programs, but also to ensure adequate data are
available to calculate dwell time, the time the liquid waste and its
gaseous combustion by-products are in the lower combustion chamber and
upper incinerator stack.
99
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Continuous monitoring of wall temperature, and the level of oxygen
and carbon monoxide in the stack gases are required because these are
the key parameters for determining the operating efficiency of tne
incinerators. In addition, continuous monitoring of the level of
carbon dioxide in the stack gases and the waste feed flow and/or
auxiliary fuel flow (If used) are required in order to calculate
combustion efficiency, dwell time and overall incinerator performance.
EPA is also requiring the continuous monitoring and recording of
draft (negative pressure) in the combustion chamber to ensure that
there is sufficient oxygen in the combustion gases from the blowers and
to prevent the escape of fugitive emissions from the incinerators and
thereby protect shipboard personnel.
(9) Regulation 7:
A permit application for the incineration of wastes or other
matter at-sea shall include information on the characteristics of
wastes or other matter sufficient to comply with the notification
requirements (which includes an analyses of the wastes and the
properties of the wastes).
The application for the special permits included a request to
incinerate approximately 300,000 metric tons of mixed liquid organic
wastes, EPA has limited the mixed chemical wastes eligible for
incineration (see Section-by-Section Analysis, Special Provision No.
2). In addition, prior to the loading of a vessel for each
incineration cruise, a chemical analysis of the wastes to be
incinerated on that cruise must be submitted to EPA.
The analyses of the wastes are to be conducted in accordance with
EPA-approved protocols, (listed in Appendix A of the Permits), in an
EPA-approved laboratory. Use of the protocols will ensure the
identification of all chemical compounds present in the wastes in
100
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quantifiable concentrations. EPA may take duplicate samples from the
blending/holding tanks or from the vessels' and/or the dockside storage
tanks to verify the analyses. Only when EPA is convinced that the
wastes meet the specifications of the permits will written
authorization for loading and incineration be provided.
Therefore, the proposed permits exceed the requirement of this
Regulation because the exact composition of each load of wastes will be
known prior to each incineration cruise.
(10) Regulation 8:
Provisions to be considered in establishing criteria governing the
selection of incineration sites shall include the following:
(A) the atmospheric dispersal characteristics of the area -
including wind speed and direction, atmospheric
stability, frequency of inversions and fog,
precipitation types and amounts, humidity - in order to
determine the potential impact on the surrounding
environment of pollutants released from the marine
incineration facility, giving particular attention to
the possibility of atmospheric transport of pollutants
to coastal areas;
(B) oceanic dispersal characteristics of the area in order
to evaluate the potential impact of plume interaction
with the water surface;
(C) availability of navigational aids.
The Environmental Impact Statement on the designation of the Gulf
Incineration Site, published in July 1976, covered the points indicated
in this London Dumping Convention Regulation. A description of the
site may be found under "Consistency with the Ocean Dumping
Regulation."
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(11) Regulation 9:
Contracting Parties shall comply with notification procedures
adopted by the Parties in consultation. These notification procedures
include a form which is to contain the following information for each
permit:
(1) issuing authorities;
(2) date issued;
(3) period for which the permit is valid;
(4) country of origin of wastes and port of loadings;
(5) total quantity of wastes (in metric units) covered by the
(6) forTin which the waste is presented (bulk or containers; in
the latter case, also size and labelling);
(7) composition of the waste, such as:
.1 principal organic components;
.2 organohalogens;
.3 main inorganic components;
.4 solids in suspension; and
.5 other relevant constituents.
(8) properties of the waste, such as:
.1 physical form:
.2 specific gravity;
.3 viscosity;
.4 calorific value;
.5 radioactivity; and
.6 toxicity and persistence, if necessary.
(9) industrial process giving rise to the waste;
(10) name of the marine incineration facility and state of
(11) areTof3incineration (geographical location; distance from
the nearest coast);
M?) expected frequencies of incineration;
13 special conditions relating to the operation of the marine
incineration facility which are more stringent than those
specified in the Regulations or other than those in the
Technical Guidelines; i-e*^ <«
(14) additional information, such as relevant factors listed in
Annex III to the Convention.
If the Assistant Administrator for Water makes a final determina-
tion to issue the permits, after taking into consideration public
comments received on the proposed permits and the findings in the
Notice, EPA will notify the International Maritime Organization
of the Permits, in accordance with this Regulation.
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(b) Technical Guidelines
(1) Technical Guideline 3.1.2:
Where solid wastes are burned, the waste type and rate of input
should be recorded in the log.
The design limits of the incinerator systems on the M/T VULCANUS I
and II preclude the incineration of solids. Therefore, this Guideline
is not applicable.
(2) Technical Guidance 3.1.3:
The feeding of wastes in containers to the incinerator will
necessitate special design and operational requirements in order to
comply with the Regulation.
For the same reason as stated immediately above, this Guideline is
not applicable.
(3) Technical Guideline 3.2.1:
The amount of air entering the incinerator should be sufficient to
ensure that a minimum of 3 per cent oxygen is present in the combustion
gases near the incinerator stack exit. This requirement should be
monitored by an automatic oxygen analyzer to routinely record oxygen
concentrations.
The proposed permits are more stringent than this London Dumping
Convention Guideline. Based on EPA's extensive data base on all types
of hazardous waste incinerators, oxygen levels in the range of
approximately 5 through 15 percent have been identified as a
consistently successful operating range for oxygen levels in the
combustion gases. Therefore, a minimum 5 percent oxygen level in the
stack gases is stipulated in the permits. Based on the trial burns,
103
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the average oxygen level in the combustion gases must be equal to or
greater than 10.1 percent for the M/T VULCANUS I and 10.6 percent for
the M/T VULCANUS II, except if incinerating TCDD or PCBs. If
incinerating TCDD or PCBs, the average oxygen level for the M/T
VULCANUS II must be equal to that of the M/T VULCANUS I.
(4) Technical Guideline 3.3.1:
Temperature controls and records should be based on the
measurement of wall temperature. Unless otherwise determined by the
Contracting Party there should be three or more temperature measurement
devices for each incinerator.
(B) Technical Guideline 3.3.2:
The Contracting Party should define the operating wall temperature
and the temperature below which the flow of waste to the incinerator
should be automatically shut off by approved equipment.
(6) Technical Guideline 3.3.3:
The minimum wall temperature should be 1200°C unless the results
of tests on the marine incineration facility demonstrate that the
required combustion and destruction efficiencies can be achieved at a
lower temperature.
The proposed permits are consistent with these temperature
guidelines because:
0 the permits are contingent on a survey of the incineration
system by a Contracting Party to the London Dumping Convention;
0 EPA has defined a minimum temperture of 1280°C for the M/T
VULCANUS I and 1166°C for the M/T VULCANUS II unless
incinerating TCDD or PCBs when the minimum temperature shall be
1280°C. If reached, these minimums trigger automatic devices
that shut off the flow of wastes to the incinerators;
0 the minimum wall temperature is 1200°C unless, as in the case of
the M/T VULCANUS II, the required destruction efficiency was
achieved at a lower temperature.
104
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0 EPA has defined a minimum temperature that must be attained
orior to feeding wastes to the incinerators. This temperature
is 1353°C for the M/T VULCANUS I and 1250°C for the M/T VULCANUS
II (1353°C when incinerating TCDD or PCBs).
(7) Technical Guideline 3.4.1:
Destruction efficiency should be determined not only for the total
organic components of the wastes but additionally for particular
substances such as PCBs, PCTs, TCDD, BHC, DDT in the survey and
approval of the incineration system.
The proposed special permits were developed in accordance with
this Technical Guideline. EPA has developed a system based on
comparing the heats of combustion of compounds in a waste mixture to
the heats of combustion of the principle organic hazardous constituents
(POHCs) used in the trial burn. As discussed previously in greater
detail, one or more POHCs in a waste mixture are selected, based on
their heat of combustion and on their concentration in the mixture.
During a trial burn, under a research permit or as part of an initial
survey of an incineration system, the POHCs selected are carefully
monitored to determine the destruction efficiencies for the
incinerator. If the incinerators demonstrate a destruction efficiency
of 99.99 percent or greater on each of the POHCs, then the waste
mixtures under a special permit may contain compounds with heats of
combustion equal to or greater than the POHC with the lowest heat of
combustion.
In order to incinerate any of the five compounds listed above, a
trial burn is performed. Various trial burns for the MA VULCANUS I
included waste mixtures containing TCDD, PCBs and hexachlorobenzene and
the trial burn for the M/T VULCANUS II included a waste mixture
105
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Containing tetrachloromethane. Therefore, the M/T VULCANUS I is
authorized to incinerate TCDD and PCBs as well as compounds that have a
heat of combustion equal to or greater than 1.79 kcal/gram, the heat of
combustion of hexachlorobenzene. Trial burns on TCDD and PCBs were
waived for the M/T VULCANUS II based on a determination that the
incinerators on the M/T VULCANUS II are similar to those of the M/T
VULCANUS I and on the Agency's accumulated experience in monitoring
incinerator emissions for TCDD and PCBs. Therefore the M/T VULCAHUS II
is authorized to incinerate TCDD, PCBs and compounds with heats of
combustion equal to or greater than 0.24 kcal/gram.
(8) Technical Guideline 3.5.1:
The mean residence time of the incinerator should be on the order
of one second or longer at a flame temperature of 1250°C (or a wall
temperature of 1200°C) during normal operating conditions. Technical
Guideline 3.5.1)
The proposed permits have an identical provision.
(9) Technical Guideline 3.6:
Devices to shut off the waste feed to the incinerator should
include the following:
(1) flame sensors with each burner to stop waste flow to that
burner in the event of a flame-out; and
(2) automatic equipment to stop waste flow in the event of wall
temperatures falling below 1200°C.
The proposed permits require that automatic devices shut off the
flow of the wastes to the incinerators not only if the flame goes out
or the temperature falls below a specified reading, but also if carbon
106
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monoxide or oxygen In the combustion gases exceeds or falls below the
specified levels, respectively, or the monitoring devices for wall
temperature, air flow, draft (negative pressure) in the combustion
chambers, carbon monoxide, oxygen, carbon dioxide and waste feed flow
or auxiliary fuel (if used) fail.
(10) Technical Guideline 3.7.1:
In approving the siting of temperature measuring devices and gas
sampling probes, the Contracting Party should take into account that 1n
certain cases flames can be non-homogeneous (e.g. through vortex
formation in the incinerator or during incineration of solid or
containerized wastes). (Technical Guideline 3.7.1)
During the 1977 Research Permit burn of Herbicide Orange, EPA
positioned the gas sampling probe at different locations in the cross
section of the stack and found from carbon monoxide, carbon dioxide and
oxygen readings that the combustion gas composition was homogeneous.
(11) Technical Guideline 4.1.1:
Hue to the risk of spillages wastes should not be transferred from
barges to the Vessel outside harbour limits except where special
arrangements have been made for the prevention of spillages to the
satisfaction of the Contracting Party.
Consistent with this Technical Guideline, the proposed permits
require that the loading of the vessels may take place only in the Port
of Mobile, Alabama.
(12) Technical Guideline 4.1.2:
Wastes in damaged containers should not be taken on board marine
incineration facilities.
(13) Technical Guidelines 4.1.3:
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Containers loaded on board should be adequately labelled.
(14) Technical Guideline 4.1.4:
Containerized wastes should be stowed in accordance with the
regulations of the IMCO International Maritime Dangerous Goods Code
(IMDG Code).
These provisions are not applicable to the proposed (permits
because containerized wastes are not authorized for incineration.
' \
(15) Technical Guideline 4.2.1:
Tank washings and pump-room bilges contaminated with wastes should
be incinerated at sea in accordance with the Regulations for the
Control of Incineration of Wastes and Other Matter at Sea and with
these Technical Guidelines, or discharged to port facilities.
(Technical Guideline 4.2.1)
The proposed permits require that if tanks are washed, they may
only be washed with combustible solvents and such washings must be
incinerated at-sea or, on return to port either incinerated in
EPA-approved land-based facilities or treated in accordance with 40 CFR
761.60 and TSCA Compliance Program Policy No. 6 PCB-2 — Physical
Separation Techniques (August 16, 1983).
(16) Technical Guideline 4.2.2:
Residues remaining in the incinerator should not be dumped at sea
except in accordance with the provisions of the Convention.
The proposed permits require that any residues remaining in the
incinerator must be incinerated in EPA-approved facilities.
(17) Technical Guideline 4.3.1:
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In licensing the incineration of wastes and other matter on board
approved maMne incineration facilities, the Contracting Par* should
have regard to the need to avoid hazards to other vessels by
aSoropriate location of the incineration sites or incineration zones
wScerned and by ensuring that the relevant maritime authorities are
™?if ed of thedate of sailing and/or intended schecu e as well as
the intended movements of the marine incineration facility (whether
underway, at anchor, etc.).
As discussed under "Consistency with the Ocean Dumping
Regulations", the Gulf Incineration Site is 75 miles from the nearest
commercial shipping fairway and beyond the reach of most recreational
vessels. In addition, the proposed permits require that 10 days before
the loading of the vessels is to begin, the Permittees notify the U.S.
Coast Guard and the Captain of the Port Mobile and, 24 hours before
sailing the Permittees notify the Captain of the Port, Mobile.
(18) Technical Guideline 4.3.2:
Regular radio warnings should be broadcast during the period of
incineration.
During transport to and incineration at the Gulf Incineration
Site, the U.S. Coast Guard issues "Broadcasts to Mariners" warning
ships away from the Site.
(19) Technical Guideline 4.3.3:
Contracting Parties in a given geographical area should endeavor
to designate common incineration sites in the area.
Mexico is a Contracting Party to the London Dumping Convention.
Although at this time Mexico has not indicated an interest in
incinerating at-sea mixed liquid organic wastes, it would be
appropriate for the United States and the Government of Mexico to work
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out a joint agreement on the use of the Gulf Incineration Site should
the Government of Mexico wish to initiate incineration at-sea
activities.
(20) Technical Guideline 4.4.1:
For the carriage of liquid wastes an incineration ship shall carry
a valid "Certificate of Fitness" as required under the IMO Code for the
Construction and Equipment of Ships Carrying Dangerous Chemicals in
Bulk.
As a condition of the permits, the vessels must have and
prominently display a valid "Certificate of Fitness."
(21) Technical Guideline 4.5.1:
Marine incineration facilities should record (in addition to the
ones previously mentioned under Regulations):
(i) the oxygen concentration in the combustion gases;
(ii) the air feed rate, if variable, the air feed used;
(iii)the tank(s) from which waste is taken; and
(iv) the meteorological conditions, e.g., wind speed and
direction.
As previously indicated, the permits require continuous monitoring
and recording of air flow to the incinerators and oxygen content in the
combustion gases. The oxygen content of the combustion gases is a
direct result and an indicator of sufficient air flow. In EPA's
judgment, monitoring the oxygen content of the combustion gases is more
important than the air feed flow. However, the continuous monitoring
of air flow is necessary to be able to calculate dwell time for wastes
entering the incinerators.
EPA requires a full accounting of all wastes before the wastes are
loaded onto the vessel. The samples for the analyses are taken from
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the Mending/holding tanks in Emelle, Alabama. If the wastes are
eligible for incineration based on the analyses from the
blending/holding tanks, there is no combination of blending in the
vessels' storage tanks that would make the wastes less acceptable for
incineration. Therefore, during the incineration, EPA has not required
the identification of the tank from which the wastes are being fed into
the incinerator.
EPA does require the monitoring of meteorological conditions
including wind speed and direction. Based on EPA's experience, a
combination of vessel speed plus wind velocity of three knots is
necessary to ensure the plume does not come in contact with the vessel.
(22) Technical Guideline 5.1.1:
Information on the characteristics of wastes or other matter to be
provided hould include, if possible, information on the chemica1nd
nhv^ical transformation of the waste after incineration, in particular,
^rsequent formation of new compounds, composition of ashes or unburned
residues.
At least 99.9 percent of the products of incineration are known.
They include hydrochloric acid, carbon dioxide, carbon monoxide, water
vapor and trace amounts of metallic oxides, silicate ash, and partially
combusted or surviving organic compounds. Partially combusted or
surviving organic compounds comprise no more than 0.1 percent of the
emissions. While these products cannot be characterized completely,
their impact on the environment is believed to be minimal based on the
following:
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0 The incineration process degrades the compounds by lowering the
molecular weight and chlorine content of the compounds. As a
result, these partially combusted or surviving organic compounds
are less toxic than the original compounds.
0 Environmental monitoring of incineration at-sea over the last
nine years has shown no adverse affects on the marine aquatic
ecosystem from any aspect of incineration at-sea operations.
(23) Technical Guideline 4.1.2:
Examples of wastes or other matter over which doubts exist as to
the thermal destruction and efficiency of combustion are listed as
follows:
0 Polychlorinated biphenyls (PCBs)
0 Polychlorinated triphenyls (PCTs)
0 Tectrachloro-dibenzo-p-dioxin (TCDD)
0 Dichlorodiphenyl trichloroethane (DDT)
0 Benzene hexachloride (BHC, lindane)
The requirements for trial burns and a demonstration of 99.99
destruction efficiency on these compounds were discussed above under
Regulation 4.
(24) Technical Guideline 5.2.1:
The Contracting Party must ensure that the incineration of a waste
containing Annex I substances (such as organohalogen compounds,
mercury, cadmium) should not result in the introduction of Annex I
substances into the marine environment unless these are rapidly
rendered harmless x>r are present as trace contaminants. Based on
current scientific knowledge on the environmental effects of
incinerating liquid organochlorine compounds, this requirement is
considered to be met if the Regulations and Technical Guidelines are
observed.
EPA's findings are that the Regulations and Technical Guidelines
have been observed and that incineration will not result in the
introduction of organohalogen compounds, mercury and mercury compounds
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and cadmium and cadmium compounds into the environment, except as trace
contaminants.
(25) Technical Guideline 5.2.2:
Where it is proposed to incinerate wastes at sea containing other
Annex I substances or organochlorine compounds such as PCBs, PCTs,
TCDD, BHC, DDT, it will be necessary to determine that the residues
entering the marine environment after incineration are rapidly rendered
harmless or present as trace contaminants through procedures adopted by
the Contracting Parties in consultation.
Based on EPA's accumulated data and experience in monitoring
incineration emissions for TCDD and PCBs and emission plume modelling
and subsequent ocean dispersion modelling, it has been demonstrated
that any emissions of the incineration process will be rapidly rendered
harmless or will be present as only trace contaminants, well below the
limiting permissible concentrations defined in 40 CFR 227.27 as the
marine water quality criterion or the marine aquatic life no effect
level for PCBs and TCDD, respectively.
(26) Technical Guideline 5.3.1:
Each Contracting Party should immediately notify the International
'Maritime Organization of a Special Permit issued for incineration of
wastes or other matter at sea.
If the Assistant Administrator for Water makes a final
determination to issue the permits, after taking into consideration
comments received on the proposed permits and the Notice, EPA will
notify the International Maritime Organization in accordance with the
procedures set out in the London Dumping Convention described under the
Regulation 9 discussed above.
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(c) Finding
Based on the above analysis, EPA finds that the proposed Special
and Research permits are consistent with the Regulations and Technical
t
Guidelines of the London Dumping Convention.
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4. COMPLIANCE WITH TSCA REGULATIONS WHEN INCINERATING LIQUID PCBs
Section 6(e)(l)(A) and (B) of the Toxic Substances Control Act*
(TSCA), requires the Administrator "to promulgate regulations to
prescribe methods for the disposal of polychlorinated biphenyls and
require polychlorinated biphenyls to be marked with clear and adequate
warnings, and instructions with respect to their processing,
distribution in commerce, use, or disposal or with respect to any
combination of activities." Based on this mandate, EPA promulgated
regulations in 40 CFR 761.70, controlling the incineration of wastes
containing PCBs.
EPA Regional Administrators usually issue permits for incinerating
PCBs; however, for at-sea incineration of PCBs, the Assistant
Administrator for Water was delegated the responsibility for issuing
the permits. The Assistant Administrator for Pesticides and Toxic
Substances gives written approval of the permits before any
incineration of PCBs.
Because the special permits apply only to liquid PCB wastes, for
purposes of complying with TSCA regulations for incinerating PCBs, EPA
focused on those TSCA regulations in 40 CFR 761.70(a) which apply to
liquid PCB wastes. The following analysis compares the requirements of
Section 761.70(a) with the proposed incineration at-sea permits.
* 5 USC §2601, P.L. 94-469, October 11, 1976, 90 Stat. 2003
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(a) Operational Permits
(1) Section 761.70(a)(l)
Combustion criteria shall be either of the following:
(i) Maintenance of the introduced liquids for a 2-second dwell
time at 1200°C(VI000C) and 3 percent excess oxygen in the
stack gas; or
(11) Maintenance of the introduced liquids for a 1 1/2 second
dwell time at 1600°C(+100°C) and 2 percent excess oxygen in
the stack gas.
If incinerating TCDD or PCBs, the proposed incineration at-sea
permits require.
0 a minimum wall temperature of 1280°C; a minimum temperature of
1353°C prior to waste feed into the incinerators;
and an average wall temperature of 1303°;
0 a mean residence time on the order of one second or longer;
0 a minimum 5 percent oxygen in the stack gases; and
0 an average 10.1 percent oxygen in the stack gases.
These parameters were selected based on the August, 1982 trial
burn of PCBs under Research Permit HQ 81-002 which demonstrated a
destruction efficiency of greater than 99.99 percent on the M/T
VULCANUS I. Except for "dwell time", the time the liquid waste and its
gaseous combustion by-products are in the lower combustion chamber and
upper incineration stack, the parameters for the proposed permits are
more stringent than the TSCA requirements.
EPA once felt that residence time was a parameter of major
significance in developing regulatory policy. Residence time is
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currently overshadowed by the more important parameter of destruction
efficiency. While it is often stated that residence times (and
therefore the need to establish chemical waste feed and air flows) of 2
seconds or more were universally needed to achieve good destruction
performance for PCBs, the Agency now has an extensive data base which
indicates that as little as tenths of one second may be sufficient in
well designed incinerators. TSCA has a waiver provision for dwell time
which basically relies on destruction removal efficiency as the primary
measure of incinerator performance.
(2) Section 761.70(a)(3):
Combustion efficiency shall be at least 99.9 percent computed as
follows:
Combustion efficiency =
CC02/CC02 + Ceo x 100
where:
Ccog = Concentration of carbon dioxide in the combustion
gases.
Ceo = Concentration of carbon monoxide in the combustion
gases .
The proposed permits have an identical performance standard.
(3) Section 761.70(a)(3):
The rate and quantity of PCBs which are fed to the combustion
system shall be measured and recorded at regular intervals of no longer
than 15 minutes. (Section 761.70(a)(3)
The proposed permits require continuous monitoring and recording
of waste feed rate and/or auxiliary fuel (if used).
(4) Section 761.70(a)(4):
The temperatures of the incineration process shall he continuously
measured and recorded. The combustion temperature of the incineration
process shall he based on either direct (pyrometer) or indirect (wall
thermocouple-pyrometer correlation) temperature readings.
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The proposed permits have an identical provision for continuously
measuring and recording wall temperature.
(5) Section 761.70(a)(5):
The flow of PCBs to the incinerator shall stop automatically
whenever the combustion temperature drops below the temperatures
specified.
The proposed permits require automatic tamper proof devices to
instanteously shut off the flow of wastes to the incinerators if the
wall temperature falls below the minimum specified.
(6) Section 761.70(a)(b):
The flow of PCBs to the incinerator shall stop automatically when
any one or more of the following conditions occur unless a contingency
plan is submitted by the incinerator owner or operator and approved by
the Regional Administrator and the contingency plan indicates what
alternative measures the incinerator owner or operator would take if
any of the following conditions occur:
(i) Failure of monitoring operations specified;
(ii) Failure of the PCB rate and quantity measuring and recording
equipment;
(iii)Excess oxygen falls below the percentage specified.
(Section 761.70(a)(B))
An identical provision is included in the proposed permits.
(7) Section 761.70(a)(9):
Water scrubbers shall be used for HC1 control during PCB
incineration and shall meet any performance requirements specified by
the appropriate EPA Regional Administrator. Scrubber effluent shall be
monitored and shall comply with applicable effluent or pretreatment
standards, and any other State and Federal laws and regulations. An
alternate method of KC1 control may be used if the alternate method has
been approved by the Regional Administrator. (The HC1 neutralizing
capability of cement kilns is considered to be an alternate method).
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Land-based Incinerators must have auxiliary air pollution control
devices such as scrubbers to neutralize the hydrochloric acid emitted
as a by-product of the incineration of orqanochlorine compounds.
Scrubbers are also used to remove excess particulate matter. Water
scrubbers are not required for incineration at-sea because the
hydrochloric acid is rapidly rendered harmless by the dilution and
buffering action of the ocean. The proposed permits require that the
vessels' direction and orientation during incineration be controlled to
ensure that the hydrochloric acid in the incinerator plume is directed
to the stern of the vessel. The proposed permits limit the amount of
metals in the waste stream to ensure that any emissions reaching the
water do not cause marine water quality criteria to be exceeded. The
modeling described earlier showed that metals in excess of the 100 ppm
limit except for mercury, which is limited to 9 ppm and silver, which
is limited to 20 ppm, are more than adequate to ensure water quality
criteria or the limiting permissible concentration of PCBs as required
in 40 CFR 227.27 are not exceeded.
(8) Section 761.7(a)(6)
Monitoring of stack emission products shall be conducted:
(i) When an incinerator is first used for the disposal of PCBs
under the provisions of this regulation;
(ii) When an incinerator is first used for the disposal of PCBs
after the incinerator has been modified in a manner which may
affect the characteristics of the stack emission products;
Mil) At a minimum such monitoring shall be conducted for the
following parameters: (a) 02; (b) CO; (c) C0?; (d) Oxides
of Nitrogen (N02); (e) Hydrochloric Acid (HCT); (f) Total
Chlorinated Organic Content (RC1); (g) PCBs; and (h) Total
Particulate Matter.
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During the August 1982, trial burn on the M/T VULCAMUS I that
demonstrated a destruction efficiency of greater than 99.99 percent on
PCBs, the stack gases were monitored for the above parameters, except
for (d) oxides of nitrogen and (h) total particulate matter.
The stack gases were not monitored for oxides of nitrogen because
the wastes incinerated contained only minute concentrations of
nitrogenous compounds and in EPA's judgment, there would have been no
quantifiable emissions.
Total particulate matter was not measured because all surviving
organic species are completely disassociated from any particulate
matter in the emissions at the temperatures associated with the
combustion gases in at-sea incinerators (1300°C).
Measuring total particulate matter would have no effect on the
calculation of destruction efficiency. The liquid nature of the wastes
being incinerated also precludes significant formation of particulates.
The combustion gases are much cooler (40°C) on land-based incinerators
because of the scrubbers so surviving organic species could be
associated with particulate matter. Therefore, in order to accurately
calculate destruction efficiency for land-based incinertors, total
particulate matter must be monitored.
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(9) Section..761.7n(a)(7):
At a minimum monitoring and recording of combustion products and
incineration operations shall be conducted for the following parameters
whenever the incinerator is incinerating PCBs; (i) 02; (ii) CO; and
(iii) C02. The monitoring for 02 and CO shall be continuous. The
monitoring for C02 shall be periodic, at a frequency specified by the
Regional Administrator.
The proposed permits require continuous monitoring and recording
of oxygen, carbon monoxide, and carbon dioxide in the stack gases and
the draft (negative pressure) in the combustion chamber.
(b) Trial Burns
Section 761.70(d)(2):
The Regional Administrator may not approve the incineration of
PCBs unless he finds that the facility meets the operating and
performance requirements for incinerating liquid and/or non-liquid
PCBs. The Regional Administrator may approve the facility based on an
initial report submitted by the applicant and a waiver for a trial burn
or may approve the facility based on a trial burn. If the Regional
Administrator determines a trial burn is necessary, the applicant must
submit a detailed plan which includes:
(1) Date trial burn is to be conducted;
(2) Quantity and type of PCBs and PCB items to be incinerated;
(3) Parameters to be monitored and location of sampling points;
(4) Sampling frequency and methods and schedules for sample
analyses; and
(5) Name, address, and qualifications of persons who will review
analytical results and other pertinent data, and who will perform
a technical evaluation of the effectiveness of the trial burn.
The Regional Administrator may disapprove, modify, or approve the
plan. If the plan is approved, the trial burn takes place at a
date and time agreed to by the Regional Administrator and the
applicants.
Trial burns are used in the incineration at-sea program to conduct
an initial survey of a new vessel, in accordance with the London
Dumping Convention, and to determine the performance (destruction
efficiency) of an incinerator on PCBs or other POHCs. Research permits
are written for incineration at-sea trial burns and are similar to
special permits. The research permit specifies the POHCs to be
included (PCBs or other compounds), the minimum operating conditions
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and, as part of Appendix A, the testing protocols to be used in
determining the destruction efficiency of the incinerator. EPA reviews
the qualifications of persons who will collect the samples and perform
the analysis. However, it has been and it will continue to be EPA
policy to have an EPA observer or an EPA-certified observer onboard the
vessel during the trial burn. If the trial burn is conducted at a U.S.
incineration site, EPA may conduct environmental monitoring studies
from its research vessel, OSV ANTELOPE.
The waiver of a trial burn in order for the M/T VULCANUS II to
incinerate mixed chemical wastes with TCDD or PCBs discussed earlier,
was authorized under the above provision in the TSCA regulations. The
determination to issue the waiver was based on a finding by EPA's
Industrial Environmental Research Laboratory (IERL-CI) that the
M/T VULCANUS I and M/T VULCANUS II are using the same equipment and on
EPA's accumulated experience with monitoring incinerator emissions for
TCDD and PCBs.
(c) Finding
TSCA regulations for liquid PCBs specify a performance standard of
99.9 percent combustion efficiency. However, the performance standard
for non-liquid PCBs in Section 761.70(b)(l) states:
"The mass air emissions from the incinerator shall
be no greater than O.OOlg PCB/kg of tne F-CB
introduced into the incinerator"
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This translates into a destruction removal efficiency* of at least
99.9999 percent. While there is no equivalent destruction removal
efficiency stipulated in the TSCA Regulations for liquid PCBs, it is
believed that if the incinerator meets the operating requirements
(i.e., temperature, oxygen, and dwell time) and attains the stipulated
performance standard for combustion efficiency of 99.9 percent on the
entire waste mixture, then, the incinerator will achieve a destruction
removal efficiency of at least 99.9999 percent.
The proposed incineration at-sea permits require a destruction
efficiency of at least 99.99 percent. In the August 1982, trial burn
the M/T VULCANUS I demonstrated a destruction efficiency of greater
than 99.99 percent. A great deal of attention has been focused on this
apparent difference in land-based and at-sea incineration program
requirements.
In EPA's judgment, the real difference is not in the actual
performance of land-based and at-sea incinerators, but in the ability
to routinely detect trace quantities of surviving PCBs to demonstrate a
particular performance level. Sampling of the combustion gases in
land-based facilities is done after the gases pass through the
scrubbers. As a result, the combustion gases are approximately 40°C at
the time the gases are sampled in land-based facilities while the
combustion gases on the MA VULCANUS I and II are over 1200°C at
* Destruction removal efficiency is equivalent to the destruction
efficiency of at-sea incinerators. The difference in terminology is
a result of the auxiliary air pollution control devices, such as
scrubbers, that are required in land-based facilities.
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sampling. At these high temperatures the difficulty of sampling
increases substantially. The cooler combustion gases in land-based
facilities allow for longer sampling periods. The longer the sampling
period, the greater the volume of gases that can be collected. The
greater the volume of gases collected, the smaller the concentration of
surviving orgamcs that can be detected. EPA believes that if
incinerators at-sea could be sampled in the same manner as TSCA units,
at-sea destruction removal efficiencies also could be expressed to
99.9999 percent.
EPA scientists are confident that they can routinely demonstrate
greater than 99.99 percent destruction efficiency for at-sea
incinerators. However, until the difficulties of sampling hot
combustion gases can be surmounted, EPA scientists are not confident
that they can routinely demonstrate a destruction efficiency of 99.9999
percent for at-sea incineration.
Therefore, EPA finds that if at-sea incinerators attain the
performance standard of 99.9 percent combustion efficiency which is the
same as the TSCA requirements for liquid PCBs, and meet the operating
requirements (for temperature, oxygen and carbon monoxide) which are
more stringent than the TSCA requirements for liquid PCBs, then the
at-sea incinerators will perform at a level at least equal to that of
the land-based facilities incinerating liquid PCBs.
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Subpart 0 (40 CFR 264.340-264.351) of the regulations implementing
the Resource Conservation and Recovery Act (RCRA) cover land-hased
incineration of hazardous wastes with the exception of PCBs which are
regulated under TSCA and the rules in 40 CFR 761.70. The rules on
conducting trial burns under RCRA for land-based facilities are
in'40 CFR 122.27(b). Although RCRA regulations do not apply to the
incineration of hazardous wastes at-sea, it is EPA's policy to include
requirements in at-sea incineration permits equivalent to the
requirements in land-based permits, unless there is a specific reason
which renders the land-based requirements unnecessary for incineration
at-sea. Table 3 on page 83, "Hazardous Waste Incineration: Comparison
of At-Sea and Land-Based Requirements" summarizes and compares the
requirements in the proposed permits and those in RCRA issued permits.
(a) Operating Permits
(1) Performance Based Permits
RCRA-issued permits are performance based, as are incineration
at-sea permits. There are no "generic" operating conditions. Each
facility's operating conditions are determined by the conditions
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necessary for the achievement of the performance standard as
demonstrated in a trail burn. (Trial burns under RCRA and under at-sea
research permits are described later in this section).
(2) Section 264.342. Principal Organic Hazardous Constituents (POHCs)
Both programs require trial burns to determine whether the
incinerators can achieve a destruction efficiency of at least 99.99
percent on a POHC. A POHC is selected based on its heat of combustion
and concentration in the waste mixture. Waste mixtures eligible for
incineration in both programs are those that contain compounds with
heats of combustion equal to or greater than that of the POHC with the
lowest heat of combustion for which at least a 99.99 destruction
efficiency or destruction removal efficiency was demonstrated in the
trial burn.
(3) Section 264.343(a). Destruction Removal Efficiency/Destruction
Efficiency
As discussed under "Compliance with TSCA Regulations", destruction
removal efficiency (ORE) and destruction efficiency (DE) are
equivalent.
The formula for determining destruction removal efficiency and
destruction efficiency is the same:
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Win -
.
OE/DRE = Win x 100
Where*
Win = Mass feed rate of one POHC in the waste stream feeding
the incinerator
Wm,t = Mass emission rate of the same POHC in exhaust
emissions prior to release to the atmosphere.
(4) Section 264.343(d)
For purposes of permit enforcement, compliance with the operating
requirements specified in the permit will be regarded as compliance
with the performance standard. However, evidence that compliance with
those permit conditions is insufficient to ensure compliance^with the
performance requirements of this Section may be "information
justifying modification, revocation, or reissuance of a permit.
The proposed permits have a similar provision. Compliance with
the operating conditions specified in the permit will be regarded as
compliance with the performance standard. However, the proposed
permits may be modified, revoked or reissued if subsequent analyses
indicate that the operating conditions specified in the permits are
insufficient to ensure compliance with the performance standard of
99.99 percent destruction efficiency and 99.9 percent combustion
efficiency.
(5) Section 264.344(a):
The owner or operator of a hazardous waste incinerator may burn
only wastes specified in his permit and only under operating conditions
specified for those wastes.
(6) Section 264.344(b):
Other hazardous wastes may be burned only after operating
conditions have been specified in a new permit or a permit modification
as applicable. Operating requirements for "ew wastes may be based on
either trial burn results or alternative data included with Part B of a
permit application.
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Similar provisions are included in the proposed permits.
(7) Section 264.341(b):
Throughout normal operation, the owner or operator must conduct
sufficient waste analysis to verify that waste feed to the incinerator
is within the physical and chemical composition limits specified in his
permit.
The proposed permits require a chemical analysis of the wastes
prior to each incineration cruise. The chemical analysis must be
conducted in an EPA-approved laboratory in accordance with EPA-approved
protocols found in Appendix A of the permits. Duplicate samples may be
taken by an authorized EPA representative to verify the Permittees'
chemical analysis. Only when EPA is convinced that the wastes to be
incinerated meet the requirements of the permits will authorization be
given for loading the vessels.
An authorization for loading is, for all practical purposes, an
authorization for incineration. However, should the analyses of any
samples taken by EPA from the vessels' or dockside storage tanks or
from the blending/holding tanks at Emelle, Alabama demonstrate the
presence of compounds that were not in, or were in concentrations
greater than that indicated, in the original analyses of the
Permittees' samples of the blending/holding tanks, EPA may terminate
the incineration even if incineration has already begun.
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(8) Section 264.345(a):
An Incinerator must be operated in accordance with operating
requirements specified in the permit. These will be specified on a
case-by-case basis as those demonstrated in a trial burn or from
alternative data included with Part B of a facility's permit
application, to be sufficient to comply with the performance standard.
(9) Section 264.345(b):
Each set of operating requirements will specify the composition of
the waste feed (including acceptable variations in the physical or
chemical properties of the waste feed which will not affect compliance
with the performance standard) for which the operating requirements
apply. For each such waste feed, the permit will specify acceptable
operating limits including the following conditions:
(i) Carbon monoxide (CO) level in the stack exhaust gas;
(ii) Waste feed rate;
(iii )Combustion temperature;
(iv) An appropriate indicator of combustion gas velocity;
(v) Allowable variations in incinerator system design or
operating procedures; and
(vi) Such other operating requirements as are necessary to ensure
that the performance standards are met.
The proposed permits specify the compounds that may not be
included in a waste mixutre or are restricted. The proposed permits
also specify the incinerator operating conditions necessary to assure
compliance with the performance standards. The level of waste analysis
to be submitted by the Permittees must be expressed as quantifiable
concentrations of the chemical class of the compounds in a waste
mixture. This level of analysis is more than sufficient for EPA to
determine whether the compounds in a waste mixture are eligible for
incineration. It is not necessary to specify the physical properties
of the wastes because the design limits of the incinerator systems on
the M/T VULCANUS I and II preclude wastes other than pumpable liquids.
The proposed permits require that the waste feed rate he monitored but
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do not specify a thermal input rate. Nor do the proposed permits
specify "an appropriate indicator of combustion gas velocity." In lieu
of these operating indicators, the incineration at-sea permits require
demonstration of the performance standard of 99.9 percent combustion
efficiency after each burn to control the performance of the
incinerator.
(10) Section 264.34R(c):
During start-up and shut-down of an incinerator, hazardous waste
must not be fed into the incinerator unless the incinerator is
operating within the conditions of operation specified in the permit.
(Section 264.345(c))
The proposed permits have an identical provision.
(11) Section 264.345(e):
An incinerator must be operated with a functioning system to
automatically cut off waste feed to the incinerator when operating
conditions deviate from limits established. (Section 264.345(e))
The proposed permits stipulate that automatic devices shut off the
flow of the wastes to the incinerators whenever the flame goes out, or
the minimum temperature, minimum level of oxygen in the combustion
gases or the maximum level of carbon monoxide in the combustion gases
are reached or, the devices monitoring temperature, air flow, draft
(negative pressure) in the combustion chambers, oxygen, carbon
monoxide, carbon dioxide and waste feed flow and/or auxiliary fuel (if
used) fail.
(1?) Section 264.345(f):
An incinerator must cease operation when changes in waste feed,
incinerator design, or operating conditions exceed limits designated in
its permit. (Section 264.345(f))
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This provision is not applicable to the proposed permits because
prior to loading the wastes onto the vessel before each incineration
cruise, EPA makes a determination that the wastes meet the requirements
of the permits.
(13) Section 264.347(a)(l) and (2):
The owner or operator must conduct, as a minimum, the following
monitoring while incinerating hazardous waste:
(i) Combustion temperature, waste feed rate, and the indicator of
combustion gas velocity specified in the facility permit must
be monitored on a continuous basis.
(ii) CO must be monitored on a continuous basis at a point in the
incinerator downstream of the combustion zone and prior to
release to the atmosphere.
The proposed permits require continuous monitoring and recording
for:
0 wall temperature
0 air flow to the incinerators
0 oxygen concentration in the combustion gases
0 carbon monoxide concentration in the combustion gases
0 carbon dioxide concentration in the combustion gases
0 flow rates of the wastes or auxiliary fuel (if used)
0 draft (negative pressure) in the combustion chambers
The requirement for the continuous monitoring and recording of air
flow to the incinerators replaces the analogous RCRA requirement for
combustion gas velocity.
(14) Section 264.347(a)(3):
Upon request by the Regional Administrator, sampling and analysis
of the waste and exhaust emissions must be conducted to verify that the
operating requirements established in the permit achieve the
performance standards of destruction removal efficiency.
The proposed permits have a similar provision.
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(15) Section 264.347(b):
The incinerator and associated equipment (pumps, valves.
conveyors, pipes, etc) must be subjected to thorough visual inspection,
at least daily, for leaks, spills, fugitive emissions, and signs of
tampering.
The proposed permits require calibration of instruments before
each cruise and in accordance with manufacturer's recommendations. In
addition, the proposed permits require shipriders to provide 24 hour a
day observation of all incineration activities. Shipriders may be EPA
employees or EPA-approved contractors that report directly to EPA but
are paid for by the Permittees. These shipriders will inspect for
leaks, spills, signs of tampering, etc. A Principal Shiprider,
designated by EPA, may terminate incineration operations if, in his
opinion, any term or provision of the permits is not being met and harm
to the environment or human health or welfare is occurring or is about
to occur. The proposed permits also provide for the maintenance,
continuous monitoring and continuous recording of a minimum draft
(negative pressure) in the combustion chambers. This requirement will
prevent the release of fugitive emissions, thereby protecting shipboard
personnel and help to insure proper incinerator operation.
(16) Section 264.347(c):
The emergency waste feed cutoff system and associated alarms must
be tested at least weekly to verify operability, unless the applicant
demonstrates to the Regional Administrator that weekly inspections will
unduly restrict or upset operations and that less frequent inspection
will be adequate. At a minimum, operational testing must be conducted
at least monthly.
The proposed permits require testing of the automatic devices
shutting off the flow of wastes to the incinerators before each
incineration cruise.
(17) Section 264.3A7(d):
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Monitoring and inspection data must be recorded and the records
must be placed in the operating log.
The proposed special permits require the Permittees to submit the
monitoring and inspection data to EPA within 10 working days after the
termination of each incineration cruise. Data on destruction
efficiency tests conducted under the proposed research permit and on
destruction efficiency tests if conducted under the special permits do
not have to be submitted to EPA until 90 working days after the cruise
because it it takes longer to analyze the data to calculate destruction
efficiencies.
(18) Section 264.351(a):
At closure, the owner or operator must remove all hazardous waste
and hazardous waste residues (including, but not limited to, ash,
scrubber waters, and scrubber sludges) from the incinerator site.
The proposed permits require that waste contaminated waters or ash
from the vessels be incinerated at sea or disposed of in EPA-approved
land-based facilties.
(19) Section 264.347(c) and Sections 264.50-56: Contingency
Plan/Emergency Procedures
A Contingency Plan must be submitted as part of the permit
application for a RCRA permit as is required for the incineration
at-sea permits. While the incineration at-sea Contingency Plan and
emergency procedures cover similar generic topics (i.e., fires,
explosions, spills, etc.) as RCRA, the at-sea Contingency Plan focuses
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on different coordination mechanisms and responses based on the nature
and locations of the operations. EPA asked the U.S. Coast Guard to
review the Contingency Plan submitted by the applicants to determine
whether the Contingency Plan meets U.S. Coast Guard's requirements for
handling emergencies in the harbor and at sea. The finding by the U.S.
Coast Guard is discussed in the next section.
(b) Trial burns/research permits
Sections 264.344{c), 122.27:
The purpose of trial burns is to establish permit conditions,
including but not limited to, allowable waste feeds and operating
conditions for a new land-based hazardous waste incinerator under RCRA,
and for special permits under the Ocean Dumping Regulations. In some
respects, the trial burn under RCRA corresponds to the "survey" of the
vessel conducted by a Contracting Party to the London Dumping
Convention and in other respects with the at-sea incineration research
permits issued to determine the destruction efficiency of incinerators
on POHCs and the five compounds listed in the London Dumping Convention
on which doubts exist as to their incinerability.
Under RCRA, EPA approves the applicants' recommended operating
conditions, and trial burn plan, including waste analysis, sampling and
monitoring procedures, waste feed shut off systems, etc. These items
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are specified for the applicants in a research permit for incineration
at-sea trial burns.
A trial burn is limited to 720 hours (30 days) under RCRA with an
option for an additional 720 hours when good cause is shown.
Applicants may continue to burn wastes under the conditions specified
in the trial burn until the results of the trial burn are analyzed.
Research permits for incineration at-sea trial burns are issued
for six months. During the period of the research permit, incineration
of wastes may occur only under the closely monitored conditions
specified in the permit. Until the data from the trial burn is
analyzed additional "burns" may not take place.
(c) Findings
\ Based upon the above comparison of RCRA program requirements and
the conditions included in the proposed special and research permits,
EPA finds that the proposed permits are, at a minimum, consistent with
the RCRA requirements.
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6. U.S. COAST GUARD'S FINDING ON THE CONTINGENCY PLAN
The Applicants were required to submit, as part of their
application, a Contingency Plan which outlines the safety precautions
taken in designing, constructing and equiping the vessels and the
procedures to be implemented in case of an accident or other emergency
at-sea. Both vessels are classified as Type II chemical ships which
means that to be certified by the International Maritime Organization
and the U.S. Coast Guard there must be a significant degree of cargo
containment capability. Since both vessels have double hulls and
double bottoms and the wastes in both vessels are stored in several
compartments in the interior of the vessels, there is little likelihood
that any collision would cause the rupture of the storage compartments.
In addition, the safety equipment and its placement on board the
vessels is governed by the Safety of Life at Sea Convention (SOLAS).
As a condition of the permits and to operate in international and U.S.
waters, the vessels must have on board valid certificates indicating
compliance with all international and U.S. regulations.
The Contingency Plan also specifies the coordination mechanisms
and responses if fires, explosions, spills, collisions, etc., should
occur in the harbor or at sea. A major focus of the Contingency Plan
is the steps that will be taken to minimize the environmental affect of
an incident.
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Because of the nature of the activities in the harbor or at sea,
EPA requested that the U.S. Coast Guard review and make recommendations
on the adequacy of the Contingency Plan. Based on its preliminary
review, the U.S. Coast Guard concluded that both vessels have taken the
necessary precautions to prevent incidents and that the Contingency
Plan is a workable plan for responding to a wide variety of potential
emergencies at sea or in the harbor. During the comment period on the
Notice, the U.S. Coast Guard will make further recommendations on the
Contingency Plan.
Besides the inspections that the U.S. Coast Guard makes of the
vessels and their incinerators, the U.S. Coast Guard issues "Broadcast
to Mariners", warning other ships of the vessels' progress to and
Incineration at the site. In addition, the Captain of the Port Mobile
must be notified 24 hours before sailing which precludes the vessels
from sailing if there are pending storms which would interfere with the
safe passage of the vessels to the incineration site. The U.S. Coast
Guard supervises the loading of the vessels and the Captain of the Port
Mobile supervises the passage of the vessels through Mobile Bay to the
Gulf.
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7. CONCLUSION
Rased on the foregoing analysis, EPA has made a tentative
determination to issue special permits to Chemical Waste Management,
Inc. and Ocean Combustion Service, B.V. to use the M/T VULCANUS I and
the M/T VULCANUS II to incinerate a combined total of 300,000 metric
tons of mixed chemical wastes according to the conditions and
specifications in the permits. In addition, EPA has made a tentative
determination to issue a research permit to the Applicants to
incinerate 260,000 gallons of 10 percent dichlorodiphenyl
trichloroethane (DDT), 90 percent solvent waste.
EPA has determined that the proposed permits are consistent with
the'criteria in the Ocean Dumping Regulations in 40 CFR 220-228 and the
Regulations and Technical Guidelines of the CONVENTION ON THE
PREVENTION OF MARINE POLLUTION BY DUMPING OF WASTES AND OTHER MATTER
(the London Dumping Convention) to which the United States is a
Contracting Party. With respect to the incineration of PCBs, the
permits meet the requirements of the regulations in 40 CFR 761.70(a)
implementing provisions of the Toxic Substances Control Act on
incinerating liquid PCBs. In addition as a matter of Agency policy,
the proposed permits are consistent with the Solid Waste Disposal Act,
as amended by the Resource Conservation and Recovery Act regulations on
land-based incinerator facilities in 40 CFR Part 264, Subpart 0.
The following SECTIOM-BY-SECTION ANALYSIS identifies the permit
conditions and the reasons for the choice of the particular permit
conditions selected in accordance with 40 CFR 222.3(a)(4).
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III. SECTION BY SECTION ANALYSIS OF THE PERMITS
This sectlon-by-sectlon analysis summarizes the permit conditions
and the reasons for selecting the particular conditions as required by
40 CFR 222.3(a)(4).
EPA Signatory, Assistant Administrator for Water
On September 16, 1983, the Administrator of the Environmental
Protection Agency delegated responsibility to the Assistant
Administrator for Water to issue incineration at-sea permits.
The Assistant Administrator for Pesticides and Toxic Substances,
who must grant written approval of the permits prior to any
incineration of PCBs, has approved the proposed permits as meeting the
requirements of TSCA for the incineration of liquid PCBs and the
regulations in 40 CFR 761.70(a).
I. Authorized Permittees and Incineration Vessel
This section identifies and gives the address of the Permittees,
Chemical Waste Management, Inc., and its subsidiary Ocean
Combustion Service, BV. It also identifies the specific vessel
that is to be used for the incineration activities included in
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each of the permits. No vessel other than the vessel specified
may be used for the authorized activities.
II. Vessel and Incineration Certification
This part of the permit identifies the certificates that must be
obtained prior to issuing the permit. They include a "Certificate
of Fitness" issued by the International Maritime Organization
(IMO) and a "Letter of Compliance" from the U.S. Coast Guard.
These two certificates attest to the fitness of the vessels to
load and transport the material to be incinerated and to the fact
that the vessels are in compliance with international and U.S.
Maritime Regulations for the transport of dangerous chemicals.
In addition to the certificates authorizing the vessels to
transport hazardous wastes, the incinerators must also be surveyed
and certified by a Contracting Party to the London Dumping
Convention. Every two years the incinerators must be recertified.
The M/T VULCANUS I's incinerators must be recertified by June,
1985 and the M/T VULCANUS II1s incinerators must be recertified by
July, 1985. The U.S. Coast Guard inspects the safety of the
incinerators as required by P.L. 97-389, December 29, 1982.
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III. General Provisions
The items included in this section of the permits describe the
general administrative and enforcement provisions of the permits.
The terms used in the permits have the same meanings assigned to
them as those in the Marine Protection, Research and Sanctuaries
Act of 1972, as amended (the Act) and the regulations issued in 40
CFR Parts 220-228. Two other terms are used in the permit:
quantifiable concentration and Permit Program Manager.
Quantifiable concentration is defined as the minimum concentration
of a discrete chemical constituent (element or compound) in a
chemical waste that can be detected, identified, and quantified
without confirmatory analyses. The amount of this concentration
will vary depending on the chemical constituent, possible
interferences of other constituents in the chemical waste, the
method of sample preparation, and the method of analytical
detection, identification, and quantification (as defined in
Appendix A of the Permits).
The Permit Program Manager is identified as the Director, Criteria
and Standards Division, Office of Water Regulations and Standards,
U.S. EPA. The Permit Program Manager is the official who will
make the decisions on all aspects of the permit and who is
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ultimately responsible for ensuring that the incineration
operations are carrried out safely and efficiently.
By reference, EPA has included, as a general condition of the
permit, compliance with RCRA and TSCA regulations on the
generation, collection, transportation, labelling, storage and
reporting of hazardous materials; and U.S. Coast Guard
Regulations.
To assure compliance with the terms and conditions of the permits,
EPA, or an authorized representative of EPA, may enter the
premises of the Permittees to inspect records and monitoring
equipment and take duplicate waste samples for analyses, etc. The
"Right of Entry" is a generic provision of all permits.
EPA is also requiring that shipriders be onboard the vessels
during each incineration cruise to provide full and continuous
observation of all incineration activities. This provision is
predicated on the nature of incineration at-sea activities which
precludes unannounced spot checks.
The shipriders may be EPA employees or may be independent parties
selected by the Permit Program Manager. If independent parties,
the shipriders are paid by the Permittees but report directly to
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the Permit Program Manager. A Principal Shiprider is appointed by
the Permit Program Manager. He has the authority to terminate the
burn if in his opinion any term of the permit is not being met and
harm to the environment or human health or welfare is occurring or
is about to occur.
There is a generic prohibition against any intentional or
unintentional loss of wastes during loading, transport or
incineration activities. Compliance will be verified by comparing
the weight of the wastes loaded with the weight of the wastes
incinerated and with the weight of any remaining wastes in the
cargo tanks.
The Permittees have $350,000,000 in insurance policies which
appear fully adequate to protect the United States, States and the
public against any and all liability arising out of the Permittees
acts or emissions in the performance of the permits. EPA is not
necessarily endorsing this specific amount. The Agency is
requesting recommendations on appropriate methodologies for
determining an adequate level of liability insurance.
For any violation of the terms or conditions of the Permit, the
Permittees may be liable for a civil and/or criminal penalty of
not more than $50,000 per day for each violation. In addition,
any person who knowingly violates any provision of the Act, the
regulations, or this Permit shall be fined not more than $50,000
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per day for each violation and/or be imprisoned for not more than
one year. The amount of the penalty will depend on the severity
of the particular violation.
The Permit may be modified, revoked or reissued if subsequent
analyses indicate that the operating conditions specified in the
Permit are insufficient to assure compliance with the performance
standard of 99.99 percent destruction efficiency and 99.9 percent
combustion efficiency. In addition, if analyses of data obtained
from long term monitoring of the Gulf Site indicate adverse
environmental and/or human health impacts from incineration
activities, the Permit may be revoked or reissued. There is also
a provision that the Assistant Administrator for Water or the
Permit Program Manager shall suspend the permit if any of the
activities are likely to result in imminent and substantial harm
to human health or to the environment.
Included in the General Provisions are procedures which must be
followed if there is a life threatening emergency which
necessitates the discharge of a portion or all of the cargo to
save lives. If such an emergency should occur, the MASTER of the
Vessel notifies the U.S. Coast Guard and the Permit Program
Manager immediately. Within ten days of the emergency a full
written report is to be made to the Assistant Administrator for
Water detailing the emergency and the actions taken.
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IV. Special Provisions
This section stipulates the terms and conditions necessary to
assure that the mixed chemical wastes to be incinerated under HO
83-001 and under HQ 83-002 and the 10 percent dichlorodiphenyl
trichloroethane (DPT) 90 percent solvent to be incinerated under
HO 83-003 are completely and safely destroyed. Each condition is
described separately, below.
1. Permit Term
The three year expiration date for the Special Permits, HQ
83-001 and HQ 83-002 is a regulatory requirement of 40 CFR
220.3(b). The six months expiration date for the Research
Permit HQ 83-003 is a statutory requirement of 33 U.S.C.
1412a(b), as amended by PL 96-572, December 20, 1980.
2. Description of Material
a. Eligible Material:
Mixed liquid organic compounds including, but not limited to
chlorinated organic compounds, comply with the criteria in 40
CFR 227.4, 227.8, 227.11, 227.12, and 227.27. The design of the
incinerator system on the M/T VULCANUS I and the M/T VULCANUS II
precludes wastes other than pumpable liquids.
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The M/T VULCANUS I Is authorized to incinerate mixed chemical
wastes containing compounds with a heat of combustion equal to
or greater than 1.79 kcal/gram. The eligibility of the M/T
VULCANUS I's incinerators was established in the August, 1982
trial burn (conducted pursuant to Research Permit HQ 81-002).
Hexachlorobenzene was the POHC with the lowest heat of
combustion, 1.79 kcal/gram, tested. The destruction efficiency
attained in the tests was greater than 99.99 percent.
Based on the February, 1983 trial burn on the M/T VULCANUS II
that was conducted jointly by the Government of Netherlands and
EPA1, a destruction efficiency of greater than 99.99 percent was
attained on tetrachloromethane which has a heat of combustion of
0.24 kcal/gram. Therefore, the M/T VULCANUS II is authorized to
incinerate mixed chemical wastes with a heat of combustion equal
to or greater than 0.24 kcal/gram.
b. Prohibited Materials:
(1)
The mixed chemical wastes may not include, in quantifiable
concentrations, the following:
(A) compounds with heats of combustion less than 1.79 kcal/gram
for the M/T VULCANUS I and less than 0.24 kcal/gram for the
M/T VULCANUS II. This is consistent with the Ocean Dumping
Regulations, 40 CFR 227.6(h), the requirements of the
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POHC/Index of Incinerability found In RCRA's regulation at 40
CFR 122.27(b)(l) and the London Dumping Convention (Annex 5,
Regulation 5).
(1) (B)-(D)'
The London Dumping Convention (Regulation 4) requires 'a trial burn
for DDT, BHC, and PCT because there are doubts as to the
incinerability of these compounds.
The amount of TCDD (dioxin) in the waste mixture is limited to 2
ppm based on the 1977 trial burn in which the M/T VULCANUS I
incinerated Herbicide Orange with an average concentration of 1.9
ppm TCDD. Usually a concentration of at least 100 ppm of a
compound is needed in a waste mixture to analytically measure and
demonstrate an incinerator's destruction efficiency for that
compound to at least 99.99 percent. An overall destruction
efficiency of greater than 99.93 was demonstrated for dioxin in
the three burns. However, EPA believes that in actuality, the
incinerators probably achieved at least a 99.99 percent
destruction efficiency based on the fact that during the same
trial burns, the destruction efficiencies for 2,4-D and 2,4, 5-T
were calculated to be greater than 99.999 percent.
At that time the methodologies employed did not have the
analytical sensitivity to measure low levels of potentially
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surviving dioxin in stack gas samples in order to be able to
demonstrate an unqualified destruction efficiency. In order to do
so, there has to be a detectable and quantifiable amount of a
compound in the stack gas samples. Failure to detect a compound
does not mean that the compound is not there, if the level of
detection of the sampling and analytical methodology is not
adequate to measure low levels of a particular compound and if, as
was the case with Herbicide Orange, there were compounds with a
similar chemical structure as dioxin in the stack gases sampled.
In addition to the fact that EPA believes the destruction
efficiency obtained on TCDD was probably closer to 99.99 percent
than the data indicate, dioxin is much easier to incinerate with a
heat of combustion of 3.43 kcal/gram than hexachlorobenzene with a
heat of combustion of 1.79 kcal/gram on which the M/T VULCANUS I
later demonstrated greater than 99.99 percent destruction
efficiency or tetrachloromethane with a heat of combustion of 0.24
kcal/gram on which the M/T VULCANUS II demonstrated greater than
99.99 percent destruction efficiency. Furthermore, incinerator
plume modelling and subsequent ocean dispersion modelling have
demonstrated that the emissions resulting from the incineration of
chemical wastes containing 2 ppm of dioxin at a destruction
efficiency of 99.93 percent will cause no adverse environmental
impact. This is based on a determination that any uncombusted
dioxin in the emissions would result in an ambient water
concentration of dioxin below the marine aquatic life no effect
level for this compound and below the limiting permissible
concentration as required in 40 CFR 227.27. Therefore, EPA has
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authorized the Incineration of waste mixtures containing dioxln at
2 ppm or less.
A trial burn was waived for the M/T VULCANUS II to demonstrate a
99.99 percent destruction efficiency on dioxin based on a finding
that the incinerator equipment on the M/T VULCANUS II is the same
as that on the M/T VULCANUS I and on EPA's accumulated experience
in monitoring incinerators for dioxin emissions.
(11) (B)
The concentration of PCBs in the waste mixture may not exceed 35
percent to assure that at a destruction efficiency of at least
99.99 percent, any trace PCB emissions will not cause ambient
marine water quality criteria (limiting permissible
concentrations) to be exceeded as required at 40 CFR 227.27.
Trial burns on the M/T VULCANUS I demonstrated destruction
efficiencies of greater than 99.99 percent on PCBs. In addition,
incinerator plume modelling and subsequent ocean dispersion
modelling have shown that any surviving PCBs in the emission plume
would result in an ambient marine water concentration of PCBs
below the marine water quality criterion for PCBs as required by
40 CFR 227.27.
EPA also waived the trial burn on PCBs for the M/T VULCANUS II.
This PCB waiver is based on the same determination as the TCDD
waiver that the M/T VULCANUS II's incinerator equipment is the
same as that on the M/T VULCANUS I and on EPA's accumulated
experience in monitoring the incineration of PCBs.
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(11)
EPA is limiting the chlorine content of the wastes to 70 percent
of the mixture. Trial burns have shown that the incinerators on
both vessels can attain combustion efficiencies of 99.9 percent on
-whole wastes with a chlorine content as high as 70 percent as well
as destruction efficiencies of greater than 99.99 percent on POHCs
in a waste mixture with a 70 percent chlorine content. In fact,
EPA has found no technical basis in theory or In practice for
limiting the concentration of total organochlorines. There is a
self-regulating incentive for the Permittees to incinerate wastes
with sufficient heating values to maintain the specified
temperature and other control parameters without supplementing the
wastes with auxiliary fuel.
This, therefore, will usually limit total organochlorine content
in wastes to no more than 70 percent for any burn. However,
consistent with other provisions of the Permit, EPA is adopting a
conservative approach and specifying 70 percent as a maximum
amount.
(Hi) (A-C)
Limits are placed on metals, to assure that the applicable marine
water quality criteria will not be exceeded. The limits are based
on a model developed for EPA by JRB Associates under EPA Contract
Mo. fi8-01-6388, Work Assignment No. 37. The model was used to
determine the limiting permissible concentrations of a consistuent
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as required by 40 CFR 227.27. The models are discussed 1n the
report, Permissible Metal. PCB, and TCDD (Dioxin) Concentrations
In Incineration Waste Material, September 26, 1983. The model
Indicated that for all but two of the metals (silver and mercury),
significantly higher metal concentrations than 100 ppm in waste
would not emit a level of metals after incineration that would
cause water quality criteria to be exceeded. EPA has limited the
maximum concentration to 20 ppm for silver, 9 ppm for mercury and
100 ppm for the remaining metals to add an additional margin of
safety due to the uncertainties of assumptions used in any model.
Although the limits in the permits are conservative, they will be
retained until EPA can verify that even trace amounts of these
materials will have no long term adverse Impact on the marine
environment.
(A-D)
High level radioactive wastes or materials used in radiological,
chemical or biological warfare are prohibited by Section 102(a) of
the Act. In addition, the Ocean Dumping regulations at 40 CFR
227.5 prohibits materials which cannot be identified or, which are
persistent, inert, synthetic or, which may float or remain in
suspension in the ocean.
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(v)
The analyses conducted to confirm that the wastes are eligible
for incineration must be done in accordance with Appendix A,
"Waste Sampling and Analysis Procedures".
3. Analysis of Material
(a-d)
The Ocean Dumping Regulations prohibit .in 40 CFR 227.5(c) the
- incineration of materials insufficiently described to determine
their impact on the environment. Before the wastes are loaded
onto the vessels, for each incineration cruise, the Permittees
must provide chemical analyses of the wastes to be incinerated.
The chemical analysis must be conducted in an EPA-certified
laboratory in accordance with the EPA-approved protocols found in
Appendix A of the permit. The analyses will provide information
on quantifiable concentrations of the chemical classes of the
constituents in the waste mixture. A quantifiable concentration
of an organochlorine is most likely 1-2 ppm and of a metal 1-10
ppb. This level of detail is sufficient to determine the
incinerability of the wastes and the effects of a waste on the
environment after incineration.
The samples are to be taken from the Permittees' blending/holding
tanks at Emelle, Alabama and, at the discretion of the Permit
Program Manager, from the dockside or the vessels' storage tanks.
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The Permit Program Manager may require duplicate samples be taken
by EPA or by an authorized EPA representative, coded and analyzed
in an EPA-approved laboratory to verify the Permittees analyses.
This will be done at the Permittees' expense.
Permittees' are to report, to the best of their knowledge, whether
any of the wastes to be incinerated are from hazardous waste sites
which are subject to a Court, State or, an EPA cleanup order.
This information will assist EPA and the States in verifying the
location and final disposition of such wastes and may assist EPA's
determination as to whether the wastes meet the permit conditions.
4. Authorization for Loading the Vessel and Incineration
(a-c)
The Permit Program Manager will evaluate the chemical analyses
submitted by the Permittees to ensure that the wastes do not
contain quantifiable concentrations of chemicals with a heat of
combustion less than that specified in the permits (for HQ 83-001,
1.79 kcal/gram; for HQ 83-002 and HQ 83-003, 0.24 kcal/gram), and
do not contain any prohibited materials. In addition, the Permit
Program Manager will verify that the duplicate samples, if taken,
are equivalent. If the Permit Program Manager is convinced that
the wastes meet the specifications of the Permit, he will
authorize the loading of the vessel. Loading of the vessel may
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begin based on a verbal authorization, but prior to departure, the
specific written authorization must be onboard the vessel.
The authorization for the loading is, for all practical purposes,
, t. •
an authorization for incineration. However, should any of the
results of analyses on samples taken by EPA from the vessels' or
dockside storage tanks or from the blending/holding tanks in
Emelle, Alabama demonstrate the presence of compounds that were
not in or were in concentrations greater than that indicated in
the original analyses of the Permittees' samples of the
i
blending/holding tanks, the Permit Program Manager shall terminate
the incineration if the newly discovered compounds or the
concentrations of these compounds are not eligible for
incineration. If these verification analyses of the mixed
chemical wastes show the wastes are nevertheless eligible for
incineration, the Permit Program Manager has the discretion to
terminate or to continue the incineration. In any case, whether
i
the incineration is terminated or not, any discrepancies, beyond
the expected range of sample and/or analytical variation,
constitute a violation of the permits.
The U.S. Coast Guard supervises the loading of the vessels and the
Captain of. the Port, Mobile supervises the passage of the vessels
through Mobile Bay of the Gulf.
5. Amount of Material
The total amount of material authorized for incineration under the
special permits (HQ 80-001 and HQ 83-002) between the two vessels
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is 300,HOO metric tons. One vessel may incinerate the entire
amount or both vessels nay incinerate a portion, as long as the
total amount incinerated does not exceed 300,nno metric tons.
The 900 metric tons authorized under Research Permit HQ 83-003 is
an amount needed to run a sufficient number of destruction
efficiency tests.
6. Transportation Activities
(a)
Section 223.1(a) states that the permit shall include the port
through "or from which the wastes will be transported. The
authorized point of departure is the Port of Mobile, Alabama.
Designation of a specific port also serves to restrict the
geographic area in which the activities may take place to aid in
EPA's and the U.S. Coast Guard's surveillance and enforcement
functions.
(b)
The Captain of the Port, Mobile and the 8th District Coast Guard
are to be notified 10 days before the loading of the vessel. This
notification is preliminary because the loading of the vessel may
not take place until authorized by the Permit Program Manager.
Twenty-four hours prior to sailing, the Captain of the Port is to
be notified. At this time the written authorization for loading
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the vessel from the Permit Program Manager must be onboard the
Vessel .
(c)
In notifying the Captain of the Port of sailing, items, such as
permit number, vessel call sign, estimated arrival at the
incineration site, etc. are required so that the U.S. Coast Guard
can issue the "Broadcast to Mariners" of the vessels' progress and
incineration activities.
(d)
The items listed in this section including the permit, name of
person notified of sailing, time of contact, confirmation code and
written authorization for loading must be onboard the vessel to
ensure that the proper authorization and notifications were made.
During transport, the vessels must navigate around by at least 15
nautical miles the West and East Flower Gardens and by at least 5
nautical miles the Claypile and Stetson Banks. These areas were
identified in the 1976 EIS on the Gulf Incineration Site as areas
of biological significance that would be adversely impacted if an
accident occurred. While these areas are outside the normal
shipping fairways, EPA made transport around them a condition of
the Permit to provide additional protection to these areas.
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7. Incineration Site
(a)
The coordinates of the Gulf Incineration Site are:
•Latitude Longitude
26*20'00"N 93°20I00"W
,26°20'00"N 94000'00"W
27°00'00"N 93°20'00"W
27>°OQI00"N 94°00'00"W
As provided for in 40 CFR 228.12(b)(l), incineration of the mixed
chemical wastes may occur only when the vessel 1s within the
boundaries of the site. The continuous monitoring of the vessel's
location required under Special Provision No. 10(b)(viii) and
su'bmittal of these reports to the Permit Program Manager as
provided for in Special Provision No. 11 will verify that
incineration of the wastes occurred in the designated site only.
(b)
EPA is restricting the use of the site at this time to one vessel
at a time, consistent with its authority under 40 CFR 228.7. This
is being done for navigational safety and until the Agency
evaluates the monitoring data from the site. This does not mean
that only one Permittee may use the site. Rather, EPA will assure
that there Is an equitable distribution of the use of the site
among all Permittees.
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8. Performance Standard
(a) Destruction Efficiency of at least 99.99 percent
— A destruction efficiency of 99.99 percent was established as
a performance standard based on extensive data indicating
that such a destruction efficiency is attainable,and can be
routinely measured in incinerators burning a wide range of
organic hazardous wastes in concentrations that are over 100
ppm. This destruction efficiency ensures that any emissions
from the incineration process will be rapidly rendered
harmless or will be present as only trace contaminants, as
required in 40 CFR 227.6. This determination is based on
incinerator plume modeling and subsequent ocean dispersion
modeling that show any emissions will be below the limiting
permissible concentrations as required by 40 CFR 227.27.
— The formula for calculating destruction efficiency is as
follows (example for DDT):
Destruction Efficiency =
Total DPT fed - DDT in combustion gases x 100
total DDT fed
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(b) Combustion efficiency of at least 99.9 percent.
— Based on EPA's accumulated experience and judgment In
monitoring incineration, a combustion efficiency of at least
99.9 percent on the entire load of mixed chemical wastes (or
the liquid DDT wastes under Research Permit HQ 83-003)
corresponds to destruction efficiencies of at least 99.99
percent for all compounds in the wastes whose heats of
combustion are equal to or greater than 1.79 kcal/gram (M/T
VULCANUS I) or 0.24 kcal/gram (M/T VULCANUS II). Combustion
efficiencies are continuously calculated on each Incineration
cruise.
— The formula for calculating combustion efficiency is as
follows:
Combustion Efficiency = [CO? x 100
[C02 + [CO]
Where:
C02 = carbon dioxide 1n the combustion gases.
CO = carbon monoxide in the combustion gases.
(c) Destruction efficiencies are calculated on each incineration cruise
under Research Permit HQ 83-003 if more than one cruise is
necessary to obtain sufficient data, but not necessarily for each
incineration cruise under Special Permits HQ 83-001 and HQ 83-002.
The Permit Program Manager may request in either,of the two special
permits that the Permittees sample and analyze the waste and
emissions to verify that the operating conditions established in
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the permits achieve the performance standard of 99.99 percent
destruction efficiency.
9. Operating Conditions
(a) Incinerator Conditions
In EPA's judgment, the minimum and average operating conditions
set forth in this section will ensure that the incinerators attain
and maintain a destruction efficiency of 99.99 percent and a
combustion efficiency of at least 99.9 percent.
The minimum operating conditions are based on EPA's accumulated
data and best engineering judgment that complete combustion will
still occur if operating conditions less stringent than these
exist. The minimum operating levels are set for temperature and
oxygen concentration in the combustion gases, and a maximum level
of carbon monoxide concentration in the combustion gases because
these are the three key parameters in assuring complete combustion
of chemical wastes.
The average operating conditions that must be maintained during
incineration are based on the trial burns which demonstrated thati
the incinerators on the M/T VULCANUS I and M/T VULCANUS II
achieved destruction efficiencies of greater than 99.99 percent on
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the POHCs tested. The operating temperatures established for the
M/T VULCANUS II are lower than those for the M/T VULCANUS I,
except when burning TCDD or PCBs for two reasons. First, the BTU
content of the wastes burned during the trial burn on the M/T
VULCANUS II was lower than the M/T VULCANUS I. Second, the
thermocouples measuring the wall temperature on the M/T VULCANUS
II are placed higher above the burner head in a cooler part of the
stack than on the M/T VULCANUS I.
The averages are to be calculated every two hours. The two hour
time frame corresponds to the approximate time it takes to run a
destruction efficiency test while recording the operating
parameters during a trial burn. By using the same time frame,
there is greater assurance that the proper combustion is attained
throughout the incineration.
The minimum (or maximum for CO) operating conditions and the
averages for the M/T VULCANUS II, when incinerating wastes
containing TCDD and PCBs, are the same as those for the M/T
VULCANUS I. The reason for this is that the waivers for trial
burns on TCDD and PCBs for the M/T VULCANUS II were based, inpart,
on the determination that the incinerator equipment used on the
M/T VULCANUS II is the same as that on the M/T VULCANUS I.
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In the Research Permit, HO 83-003 only minimum (or maximum for CO)
operating conditions are specified. The Research Permit will
establish average operating conditions as a result of the trial
burn.
(i) The flow of the mixed chemical wastes into the incinerator
shall not commence or, if the mixed chemical waste flow has been
stopped for any reason, recommence, unless the incinerator wall
temperature is equal to or greater than 1353°C for the M/T
VULCANUS I or for the M/T VULCANIS II is equal to or greater than
1250°. If the M/T VULCANUS II is incinerating PCBs, this
temperature must be 1353°C.
Prior to feeding the waste into the incinerator, a temperature
50°C higher than the average must be attained to provide an
adequate margin of safety against possible transients in the
operating efficiency of the combustion zone.
(ii) Except as provided in (i) above, wastes may be fed into the
incinerator only if the following minimum conditions are met:
(A) The combustion wall temperature is to be equal to or greater
than 1280°C for the M/T VULCANUS I and 1166°C for the M/T
VULCANUS II. If the M/T VULCANUS II is incinerating wastes with
TCDD and PCBs then the minimum wall temperature is to be equal
to or greater than 1280°C.
The minimum specified temperatures are based upon data collected
from actual trial burns on both vessels and on data from a large
number of land-based incinerators. These values are to be used
as an operating guide to set the temperature where waste feed
should be automatically stopped to the individual incinerator
unit in question. In all cases, auxiliary fuel must be
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automatically substituted for waste feed at a rate to maintain
the thermal operation of the incinerator until corrective action
is taken to restore the proper temperature.
(B) A minimum of 5 percent oxygen (02) shall exist in the
combustion gases.
EPA is specifying a minimum 5 percent oxygen level in the
combustion-gases for incinerators of the Vulcanus type based
upon a review of existing M/T VULCANUS I and II performance
data, land-based incinerator data, and the Agency's liquid PCB
incineration regulations (40 CFR 761.70(a)).
(C) The concentration of carbon monoxide (CO) in the combustion
gases shall not exceed 100 ppm.
Carbon monoxide is stated as an "upper permit limit at 100 ppm"
because this represents approximately a 99.9 percent combustion
efficiency at a typical 10 percent carbon dioxide operating
range.
Hii) The average operating conditions are based on the trial burns of
the M/T VULCANUS I and M/T VULCANUS II.
(A) The average combustion wall temperature is to be equal to or
greater than 1303°C for the MA VULCANUS I and 1200°C for the
M/T VULCANUS II. If the M/T VULCANUS II is incinerating wastes
with PCBs, then the average wall temperature is to be equal to
1303°C.
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The temperature in the combustion zone 1s an operational
indicator that the incinerator is performing properly.
(B) The average oxygen level in the combustion gases shall be
equal to or greater than 10.1 percent for the MA VULCANUS I and
10.6 percent for the M/T VULCANUS II, except if incinerating
TCDO and PCB, the average oxygen level in the combustion gases
for the M/T VULCANUS II must be equal to or greater than 10.1
percent.
The oxygen level in an incinerator combustion chamber or in the
stack gases provides an indication of how well combustion air
flow is adjusted to the needs of the waste combustion process.
Finding oxygen in the combustion gases indicates that combustion
air feed is adequate, while a lack of oxygen would present a
cause for concern that not enough air was being supplied to
oxidize all of the wastes or fuel fed to the incinerator.
M/T VULCANUS I and II data indicate that oxygen concentrations
as low as 3.8 to 5.4 percent have been measured during trial
burns which demonstrated destruction efficiencies of greater
than 99.99 percent on the POHCs tested. The more typical
VULCANUS operating range has been in the 6.4 to greater than 13
percent range with 8 to 11 percent being the center of this
range. The land-based units that EPA has tested or has
evaluated, have attained destruction efficiencies at very
similar ranges of oxygen levels in the combustion chamber outlet
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duct. From the extensive data base on all types of hazardous
waste incinerators, EPA has found that oxygen levels in the
range of approximately 5 through 15 percent are a consistently
-successful operating range for oxygen levels in the combustion
gases.
(C) The average carbon monoxide level in the combustion gases
shall be no greater than 8 ppm for the M/T VULCANUS I and 22 ppm
for the M/T VULCANUS II except if incinerating TCDD and PCB, the
average carbon monoxide level in the stack gases for the M/T
VULCANUS II must be no greater than 8 ppm.
Preference is for as low or, as close to zero carbon monoxide
level as possible. The usual performance of both M/T VULCANUS I
and II vessels has been measured in the range of 3 to 20 ppm of
carbon monoxide emission with most long term data showing a
tendency for the 8 to 15 ppm range. The better-performing
land-based incinerators also perform at the 5 to 10 or 20 ppm
carbon monoxide range.
(D) The mean residence time of the mixed chemical wastes in the
incinerator shall be on the order of 1.0 seconds or longer.
This requirement is included in the permits to be consistent
with the London Dumping Convention. Residence time is a
parameter which was once felt to be of major significance in
developing regulatory policy but is currently overshadowed by
the more important parameter of destruction efficiency. While
EPA formerly believed that residence times of 2 seconds or more
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were universally needed to achieve good destruction performance
under both TSCA and RCRA permits, the Agency now has an
extensive data base which indicates that as little as tenths of
one second may be sufficient in well designed incinerators for
many kinds of materials. RCRA policy has dropped its residence
time requirements and TSCA has a waiver provision which
basically relies on destruction removal efficiency as the
primary measure of incinerator performance.
(b)(D
Automatic waste feed shutoff devices must stop the flow of the
wastes to the incinerators whenever the flame goes out, or whenever
the minimum operating conditions specified for wall temperature and
oxygen or, maximum operating conditions for carbon monoxide are not
achieved or, whenever the monitoring devices for wall temperature,
air flow to the incinerators, draft (negative pressure) in the
combustion chambers, oxygen, carbon monoxide, carbon dioxide or
waste feed flow and/or auxiliary fuel (if used) fail. This is to
prevent incomplete combustion of the wastes, provide data to
calculate combustion efficiency and dwell time, and prevent the
escape of emissions other than through the plane of the stacks to
protect shipboard personnel.
Before each cruise, the automatic devices shutting off the wastes
to the incinerators are to be tested. This assures that these
devices are in proper working order.
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(c) Other Operating Conditions
(1)
The condition that operating controls and monitoring devices are
to be supervised at all times by appropriately trained personnel
is necessary, in EPA's judgment, to assure the safe and efficient
operation of the incinerators.
(H)
The condition that there be no black smoke or extension of flame
above the plane of the stack is a requirement of the London
Dumping Convention. Black smoke or flame above the stack is an
indication of incomplete combustion.
(Ill)
The condition that a draft (negative pressure) of at least one (1)
i *
inch water column be maintained in each combustion chamber will
ensure that sufficient oxygen content in the combustion gases
results only from the operation of the blowers and also will
ensure that combustion emissions can exit only through the
incinerator stack plane, thereby protecting shipboard personnel.
(iv)
To assure that the plume is directed toward the stern of the
vessel and to assure that the plume does not come in contact with
the Vessel, the direction and orientation of the vessel and the
vessel's speed plus wind speed must be controlled. Based on EPA's
experience, the vessel's speed plus wind velocity must be at least
three knots to assure that the plume does not contact the vessel.
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(v)
The addition of ammonia to the plume, when needed, will assure
that the plume is visible and that any ships which wander off
course or which have not heard the "Broadcast to Mariners" will be
aware of and avoid the incineration operations. Visibility of the
plume is also essential if monitoring activities such as plume
tracking are conducted in the vicinity of the vessels.
(vi)
If tanks are washed, they are to be washed with a combustible
solvent. These washings and any tank residues remaining after
incineration are to be incinerated at-sea or upon return to port
incinerated in EPA-approved land-based facilities.
This provision meets the requirements of the TSCA regulation set
forth in 40 CFR 761.60 and the TSCA Compliance Program Policy No.
6 PCB-2 ~ Physical Separation Techniques (August 16, 1983).
(vii)-(viii)
Any wash waters, ballast waters, or pump-room bilge water
determined to be contaminated with organochlorine wastes beyond
background levels (as determined by on-board analysis) or any
residues (ash) remaining in the incinerator must be incinerated
at-sea or, on return to port either incinerated in EPA-approved
land-based facilities or, alternatively, treated according to
applicable EPA regulations. In no case are these contaminated
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waters or incinerator residues to be discharged directly to the
ocean or into the harbor. This provision further ensures all
possible measures will be taken to protect the environment.
(ix)
The requirement that all radio calls be promptly answered, is
included to make certain that there is continuous communication
between the vessel and the U.S. Coast Guard, the Captain of the
Port, Mobile and the Permit Program Manager during transport and
incineration activities. It is essential that any unusual
circumstances be reported immediately and that instructions on
handling the unusual circumstances be conveyed to the vessel.
(x)
During the start up of the incinerators or when the waste feed is
being switched from one tank to another, vibrations may occur.
Normally minor adjustments to the operating controls should
eliminate the vibrations. EPA believes that any vibrations should
be immediately investigated and corrective steps taken to
eliminate the vibrations. The Principal Shiprider may terminate
incineration operations if in his opinion, the vibrations endanger
the integrity of the incinerator system, the monitoring devices,
the tanks or, the vessel itself.
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in. Monitoring and Recording Requirements
Tamper proof monitoring devices are to record during incineration,
wall temperature, oxygen in the combustion gases, carbon monoxide
in the combustion gases, carbon dioxide in the combustion gases,
flow rates of the mixed chemical wastes and/or auxiliary fuel (if
used), time, date, wind speed and direction, and vessel position,
course and speed. In EPA's judgment, this information is needed
to verify that the performance standards and operating conditions
have been met, that the incineration took place at the designated
site and that there was no direct discharge of wastes to the
water.
00
The monitoring and recording of wall temperature, oxygen, carbon
monoxide, carbon dioxide and waste feed flow and/or auxiliary fuel
(if used) must be continuous. Wall temperature, oxygen and carbon
monoxide are the key parameters which determine the operating
efficiency of the incinerators. In addition, carbon dioxide and
waste feed flow and/or auxiliary fuel flow (if used) are required
in order to calculate combustion efficiency, dwell time and
overall incinerator performance.
(c) The continuous monitoring and recording of draft (negative
pressure) in the combustion chambers will ensure that Special
Provision 9(c)(iii) is met.
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(d) The continuous monitoring and recording of air flow to the
incinerators will allow for the calculation of dwell (residence)
time and ensure that Special Provision 9(a)(iii)(D) is met.
(e)
If the continuous recording devices fail for wall temperature,
air flow to the incinerators, draft (negative pressure) in the
combustion chambers, oxygen, carbon monoxide, carbon dioxide and
waste feed flow and auxiliary fuel (if used), the automatic
devices that shut off the wastes to the incinerator must be
activated for the reasons described in (b), (c) and (d) above.
If the monitoring devices fail for measuring time, date, wind
speed and direction, and vessel position, course and speed, an
hourly manual log is to be kept until the devices are repaired.
(9),
Calibration of instruments measuring wall temperature, air flow to
the incinerators, draft (negative pressure) in the combustion
chambers, oxygen, carbon monoxide, carbon dioxide and waste feed
flow and/or auxiliary fuel flow (if used) must be conducted
according to the manufacturer's specifications. Calibrations are
necessary to assure the devices are giving true readings. More
frequent calibrations than those specified by the manufacturer may
be necessary, if in the opinion of the Principal Shiprider, the
vessel has been operating under unusual circumstances such as long
and severe vibrations or in severe weather.
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Instrument calibrations are to be done according to the
manufacturer's instructions and a permanent record kept of each
calibration. This record will be examined as part of EPA's
analysis and evaluation of the monitoring data following each
burn.
(h) (Permits HQ 83-001, HQ 83-002 and HQ 83-003)
The costs for the monitoring required to assure that the
Permittees comply with the terms and conditions of the permit is a
necessary and justifiable cost of business under this Permit and
is to be paid for by the Permittees.
(h) (Permit HO. 83-003)
Destruction efficiency is the performance standard used by EPA in
determining the ability of the incinerator to destroy particular
compounds in a waste mixture, in this case, DDT, ODD and DDE.
Calculations of the destruction efficiencies of the compounds are
performed in accordance with the formula in Special Provision No.
8 above and in accordance with the protocols provided in Appendix
A of the Permit.
The Permit Program Manager will review the qualifications of the
individual(s) performing the analyses and will have the analyses
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verified by independent experts. The cost of these analyses are
borne by the Permittees.
(1)
All raw data generated during any cruise will be part of the
public domain for independent analysis and evaluation. The data
may be examined in the office of the Permit Program Manager.
11. Post-Cruise Reporting Requirements for HO 83-001. HO 83-002
(a)
Within 10 working days (90 days if destruction efficiency testing
was required) after the vessels have returned to the Port of
Mobile from an incineration cruise, the monitoring data specified
in Special Provision No. 10 is to be forwarded to the Permit
Program Manager. The Permit Program Manager will evaluate the
data to independently verify that the Permittees met the
performance standard(s) and operating conditions specified in the
permit and that the monitoring devices functioned properly.
(b)
Successive incineration cruises are dependent on a demonstration
by the Permittees that they complied with all provisions and
requirements of the Permit. Any repairs, or adjustments in
procedures must be completed by the Permittees prior to
authorization of successive cruises. The Permit Program Manager
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must authorize, in writing, successive cruises. Although this
requirement may cause a delay in incineration activities, in EPA's
judgment, it is essential to assure that incineration at-sea
activities are carried out properly.
11. Post-Cruise Reporting Requirements for HQ 83-003
The Permit Program Manager is responsible for reviewing all of the
monitoring data, including destruction efficiency results
submitted by the Permittees to assure that destruction
efficiencies of 99.99 percent or greater and a combustion
efficiency of 99.9 percent were attained, and that all other terms
and operating conditions of the Permit were met. The 90 day time
frame for submission of this data reflects the time necessary for
analyzing the monitoring data and calculating the destruction
efficiencies.
12. Contingency Plan
The Contingency Plan is included in Appendix B. The Contingency
Plan was prepared by the Permittees and approved by EPA and the
U.S. Coast Guard. It defines the safety precautions taken to
prevent incidents, the type of incidents and the response of the
vessels' MASTERS, officers and crew and Chemical Waste Management
and Ocean Combustion Service personnel, should an incident occur.
The type of incidents covered, whether in the harbor, in
transport, or at the incineration site covered in the Contingency
Plan include stranding, collision, fire and explosion, foundering
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and steering or propulsion failure. A major focus of the
Contingency Plan is the steps that will be taken to minimize the
environmental affect of any incident including the notices to be
given, the communication networks to be established and the
responses to be implemented should a particular type of incident
occur.
The Permit requires a full written report of any_ incident and any
activities carried out under the Contingency Plan within 10
working days after the termination of the burn in which the
incident occurs. However, if jettisoning the cargo due to life
threatening incidents is contemplated or carried out, immediate
verbal notification of the U.S. Coast Guard and the Permit Program
Manager is required as provided for in General Provision No. 7.
13. Reports and Correspondence
This section provides the names and addresses of U.S. Coast Guard
and EPA Officials who receive the reports, data and related
correspondence specified in the Permit.
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APPENDIX 1
POHC CASE EXAMPLES
The fallowing examples demonstrate the application of the POHC
selection criteria:
EXAMPLE 1
HAZARDOUS CONSTITUENT t CONCENTRATION HEAT OF COMBUSTION
Chloroform 3 >75
Dichloroethane 1* 3'°°
Dichlorobenzene 8 4-57
Chlorophenol 12 6-89
In this case, chloroform should be designated a POHC because of
its low heat of combustion. The most abundant constituent,
dichloroethane, should also be designated a POHC.
EXAMPLE 2
HAZARDOUS CONSTITUENT * CONCENTRATION HEAT OF COMBUSTION
Chlorobenzene 6 6.60
„,. , 4 7.78
Phenol ^
4 10.03
Benzene
Toluene 25 10.14
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Chlorobenzene, the least incinerable constituent, should be
a
th
^^
efficiency is not achieve for chlorobenzene.
EXAMPLE 3
HAZARDOUS CONSTITUENT * CONCENTRATION HEAT OF COMBUSTION
Tetrachloromethane .001 -24
Chloromethane 8 3.25
Dichloropropene 8 3»*4
Incinerability.
If chloromethane and dichloropropene are incinerated to a 99.99
wi?h tltrabhloromethane as the least incinerable POHC.
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Institute of Environmental Research. The Design of Public Consultation
Programs for Hazardous Waste Management Facilities. Environmental
Protection Service. Environment Canada. Ottawa, Canada. June
1979.
Marshall, Patricia, ed., Citizen Participation Certification for
Community Development!" A reader on the citizen participation
rocess. National Association of Housing and Redevelopment
ficials, Washington, D.C. 20037, February 1977.
pr
Of
Torrey, Wayne R., and Mills, Florence W., eds. Effective Citizen
Participation in Transportation Planning. Volume II. A Catalogue
oPrechniques, U.S. Department of Transportation. Federal Highway
Administration, Washington, D.C. 1976.
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